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HomeMy WebLinkAbout00-00831 ~ ~ ~~~ . #"" j~ ~ ~.~ k~ , h. ~~~ ~ a !i'.l! ~ ~ ~.~ ~ ;..; * >"" ~ ~~ ~ lO.~ jJ";, , ,", '. '):C~~:::~:C~:.:::~:C~;;::(:~>>:~ ,::~:C{:;~:.:::::~:.::{):.:!:;:;<c~;:;<~)_;::::~:.::~::,~~>>}: ~'s ~ ~.~ ~ ,", ~." ~ ~ lOi'. :""~.''''~~~'''''~'''~'"",''''''~'''':'''"""'r','_','''>'",,,~,""C<')':"-~"""""~-''''''''~'''''''''''.<$';""..........""".,......."...~...-.=,.,........~",,~0!'4 "'~"'__""'>''''__!'''''''!'''__!'''''~_!'',J'~<:rJt.,."~...__!,,.,.~"'__!"Y""'"":~!t..___~~~Y."""~",M..._,.,~,~_.Jt,;,:,,'~dZ',.,"_L..J'.."'W"~";"~ ~ k~ ~ ~~:~; I ~ ~.~ * ~ ~.~ ~ IN THE COURT OF COMMON PLEAS ',+,,' . !i'.1! OF CUMBERLAND COUNTY ~.~ ~ ~.~ , ~ N . ;""" STATE OF PENNA. ~ !i'.~ ;.~~ * JENNY A. STROCK -..-----....-...-..--.----.---..----.--.--.- I II No. .....~.9.Q.Q::JU 1 ,................. 19 ;"S ~ ~ ~ ~'s * ,..1'.1 <i.i.Il1:,i.:Et: L.. Versus ...fI.e~.T.li ..~.,..S.'rRQCKL ....Defe.nd.ant_. ~'S * \!~ ~ ~.~ ~ !i'.~ DECREE IN DIVORCE AND NOW, ..~.~.. .......~.~t decreed that..... JE.NNY. A. . STROCK. ........................., plaintiff, and.. EE~Tfi. .~,. .s:rEO!::X...........................,........, defendant, are divorced from the bonds of matrimony. is ordered and The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ~ ~:~ ~ ;"S e h ~, ~ ~'S ~ ~ ~ ~ i ,;;~;:::::.>>::+-,)>>::.< Pro~,honotary ...................................................-..---.~... ............ , By Attest: .0>>;-, ~ ~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~ ~ i ~~~ * ~'S * ~~~ ~ ~~~ * a a ~.~ ~ J~~. ~, < ~.'~ ~ ',+" ~ !I.I! ~ ~ ~i ~ ~.~ ~.~ ~ ~.~ ~ J'~~; 8 N ~ ~'s . ~"" ~ ~.; ~ '",; ~ ~.~ ~ ~.~ J. ~ ~.~ ~ ,.s ~ ~ '? ~ ~.I ~ ~.I ;', ~ , . l ~.",~ __,',' ~ ' I!IIII!Il!II " ,=~ '< ,,~ /O'3-(.7( /C :Ic; , .... " M~~~'~?~ 71~~'b~' , " ~ l!II!III. , _" ,~ A. ~~., ~ " ,~. - . <" .::: :-,~". ," 0' '-~ , , JENNY STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-831 HEATH A. STROCK, Defendant. : CIVIL ACTION--LA W IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~3301 (D) of the Divorce code. \ 2. Date and manner of service of the Complaint: Sheriff Service on or about May 23, 2001. 3. Date of execution of the Affidavit required by ~ 3301 (D) of the Divorce Code: June 25, 2001. Date of filing and service of the Plaintiff's Affidavit upon the Defendant: filing July 3, 2001; and service July 2,2001. 4. Related claims pending. None. I .~, ","",L . 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: I sl Class return receipt mail on August 21, 2001. Respectfully submitted, ROB SON & GERALDO " By Gerald . Robinson, Esqurre AttorneyI.D.No.27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff. " " ~~~"..". ~.~ .,J .IO.M",-"- , Plaintiff, .. . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JENNY STROCK, v. NO. 2000-831 HEATH A. STROCK, Defendant. CIVIL ACTION-Divorce o C .: ~; c~:..' ---~'. "":] ': j ri', l,' :.,") ;''-.J NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(0) DIVORCE DECREE ~'~ " ~~ -:~-' c:'.I' ..... J>r ''.) -< TO: Heath A. Strock, Defendant You haye been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301 (d) affidavit. Therefore, on or after September 14, 200 I, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit, which you may file with the Prothonotary of the Court is attached to this notice. Unless you have not already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO ONT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, P A 17101 (717) 232-7536 ~~ - ~ - .~- ~l~~ ".~ Jenny Strock, Plaintiff, IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA v. Heath A. Strock, NO. 2000-831 Defendant CIVIL ACTION--LA W IN DIVORCE COUNTER-AFFIDAVIT OF CONSENT UNDER SECTION 3301 (D) OF THE DIVORCE CODE 1. Check eifher (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim fhem before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all my economic claims with the prothonotary in writing and serve them on the other party. If! fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in this counter affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.s. Section 4904 relating to unsworn falsification to authorities. Date: Heath A. Strock, Defendant l'" , jjf;j~~o"'-~~ _1lI1 11 -,L,.,-"_,,J~~c '1!iif,r.,ilO_C"",i , - -~ ~ =" .~ '\ij (") C':> 0 ~ .,.., >'" CI:l -aU; fti ~~;Q qJG"J ~r~:' fl CI5 -",,,. .<:- ~..c:.. r-'C;o;; v ::;:: ~ ~O ""-0 ><::::: ,)? 0' , -,; Z 0 i-'" =< .r.- -'"I -<. c II""' ~"' '-' -', '~"" ,', ,-. "'" JENNIFER A. STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. .;;b:)O - fJ I Ctu~l '-r~ HEATH A. STROCK, Defendant. CIVIL ACTION-DIVORCE NOTICE TO CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Two Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ii , ,'J' .-,-- . .'k,. '^', ..'..-. JENNIFER A. STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. HEATH A. STROCK, Defendant. CIVIL ACTION-DIVORCE COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I I. Plaintiff is Jennifer A. Strock, who currently resides at 692 Sand Spur Drive, Etters, Pennsylvania. 2. Defendant is Heath A. Strock, who currently resides at 328 West Green Street, Mechanicsburg, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 3, 1994 in Shermansdale, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the Parties. II ii j" " -~- ~. , 6. The marriage is irretrievably broken. 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8" The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. 9. Plaintiff avers that there has been three children born to the Parties under the age of 18 to wit: Abbigale O. Strock, born on May 22, 1995; Sunny K. Strock, born on March 27, 1997; and Zebadiah C. Strock, born on May 10, 1998" WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 330l(c) of the Divorce Code. Respectfully submitted, ROB~RA~O , By: C~ Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street p"O" Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff i, II Ii J', ",. ..." , CERTIFICATE OF SERVICE ~ I, Gerald S. Robinson, Esquire, do hereby certify that on the ~ day of February, 2000, I caused a true and correct copy of the Complaint to be served upon the following individual by certified mail restricted delivery to addressee only by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Heath A. Strock 328 West Green Street Mechanicsburg, Pennsylvania 17055 Respectfully submitted, ROBINSON & GERALDO ~~ By: Gerald S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, P A 17110 (717) 232-8525 Attorney for Plaintiff II Ii , VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ,..; '~ , ,~ ~ '~ ' ~ilii'" \. JENNIFER A. STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-831 HEATH A. STROCK, Defendant. CNIL ACTION--LA W IN DIVORCE PROOF OF SERVICE I, Gerald S. Robinson, Attorney for Plaintiff, do hereby certify that on the 24th day of March 2000, a true and correct copy of the Divorce complaint was served on the following individual by certified mail, return receipt requested, restricted delivery to addressee only. The Acceptance of Service is evidenced by "Exhibit One" (attached). Heath A. Strock 328 West Green Street Mechanicsburg, P A 17055 Respectfully submitted, ROBINSON & GERALDO BY:~~ Gerald S. Robinson, Esquire Attorney 1.0. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff '"" .. 'D Ui D Complete items 1 and/or 2 for additional services. , = Complete items 3, 48, and 4b. ,,;,: lii C Print your name and address on the reverse of this form so that we can return this > card to you. e c Atlaeh this form 10 the front of the rnailpiece, or on the back if space does not QlI permit. :S 0 Write "Return Recaipt Requested" on the mail piece below the article number. c: D The Return ReceiPt will show to whom the article was delivered and the date o delivered. i 3. Article Addressed to: "ii ii. E o u III " seNDER: H e.~ Ii-. Wocll. ,31.'8 W. ~ S:\-. f1\.QAh~~~lffi l"'iCS's I also wish to receive the-m'ltow~ ing services (for an extra fee): ~""'.:lc;; Ie ~t ~, .. ~ ,''t!i ."' :.. DELIVERY 4a. Article Number '-1% 4b. Service Type D Registered D Express Mail Dr Return Receipt f 7. Date of Deliva q (5/'2.. 8. Addressee's Ad fse is paid) 1 Q2595-99-B..Q223 Domestic Return Receipt Exhibit A .~ and <Ii u .~ .. U> 1:i. ';j u .. II: c l; ~ 01 C u; " ~ .e " o ,., .. c .. .c ... -,'-- .. ~~' ,,,,",;-, JENNY STROCK, Plaintiff, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA: v. NO. 2000-831 HEATH A. STROCK, Defendant. : CIVIL ACTION - LAW IN DIVORCE NOTICE If your wish to deny any of the statements set forth in the affidavit, you must file a counter.affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated in May of 1999 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verifY that the statement made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: LR /2'JjOj J~~~ ,I II . . " ~ " " ,$~ Plaintiff, .. , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA JENNY STROCK, v. NO. 2000c83 1 HEATH A. STROCK, Defendant. CIVIL ACTION-Divorce NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(D) DIVORCE DECREE TO: Heath A. Strock, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301 (d) affidavit. Therefore, on or after September 14, 2001, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit, which you may file with the Prothonotary of the Court is attached to this notice. Unless you have not already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you wi11lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO ONT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, P A 17101 (717) 232-7536 "~ - . , . .. " . Jenny Strock, Plaintiff, : IN THE COURT OF COMMON PLEAS : Cumberland COUNTY, PENNSYLVANIA v. Heath A. Strock, : NO. 2000-831 Defendant. : CML ACTION--LA W IN DIVORCE COUNTER-AFFIDAVIT OF CONSENT UNDER SECTION 3301 CD) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in this counter affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.S. Section 4904 relating to unsworn falsification to authorities. Date: Heath A. Strock, Defendant ,-- ~ ,---.";' '.. ,"" '-~I "C","'.-,. <t,'_, "" ~, ~, -,. . o C ::?,'.. -Ol~ n1lj'l ~f~) (jS )> --' .;'~ r.=t::, ~\..~ ~8 C z -' -< ",: 1! II ~l N j~ Ii I' i:' Iii It "- ii [ C) CI ""1 """ ~ '- G) ['>) n':l ~= ;1"',-\ j~ ::"--; :'1 :.:::'(j [jn1 -.-:> ;'V ~:: .oj ~( . :,..,-,- _ ;.,,-",,- ,-v. ,c_'-' ~, . ' ' ~ " ~' JENNIFER A. STROCK, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLf.-ND COUNTY, PENNSYLVANIA : NO. 2000-831 v. HEATH A. STROCK, Defendant. : CIVIL ACTION--LA W IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT IN DIVORCE TO THE PROTHONOTARY: Please reinstate the Complaint in Divorce filed in the above-captioned matter. Respectfully submitted, ROBINSON &GERALDO By: l~~ Gerald S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff II I, :1 I II I Ii "'" ...; ,,,C<_ ,_~. .' -_-",', -, ' ~ ,,';;,-,--,,: .',,~-.- ,,'" .,~",.j", "--1 JENNIFER A. STROCK, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-831 HEATH A. STROCK, Defendant. : CIVIL ACTION--LA W IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT IN DIVORCE TO THE PROTHONOTARY: Please reinstate the Complaint in Divorce filed in the above-captioned matter. Respectfully submitted, ROBINSON & GERALDO By: 60)) oP d d .-hf:JI.~ Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ._1"'_'" JENNIFER A. STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. G~l[ 'tVu; HEATH A. STROCK, Defendant. NO. ..:2.000 - f'J I CIVIL ACTION-DIVORCE NOTICE TO CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are wamed that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or in'etrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Oftlce of the Prothonotary at the Cumberland County COUlihouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. " CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Two Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 (:I' --..... " II II TRUE COpy FROM RECORD In T {~SEH1{jny whafoof r i t:-t~;-'E; c~:~ ~t my hanrj ;.>i;-d ti1<l of said C ",;,' i::af,k,1'1. Pa. This ~ ji , II #'"" m__ ~. "" ' ",""" J ~p ~ ., JENNIFER A. STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. HEATH A. STROCK, Defendant. CIVIL ACTION-DIVORCE COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I I. Plaintiff is Jennifer A. Strock, who currently resides at 692 Sand Spur Drive, Etters, Pennsylvania. 2. Defendant is Heath A. Strock, who currently resides at 328 West Green Street, Mechanicsburg, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 3, 1994 in Shermansdale, Pennsylvania. II II Ii II ]1 I: 5. There have been no prior actions of divorce or for annulment between the Parties. il II ~'" -~~. -.... ",..;" 6. The marriage is in'etrievably broken. 7. Neither Party is a member of the Anned Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. I I 9. Plaintiff avers that there has been three children born to the Parties under the age of 18 to wit: Abbigale O. Strock, born on May 22, 1995; Sunny K. Strock, born on March 27, 1997; and Zebadiah C. Strock, born on May 10, 1998. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301 (c) of the Divorce Code. Respectfully submitted, II I , I I , '1 'I :] I. 'I " II ,I ;1 I, 'I II i\ :B~ Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff .1t<I1ll""'~ . ~, J_ -~~, CERTIFICATE OF SERVICE ~ I, Gerald S. Robinson, Esquire, do hereby certify that on the ~ day of February, 2000, I caused a true and correct copy of the Complaint to be served upon the following individual by certified mail restricted delivery to addressee only by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Heath A. Strock 328 West Green Street Mechanicsburg, Pennsylvania 17055 Respectfully submitted, ROBINSON & GERALDO ~~ By: Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PAl 711 0 (717) 232-8525 Attorney for Plaintiff ,..,1$""'" _,~..~, illI~l ,,: VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of i8 Pa. c.s. Section 4904, relating to unsworn falsification to authorities. / / I I ,I I' II II " Ii 'I 1, Ii II II II i! 11 iI J" ~ ~ ~ ~ - .-" ,j-- X_._" - ~ --~-. .,A.~~~L:'" _ JENNY STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA: v. NO. 2000-831 HEATH A. STROCK, Defendant. CIVIL ACTION - LAW IN DIVORCE NOTICE TO CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or armulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Two Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 . ~ , , no, I'd""'. JENNY STROCK, Plaintiff, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-831 HEATH A. STROCK, Defendant. CIVIL ACTION - LAW IN DIVORCE AMENDED COMPLAINT IN DIVORCE COUNT -I -DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Jennifer A. Strock, who currently resides at 692 Sand Spur Drive, Etters, Cumberland County, Pennsylvania. 2. Defendant is Heath A. Strock, who currently resides at 328 West Green Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 3, 1994 in Shermansdale, Pennsylvania. 5. There have been no prior actions of divorce or for armulment between the Parties. 6. The marriage is irretrievably broken. .~ " , , , ' '.c..__"~_,o, -'" ol .~: 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. 9. Plaintiff avers that there has been three children born to the Parties under the age of 18 to wit: Abbigale O. Strock, born on May 22,1995; Sunny K. Strock, born on March 27, 1997; and Zebadiah C. Strock, born on May 10, 1998. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301 (c) of the Divorce Code. COUNT II - DIVORCE UNDER SECTION 3301(D) OF THE DIVORCE CODE 10. Plaintiff incorporates paragraphs 1 through 9 of the Complaint in Divorce as fully set forth herein. 11. Plaintiff and Defendant have been separated and residing separated and apart with no cohabitation for a period of at least two (2) years. ~~ > I" WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a Decree in Divorce under Section 3301 (d) of the Divorce Code. Respectfully submitted, By: Ger a S. Robinson, squire It orney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ~ '-,~ "." [, 'l! ... VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~-- d "" ..d "ilIill!iio- ,--'-.'~. , , ,--1..", -" . ," ,,,',L 1iit~- CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the _ day of April, 2000, I caused a true and correct copy of the Amended Complaint to be served upon the following individual by certified mail restricted delivery to addressee only by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Heath A. Strock 328 West Green Street Mechanicsburg, PA 17055 Respectfully submitted, ( By: Ger d S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 ~ Attorney for Plaintiff - ~. ..- ""1 .' JENNIFER A. STROCK, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-831 HEATH A. STROCK, Defendant. : CIVIL ACTION--LA W IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT IN DIVORCE TO THE PROTHONOTARY: Please reinstate the Amended Complaint in Divorce filed in the above-captioned matter. Respectfully submitted, ROBINSON & GERALDO By: G raid S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff j" .... .. I SHERIFF'S RETURN - REGULAR CASE NO: 2000-00831 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STROCK JENNIFER A VS STROCK HEATH A GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon STROCK HEATH A the DEFENDANT , at 0011:30 HOURS, on the 22nd day of June 2000 at 328 W GREEN ST MECHANICSBURG, PA 17055 LARRY EVANS (ADULT ROOMATE by handing to OF DEFENDANT) a true and attested copy of COMPLAINT - DIVORCE together with REINSTATED and at the same time directing His attention to the contents thereof. Sheriff's costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers: r~~~t:~ R. Thomas Kline 06/22/2000 ROBINSON & GERALDO Sworn and subscribed to before BY:A~/.J~ Deputy Sher' me this t ~ day of 9. Or olAW A.D. ~,,"-(] ht~J(;'d. # rothonotary , ,~ --~- - , u. ,~~-__ -~''-' "co__ -,co, ,,,~,.-,,,,,,,j"k-> ~.I JENNIFER A. STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-831 HEATH A. STROCK, Defendant. CIVIL ACTION--LA W IN DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Complaint in Divorce was served upon Heath A. Strock, the Defendant, on June 22,2000 at 328 West Green Street, Mechanicsburg, Cumberland County, Pennsylvania by handing a copy of the complaint to Larry Evans, the Defendant's roommate. The signed receipt is attached hereto as Exhibit I. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certifY that I am a competent adult not a party to this action. I verifY that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsficationto authorities. Respectfully submitted, ROBINSON & GERALDO Dated: 0/~J{j) . By(iQJU'M ~ .M~ Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff II ., SHERIFF'S RETURN - REGULAR CASE NO: 2000-00831 P COMMO~rwEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STROCK JENNIFER A VS STROCK HEATH A GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon STROCK HEATH A the DEFENDANT , at 0011:30 HOURS, on the 22nd day of June , 2000 at 328 W GREEN ST MECHANICSBURG, PA 17055 LARRY, EVANS (ADULT ROOMATE by handing to OF DEFENDANT) a true and attested copy of COMPLAINT - DIVORCE together with REINSTATED and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers: ~/J?~..~~ R. Thomas Kline 06/22/2000 ROBINSON & GERALDO Sworn and Subscribed to before me this day of By ~ A-1J~ lJ~J2. . i;;;: Deputy Sher~ A.D. Prothonotary -_ _ "",,,n q ~- "., ,.1. '~",.' , SHERIFF'S RETURN,~ REGULAR CASE NO: 2000-00831 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STROCK JENNIFER A VS STROCK HEATH A CPL MICK BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE & AMENDED was served upon STROCK HEATH A the DEFENDANT , at 1024:00 HOURS, on the 23rd day of May , 2001 at 328 W GREEN ST MECHANICSBURG, PA 17055 by handing to CHRISTY GEPHART a true and attested copy of NOTICE & AMENDED together with COMPLAINT IN DIVORCE and at the same time directing Her attention to the contents thereof. , Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 5.58 .00 10.00 .00 33.58 r~~~ R. Thomas Kline me this .30 ~. day of OS/24/2001 ROBIN::~~~ Deputy eriff Sworn and Subscribed to before fut,r dct:; , A. D. q UL-CL~ ~ ~rothonotary , ,- -'" ,-.-- '>., -,~ ':,.,,-~,"" -"--''',,;1 _ ~,~_"'-"j_ ~ , JENNY STROCK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-00831 HEATH A. STROCK, Defendant. CIVIL ACTION- DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Amended Divorce Complaint was served upon Heath A. Strock, the Defendant, on May 23, 2001 at 328 Green Street, Mechanicsburg, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certifY that I am a competent adult not a party to this actio!).. , , ! I verifY that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unswom falsfication to authorities. Respectfully submitted, Dated: l By: G d S. Robinson, squire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 , I il ~ . .~j .~ A' SHERIFF'S RETURN - REGULAR CASE NO: 2000-00831 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STROCK JENNIFER A VS STROCK HEATH A CPL MICK BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE & AMENDED was served upon STROCK HEATH A the DEFENDANT , at 1024:00 HOURS, on the 23rd day of May , 2001 at 328 W GREEN ST MECHANICSBURG, PA 17055 by handing to CHRISTY GEPHART a true and attested copy of NOTICE & AMENDED together with COMPLAINT IN DIVORCE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 5.58 .00 10.00 .00 33.58 ~~~ R. Thomas Kline me this day of OS/24/2001 ROBINSON & GERALDO By, ~-/-~ .------a ~ .' , p,." Deputy 'eriff Sworn and Subscribed to before A.D. Prothonotary EXHIBIT ~ II a 1 .- , .~ ~-~ . -,. ,_.l -1~aL~'igook ~~-" .. .- JENNY STROCK, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 2000-00831 HEATH A. STROCK, Defendant. CIVIL ACTION- DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Amended Divorce Complaint was served upon Heath A. Strock, the Defendant, on May 23,2001 at 328 Green Street, Mechanicsburg, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certifY that I am a competent adult not a party to this action. I verifY that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsfication to authorities. Respectfully submitted, Dated: t By: G d S. Robinson, squire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 " ~ "'ci, .' SHERIFF'S RETURN - REGULAR ,. CASE NO: 2000-00831 P .' COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STROCK JENNIFER A VS STROCK HEATH A CPL MICK BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE & AMENDED was served upon STROCK HEATH A the DEFENDANT , at 1024:00 HOURS, on the 23rd day of May , 2001 at 328 W GREEN ST MECHANICSBURG, PA 17055 by handing to CHRISTY GEPHART a true and attested copy of NOTICE & AMENDED together with COMPLAINT IN DIVORCE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 5.58 .00 10.00 .00 33.58 ~~~ R. Thomas Kline day of OS/24/2001 ROBINSON & GERALDO /',/") /2 /' / / / / / By: ' d' / ./ /' -~.~j ~/ /fi ,:d:::if..~ ' r/' Deputy eriff ' Sworn and Subscribed to before me this A.D, Prothonotary EXHIBIT II :;; ~ 1 ~ :i . ' " ',,-'-;;.. ,,' ,- - '- ,,,",...~ "",,<,' '1; > " ,-I -1_, JENNY STROCK, Plaintiff, v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-831 HEATH A. STROCK, Defendant. : CNIL ACTION-DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Plaintiffs Affidavit was served upon Heath A. Strock, the Defendant, on Ju1y 2,2001 at 328 Green Street, Mechanicsburg, Cumberland County, Pennsylvania. The signed receipt is attached as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adu1t not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsfication to authorities. Respectfully submitted, Dated: By: Ger d S. Robinson, Esquire orney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff 1 ~"., JENNY STROCK, Plaintiff, v. HEATH A. STROCK, Defendant. -">1'",," , -~:""-~i"til;['i ,,-,' '- , ... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-831 CIVIL ACTION-DIVORCE ACCEPTANCE OF SERVICE I, Heath A. Strock, certify that I accepted service of the Plaintiffs Affidavit. 1'101l/IJ4}/ Date '11 [}/6/ II Ii Heat A. Strock 328 est Green Street Mechanicsburg, PA 17055 EXHIBI:T ~ Z i 1 ~ UUJ ... 'iIIi .....~~!luJ~$II\'..L.I""" '"- fj '",:-- t: ,~~. - ,~- . ."", -" -, JENNY STROCK, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-831 HEATH A. STROCK, Defendant. : CIVIL ACTION-DIVORCE PROOF OF SERVICE The undersigned makes the following retum of service: the Notice of Inten . Request Entry of Section 3301 (D) Divorce Decree was served upon Heath A. Strock,.the , . Defendant, on Augnst 21, 2001 at 328 West Green Street, Mechanicsburg, Cumberl~d ~oun~, Pennsylvania. The signed receipt is attached as Exhibit 1. __I ,1iIiIru \ , , ~ )- -', c.-,j SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certifY that I am a competent adult not a party to this action. I verifY that the statements made in this affidavit and retum of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: 1/4 j/ By: Gera S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 11110-5320 (711) 232-8525 Attorney for Plaintiff --.,1 ',Co ~ -, '-_,,",,- - ,':", -I I' I Complete items 1, 2, and- 3. Also comjJ,i$te! item 4 if RestrictE;!d De,livery is desired. i' , . Print your name and address. on the :revers'e so that we can return the card to you.: : ; . Attach this card to the back of the mailpiec~, or on the front if space permits. ' 1. Article Addressed to: 1101771 I!. .5 lZrJ tJC- .3,,2 Y !JkST (J, Rc;74.5~ur ! 1 I 111 G'tIlI4NICS8t1e6/l?4mss ~'. :~~ic~ TYP,e : ~ified Mail 0 Express Mail 1 p Registered ~rn Receipt for Merchandise - q Ins4red Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. 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