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HomeMy WebLinkAbout00-01802 F:lFlLES\DATAFILE\Gendoc.cur\10055-com.1I1de Created: 03123/00 12:05:41 pNl Revised: 03/23/00 12:17:49 pM ].0055.1 , RICHARD ELLIS PIKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, NO. 2000- lfj~ CIVIL ACTION RUTH LODEMA PIKE, Defendant IN DIVORCE NOTICE TO DEFEND AND 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 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNVLMENTIS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HAVE ALA WYER 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, Pennsylvania 17013 Telephone (717) 249-3166 , . " ~'" ".. , , ~., c.~. ,--, " - RICHARD ELLIS PlKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000- J 9'0 :2-- CIVIL ACTION RUTH LODEMA PIKE, Defendant IN DIVORCE COMPLAINT 1. Plaintiffis Richard Ellis Pike, who currently resides at HQ, CO. Building 420, P.O. Box 44, Carlisle Barracks, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Ruth Lodema Pike, who currently resides at 704-K Stanwix Circle, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 5, 1995 in Norfolk, New York. 5. There have been no prior actions of divorce or for annulment between the parties, 6. The marriage is irretrievably broken. 7. Plaintiffhas 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. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO By -rLu-c... .~ Thomas J. W; li s, Esquire Ten East Hig treet Carlisle, P A 17013-3093 (7l7) 243-3341 Attorneys for Plaintiff Date: March 23, 2000 "k , , ~- , - ~ ~ ~~ ~'" ",'~ ~. VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of18 Pa, C,S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ---~ ~--'ZSS ".' '. Richard Ellis Pike """._~~ ~ "-~.. ' ~ - , ,. ~ rp 'l:\ Lv '" ~ "'-1 "" w E;' ;'- , r' ~,,, .- ~ "'.=, "'~ ~ ";'....,.,.,~,_ or _',"~,,_ _,' , >~ _ ~. ~ ~,j~'I'II~~f.!~ _n[ " <::> 0 c: 0 .. s:: :l!: ~~ ~lJ "OJ '''"' mrn :;0 ,- 2::0 N O~ 6i~ w ~_O ~~- C::( r'o """V ~.r=R '< ~8 :Jt 00 ~m 5c ~ ~ ~ en ?G to --< 6l ~ Jt ~ "" -- "<1 -J "" I.r V- cr , , , d> e ~ (j t r ~~tj~~lj!lfQlfl,jll!ll_l_I":'_^__'lR'Jll!@iMl"" F: \FILES\DA T AFILE\Gendoc.cur\! 0055-aos.l/tde Created: 03123/00 12:05:4! PM Revised: 03128/00 12:!1:13PM 10055.1' RICHARD ELLIS PIKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1802 CIVIL ACTION RUTH LODEMA PIKE, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Ruth Lodema Pike at 704-K Stanwix Circle, Carlisle, P A 17013 on March 24, 2000 by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Ruth 1. Pike" and dated March 27, 2000. I ~~;' tvJL~ Thomas J. Williams, Esquire Swom to and subscribed before me this.<,V-f'day of March,2000. ( W -. /J ~ . "..l<1- . ~PUbliC OiIIlIotarial Se~ TrJaIS1)~oad, Nci~_' Carlisle Boro, cumber,l,a, nd MY 'Com"slon Expires 01;1.-2 0 ., . " ......... Iii'.g td-j'" st- ,. 424 03110 971 RECEIPT FOR CER~;~IED MAIL NO INSURANCE COVERAGE PROVIDED NOT FOR INTERNATIONAL MAIL (See Reverse) !IIDvVO ~ ~ ~ ~ = N ~ = ~ o ~ c,; .,; " " Postage s ' _33 ;, f-o Certified Fee Special Delivery Fee Restricted Delivery Fee .2. ,- . ,.tS' Return Receipt showing to whom and Date Delivered "' all 0> ~ " c :> .., g Postmark all '" E ~ & lJl ... S..5. 7.3 .. .. '" 'iij lJ Complete items 1 and/or 2 for additional services. II) Complete items 3, 4a, and 4b. f [J Print your name and address on the reverse of this form so that we can return this ~ card to you, l! D Attach this form to the fronl of the mailpiece, or on the back if space does not l>> permit. S a Write "Return Receipt Requestsd" on the mailpiece below the article number. [J The Return Receipt will show to whom the article wlils,dejivered and the da1e 5 delivered. . """. , ~ 3. ~rticle AdNsse~ :0: J n ,'~~:::'!_ ! ~'.I~~,}ltl' ta.J I~ 9 f.\ Il 0 1..1 I also wish to receive the fallow- ing_services (for an extra fee): 1. D Addressee's Address 2. ~ Restricted Delivery 4prt4~umber 4b. Service Type D Register.ed o Express Mail :;:. Return Receipt for Merchandise I ~ Certified o Insured DCaD 7. Date of Delivery :3 1-1 00 ~_ 8. Addressee's Address (Only if requested and Y fee is paid) 102595-99-8-0223 Dqmestic Return Receipt I , " Gi: u, 'i: .. lJl ~ Q.' .~ ' !: c ~ :>, 'ii, 0:, 0> c 'iii :> ~ .e :> o ,.. ... c .. .c, 1-, ) l ~~ t ~ (') C ? -oED [!l n-' ~~~r L_( (j) ','-' <" !i~ ~ """ ~~ ->~",."'..., ", ,..~lI!l!1!l~~!"'~~~~~-l~!l~~.,:."~~_"""JIIlJ~J:!!1!f' "",,'-,, ,-",. o (::> :x );;",," :"0" 0''') C''''''' o ., :=2 H'1;R :~g2j :-;.]<.:) ~-;- ._~ , -;::;:--n ~~; ~~ U .,=..1 '1> 'j,) -< :..,J en <..) F:\FILES\DATAFILB\Gendoc.cur\I0055-PRA.1Jtde CTeated:03123/0012:05:41PM Revised: ~1l0l00 11,23,22 AM IOO~.l~ RICHARD ELLIS PIKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1802 CIVIL ACTION RUTH LODEMA PIKE, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above captioned case settled and discontinued and issue a certificate reflecting same. MARTS ON DEARDORFF WILLIAMS & OTTO 1tvJJ.. ~ ~ By! Thomas J. Wi i s, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: April 10, 2000 -;j "-"'_m~ " , . (') c <" ~~! (flY' 2=e, "'" ~;::~ ~~, ";'-'c.::: .;:;.~ :=i --< I~'"' ~~""', " "..........""I'~ -<, ,,...,mru_ _~""~~~~ ~ ~ ~~l!5~~~mIIii!!iIlmm!l~~~.IIN C} (:.J bo u ;:,::; f'0 r0 ,;:;;> ['v r..... ~il L' 5;1 ." =< lilt r'lTLIHI , .