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Home My WebLink About00-01723 . .. - + 'I' 'I' + 'I' C1':to +. ,., '" ;t. 'I' '" + :f."'''''l' .. :Ii'!''!' +;1'+'1' +'1' , . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . KATHERINE A. SHERLOCK STATE OF PENNA. . 1723 Civil 00 . Plaintiff No. . . VERSUS RAYMOND F. SHERLOCK . . . Defendant . . . . . . DECREE IN DIVORCE dt~:(\{PM. . . . . . . . . e 2000 AND NOW, Kathe . , IT IS ORDERED AND . . . DECREED THAT , PLAINTrFF, . . . . . . . . Raymond F, Sherlock AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . 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; None . . . . . . J. c?ud. ~TA"T . . . . . . . . . . . . . . . . . . . ;f. + + 'I' 'I' . + 'I' . .. . '1''1'+++ +++++++'1'+.++++ ++++ ++'1'+'1'+++++++'1'+++ +++++++ '" + 'I' 'f 'I' . , . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . <, '- ' ~..:~" ~ <f -:: .. '. "^. .. ..;'I"~- , ...~ ~ ?'N'4? ~-~-~&4~ ~Pf-&CJ '71~ ~~ 'Y' -~ , Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. SHERLOCK, Plaintiff v. NO. 00-1723 Civil RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~ 3301(c) 3301(d)(1) of the Divorce Code, 2. Date and manner of service of the complaint: March 23, 2000 per the amended acceptance of service filed of record, 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by plaintiff: June 27, 2000; by defendant: June 29, 2000. (b)(1) Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code: N/A. (2) Date of filing and service of the plaintiff s affidavit upon the respondent: N/ A. . '. 4. Related claims pending: All economic claims raised of record have been withdrawn. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/ A. (b) Date plaintiff's Waiver of Notice in ~ 3301 (c) Divorce was fIled with the Prothonotary: July 6, 2000, Date defendant's Waiver of Notice in ~ 3301 (c) Divorce was fIled with the Prothonotary: July 6, 2000. /LO~7/t~ Counsel For Plaintiff Dated: August 3, 2000 2 '. > 0 = 0 c <=> " s: :l> :::; "UOJ ~ '-{'i ::n mm G5 ~-;m Z:rJ , z:c::- :00 (J?..~ .i:C' 8' -<2 :-.9 kCJ -0 ~-H ):>0 ::it: zO ~o -m C 9. ~ w 55 <n -< Theresa Barrett Male Supreme Court #46439 115 Piue Street Harrisburg, PA 17101 (717) 233-3220 Couusel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KATHERINE A. SHERLOCK, Plaintiff v. NO. 00, 17a-3 iu;J RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA V,B' 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 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 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, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAIffi 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY TIlE COURT:t J. Theresa Barrell Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaiutiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A, SHERLOCK, Plaintiff v. (,) - ., .-.-:: NO. thJ. 17:23 ~ f ~ RAYMOND F, SHERLOCK, Defendant CIVIL ACTION - DIVORCE COMPLAINT IN DIVORCE Count I - Divorce 1. Plaintiff is Katherine A. Sherlock who currently resides at 3834 Pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania since in or around March 13, 1993. 2. Defendant is Raymond F. Sherlock who currently resides at 3834 pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania since in or around March 13, 1993. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The parties were married on August 27, 1983 in Watertown, New York. 5. There have been no prior actions for divorce or annulment between the parties. 6. The grounds for divorce are: a. the marriage is irretrievably broken. b. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 7. Neither party is a member of the armed forces of the United States or its allies. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Wherefore, Plaintiff requests the Court to enter a Decree in Divorce under sections 3301(c) and 3301 (a)(6) of the Divorce Code, as amended. Count II - Equitable Distribution 9, Plaintiff incorporates by reference paragraphs 1 through 8 above. 10. During the marriage, Plaintiff and Defendant acquired real and personal property. Wherefore, Plaintiff requests the Court to enter an Order equitably dividing all the marital property. Count ill - Alimony II. Plaintiff incorporates by reference paragraphs 1 through 8. 12. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 13. Defendant has sufficient assets to provide continuing support for Plaintiff. Wherefore, Plaintiff requests the Court to enter an order granting her alimony. 2 Count IV - Alimony Pendente Lite, Counsel Fees and Expenses 14. Plaintiff incorporates by reference paragraphs 1 through 8. 15. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 16. Defendant has sufficient assets to provide continuing support for Plaintiff. 17. Plaintiff has retained counsel to pursue this action and has agreed to pay her attorney a reasonable fee. 18. Plaintiff lacks sufficient funds to meet the costs and expenses of pursuing this action, including counsel fees and the costs to retain experts to value the marital assets. 19. Defendant has sufficient assets to provide alimony pendente lite, counsel fees, costs and expenses for Plaintiff. Wherefore, Plaintiff requests the Court to enter an order awarding Plaintiff alimony pendente lite, interim counsel fees and expenses; and thereafter awarding Plaintiff such additional counsel fees and expenses as the Court deems just and appropriate. L~~ Theresa Barrett Male, Esquire Supreme Court # 46439 115 Pine Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: March 21,2000 3 VERIFICATION I, Katherine A. Sherlock, state upon personal knowledge or information and belief that the averments set forth in the foregoing document are true. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. ~:i{~Lk ,2000 Date: ""' > lK ~ ~ ~ ~ ~ '.J~ '-.1 <. su ZJ <~ ~ ~ \~ N S) ;'1 C: IS ~ " ') \S ~ ~\\ ~~~ tt (") c s:: "DOl f'i--cpt ~~~ <fjJ;-. -<z ~r5 >~ z........ >0 c ~ <::> <:::> ~~ C) "1"1 :7.1 -- h':~ -:Jm ~'J~ '~1.:' O-H gM ~ ~ :::r. ". -:.0 N '" ",. 3: 9? ,... Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff . . . COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA KATHERmE A. SHERLOCK,. Plaintiff v. NO. 00-1723 RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. ~~~ Date: March ~c9- , 2000 -, .;. 0 c::> ~ c 0 ;;;; ::<7"'- ._, ;:g~ -0 ::, ::0 ~ , r- z::r) I -Jm ZC r ';)l (f;.:'~" 9_) -<2 kV "". -.-:-.; -:;."- :.D ~O 3 ~o >2 'P. -om -, ~ U1 ?5 ~ -< Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN'SYLV ANIA KATHERINE A. SIF.clli.OCK,. Plaintiff v. NO. 00-1723 RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE AMENDED ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. ~~ Date: March 23, 2000 .. '" ~ c:::> 0 c:::> -n 5: t- :1": -oe(1 - '- _,.\:D iT\fT: .- . r:: :2::0 I ".,f"';i ~<;; 0"' 'ri~ :l.z '9=' <;:20 4J ;;k,-" _ -.1 ~8 ::& ' - ~~ - S J>C: ., ~ - ~ .<="' - Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. SHERLOCK, Plaintiff v. NO. 00-1723 Civil RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT L 22, 2000. A complaint in divorce under S 330l(c) of the Divorce Code was filed on March 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint, 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in tf1is affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: June d1 ,2000 -. ". (;) <::> O. c: <::> ';1 s:: C- ...; -om = I-n mm ;- IT1;= 2::0 I ~g~ 2C ~2: en .", '--" " ~, r:c:J -0 -r-,-, ~(;) ---,.., :3: C?C5 )>8 ""'m :=i 2 ?5. =<! - .~ -< . Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, P A 17101 (717) 233~3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. SHERLOCK, Plaintiff v. NO. 00-1723 Civil RAYMOND F. SHERLOCK, Defendant CNIL ACTION - DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary . I verify that the statements 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. Ka herine A. Sherlock Date: June ) 1 ,2000 , -. -, () 0 0 c 0 -n s:: <- :d "'Ow s; r;1"""1'7 lTlrn , Z:o I '~',m Ze- ,,o? (f) '.' "'" -<2: ':?O '-::0 -0 --1-,. ::;;; ~ 0::0 z:O -:;.-C) =0 om )>c ?5 z ~ ~ -< ...-..... Theresa Barrett Male Supreme Court #46439 l1S Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. SHERLOCK, Plaintiff v. NO. 00-1723 Civil RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. 22, 2000. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on March 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of fIling and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements 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. ~f~~ Date: June r/l- '1 ,2000 -. .0 c:> 0 c = -n .. '~~ {~-). .. ~ '- ....{ , '-~Eb s;'- ~- rnrTI , ~'1i~ 2::0 , -"1m ZS :0' :~~9 ~L ~::4~ <CJ -0 ,J...:D ~8 ~ 20 - 6n. :>c ., .o.t ~ 5:; J;:"" '< '. . ..,.- . Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. SHERLOCK, Plaintiff v, NO. 00-1723 Civil RAYMOND F. SHERLOCK, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the prothonotary . I verify that the statements 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. ~i9lL Date: June Jr ,2000 .' .- 0 C) 0 c: 0 -1'1 s:: <- ::::! um ~ '~~~ mrn 1= Z:c , ,-' z'- :',,9 ~~ en .". t~('j !;OO -0 "-;-" ~o Z 0::0 ~.-o ;;;8 6m z: ~ ~ .t:" -< ...,,~ - Theresa Barrett Male Supreme Court #46439 115 Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. SHERLOCK, Plaintiff v. NO. 00-1723 RAYMOND F, SHERLOCK, Defendant CIVIL ACTION - DIVORCE PRAECIPE To the Prothonotary: Please withdraw all economic claims raised of record in the above-captioned action. L~~ Theresa Barrett Male, Esquire Supreme Court # 46439 115 Pine Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: August 3, 2000 ~ - ~j_llt 0 0 0 c a ,1 s: :: ~-,~ -ace ,~:D mgj G"") :z . '<'r- z. I ~m ~~ .,,- :52 \::::i ~o ;:20 -0 -r, ~o :3; o:!l $@ z~ ~ ~ w ~ C"\