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Home My WebLink About00-03798 -- "~ . . . . . . . . . . . . . . . . . . . . . . . . . . , . , :f. :f.;!;:f.:+::f.:+::f.:+: :f.;!;"''''''''''''' '" . :f. "'''':f.''':+: .. '" "'''':+: :+: "';Ii"';!;"'''' :+: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Susan R. Stake. PENNA. STATE OF 3798 Civil Term 2000 Plaintiff No. VERSUS Charles L. Stake, Defendant DECREE IN DIVORCE AND NOW, O~4- /r , 2JltH' , IT IS ORDERED AND DECREED THAT Susan R. Stake , PLAINTIFF, . . . . . . . Charles L. Stake 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; . . . . . . . . . _ .AI, AJ E By TH~.U4 d A7f~ PROTHONOTARY . . . . . . . . . . . . . . . . . . . . . "''''''' "''''''',.,''''''''' .. '" '" "'''' '" ... . . .!liMO .~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . ~ ,j _, '_0' _, r"'_~~~._ ,__,~ _ ..', ~_~_"7 -","'" , ., /,(J /f.?itJ It) /f( .t:Jc , - -, '""" ,~ ~ i- t "..". ., " '. IW'C~~64~ 77~~~ ~~. _"_ ~, ~" '", ,!lPl ~,.,."._ "', " ~9:" , ~_, ~-""l""'~< , ...","'", .~- "'...... -~ '-- -..""'-t;ilii, SUSAN R. STAKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 00 - 3798 Civil Term. CHARLES 1.. STAKE, Defendant : ACTION IN DNORCE 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 93301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted deliveJY. return receipt requested. delivered on: June 23. 2000. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: October 10, 2000. By Defendant: October 12, 2000. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: October 16, 2000. Respectfully Submitted: Date: /0-/6 I t)O e Adams, Esquire .0. No. 79465 117 South Hanover 8t. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ~~ '"~. ~ , ~'~[f.~Ja.i~~I~.-- .. , SUSANR. STAKE, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 06- 3"'19P Cud c,-~I'Y) CHARLES 1.. STAKE, Defendant : ACTION IN DNORCE 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. Where 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 Office ofthe Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Bar Association 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 1< ~1itI~I..J;l,- . .. SUSAN R. STAKE, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA No. M. 3'19F CWJ./~ CHARLES 1.. STAKE, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Susan Stake, an adult individual, who has resided at 41 Walnut Street, Carlisle, Pac 17013, since December 15,1999. 2. Defendant is Charles 1.. Stake, an adult individual, who has resided at 79 Old State Road, Gardners, Pa. 17342, since May 14, 1999. 3. Plaintiff and Defendant have been bona fide residents ofthe Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 21,1991 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. ., ~~" W")l<~_.f!Ildr.t_""'.;.:'d . " ... 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint 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 falsification to authorities. ~C/!~ Susan Stake, Plaintiff Respectfully submitted, Date: cp lIfe; /00 ~od(}M'~ ane Adams, EsqUlre LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -"^,-"",,'." ';, ,.c_;;., "_.,-~"' -'\IiMi~u t~,-,~<t~~;.;;Ql1i..;. ~.~ '"~ '" it> If:. ...0 ~ .0 C, ~ ~-. ~ ~ .,() ::a ~ ~ ~ frt ~ ~ ? g i;tJ ~ jt " o M'~ ~~r if; '_-,~ ~@~' s: c-:> ~=r-:; -1--,."-_" ~c 2:" ~ ~jll_"-~O;;'~ [5 r-~J c=~ i} -::-.) h) .... ',- ,- i5 ~"J -< . "~ ,,-- ~~~~"'ii-_ SUSAN R. STAKE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 00 - 3798 Civil Term. CHARLES L. STAKE, Defendant : ACTION IN DNORCE AFFIDAVIT OF SERVICE OF THE COMPLAINT AND NOTICE TO DEFEND AND NOW, this June 26, 2000, I, Jane Adams, Esquire, hereby certify that on June 23, 2000, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Charles Stake 79 Old State Road Gardners, Pa. 17324 DEFENDANT Respectfully Submitted: ~~ Jane Adams, EsqUIre LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF '0' " ,~~"'" ;, "l~illi!l}ikJlIilIIiIt!lIJll_!i~i!i\illjlPIiiiW""Jl<~ili..l1Mi -,.- o~-_~~..... ~-<'" ~.. ." ~liiirl_ ~"" ~l~'U ~ g 0 " t... '4 im c: ::I:fQ % r.... .. ~ N -Urn 0'\ ~OCJ 0' ~ ~~ ~ N ~ W -< ~. " '" 7.i " " :;; ~ " '" SENDER: III Complete [lems 1 and/or 2 for additional services. !Ill Complete items 3, 4a, and 4b. :II Print your name and address on the reverse of this form so that Wfl can return this card to you. 1lI Attach this form to the Iront of the maHplece, or on the back if space does not permit. ".III Wrj.te "Return Receipt Requested" on the mailpiece below the article number. !II The Return Receipt wlIl show to whom the article was delivered and the dats delivered. I also wish to receive the following services (for an extra fee): 1 . 0 Addressl?e's Address 2~~Restrlcted ~~ivery . Consult postmaster for fee, 4a. Article Number 3 3. Article Addressed to: - "- '" " 1 oqS- &! E " " a: '" " 'in " .E 4b. S~rvice Type o Registered D Express Mail D Return Receipt for Merchandise 7~ Date of Delivery (e -;;2.3 - o(!l 8. Addressee's Address (Only If requested and fee Is paid) -'=-----~---'--~-~~------~ 102595-58-8-0229' ~Certifled o Insured o COD Domestic Return Receipt .; " "E " U) ~ o >- '" " " ;:: - ~"..; . ..... ... .. SUSAN R. STAKE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY, PENNSYLVANIA V5. No. 00 - 3798 Civil Term. CHARLES L. STAKE, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on June 20, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3, I consent to the entry of a final decree of divorce, 4, I understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or expenses, if I do not claim them before a divorce is granted. I understand that the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. Date: L()'/O-Oc) ~i2JM ~0 Susan R. Stake, Plaintiff - WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 633011c) OF THE DIVORCE CODE 1. I consent to 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. ~l-A~#~ Susan R. Stake, Plaintiff Date: 10'/0- C90 JilftJ" !il.j _~~.~""""~~~I!<~"lilktM~~~1 ^"' . - ~_il!iUi'" (') c -oF~ rnrr: .z: ::"''1 ::?'l-'. 05~~ -<~'- ~C: :P~ 2(.' ;;:cJ 2 =< .il1lll'~IlioiiiiiWo';~ i 1--"_'1 "i ',' il ::1 l:i :~ ," ::i :!I ii, i'l 'I I' Iii Iii ';1 ,I "-:-;1 <:;:) a n ~.., () -r; ;-:..:;J dg 7~ ~~~ i ~?:f i:i':~ ~O i;i :J.J -< 0', ~TJ ~...". ~. i~,:? .... " -",__',^0,' _~"";'i 5-' '" ,.,',{C',~ !,,,,~-'->-=~-;"^' '~-2"-.-;-M":.."',N,-d, -~,~"", ~. ,--- :'J SUSAN R. STAKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3798 CIVIL TERM CHARLES L. STAKE, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: I. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: October J;l. ,2000 ~(l- ;ts~ ~ CHARLES L. STAKE ~,~' Dale " ~,,- ," " - (') ,--' {~ C C) .. ~ ~l ~-: ;:::J -or-C;- \. .J F,t~C --I Z:'-C" 2:C C"'\ ~:::;~: yC.; ,,0 ~C~. , :::~(--l 1'0 "--" )>c: ~, .~; .','':' 1::- ~ -j -, . -,- _". ~ "''''",,, -, > '_',,"^"-"'T".__ ". "' ,'_ -'"".' ,-',,",., 'dd''''"'''':.;: SUSAN R. STAKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3798 CIVIL TERM CHARLES L. STAKE, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 20, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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 statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: October J:L , 2000 P~eA- ~ ....- CHARLES L. STAKE ,- -", ,~" '..~",--~~:~-;:"'CS"'" '"";~_',_~;,_ _ , '^__'.-"~"__-: SUSAN R. STAKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3798 CIVIL TERM CHARLES L. STAKE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a fmal Decree of Divorce without notice. 2. 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. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: October /:1 , 2000 ~~(4 ~7~> CHARLES L. STAKE Defendant