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HomeMy WebLinkAbout97-02926 ( ~ ~ ..... . .. .~ ~ . ~ ~ " . ~ . . , r~~~~~-~-----~-----~-_._~----~ , ~ IN THE COURT OF COMMON PLEAS $ ~ ~ 8 OF CUMBERLAND COUNTY ~ ~ tf' @ ~ ~ , STATE OF ~ PENNSYLVANIA ! ~ ~ ~ ~ 8 OHH' OH.I?A.V.I'!?H~"'HIl~F.!>.! H Hd'd H'''ddHHHHddH !I ~ ~ 'H"HH'HH'HHHH'''HH'H'HH''Hd.Plaintiff'H'd'Hd' ..i N (),..m~H~;YJ.l .~!:m....... 19 97 ~ ~ Versus ~ :HH~J:~:.J.":::Il~~.E:!, ,.~~~~:~.. dd'dH :1 ~ 8 M f, ~ ~ , ~ ~ DECREE IN ~ ~ DIVORCE ~ ~ ~ ~ AND NOW, ......J.~Ll..~.,.........., 19.. .'n.. it is ordered and 8 ;, decreed that.......... J?-;1y~~.~:. ~~~~......................,..., plaintiff, i I :~ ~I~;~='~:~' ;:::~~~~ ~; ~~I;;~~~~:" .. .. . .. .. ... dolondanl, I ~ 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; ~ ~ , . . , . .~~ ,c:~<!~~ .~~~~~~ . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . , , , , . , , , . , . ~ , w " ................ ...... ..................................... . ~ ~ ~ ;. ~ Dy .T~he.~~~. . A.~. J( H. : " Au..l: f' fi -N lf~ . J. ',' . " <?....'u."ce . /, . 'i. r-~j';."'~ ii! ~ ~~#,,?:. r~t::..~.. . ~ ~ tI 7P~olhonolary .' ~ ., . __ .....__._______...._.. __J~ ~._-------~~~~~---~--~------- DAVID RIFE, : IN THE COURT OF COMMON PLEAS OF \ Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 97-2926 Civil Term : KELLY RIFE, : Defendant : IN LAW - 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 Section 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: bv First Class Mail (Verification of Service attached! 3. (1) Date of execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce Code: June 9. 1997 ~ (2) date of service of the Plaintiff's Affidavit upon Defendant: June 11. 1997 . 4. Related claims pending: No economic claims oendina 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached b First lass Mail Verification of Serv ce attached ( Date:3v l7 I 17 ~ -' ..... r- tI: 7- "" -:>.' ,- M llJR ()..:;; '--1t": - ()~~ -. Fb u.. '-~-J 0'- '':;'' ~... 6r N ::-.:/) I "1...' U-\'-" ,'! ~ ""~ .1,0 -L" ,'('ta.. G::i -' -, 'k; I- ,. t'5 r- ::> 0" U . ~ t: u,e (). iF' cF T( 0, till ~ L.:( f', " (.) U,.: '. :.:j '1 , ~ ~ ~ ~ ~ ~ '\ ~~ . t;: CO <'.! '. -. ,...., I ;~ ~ , .... 01 (,] ;:i. .:J () ~ ~~ ~~ ~ '0 ~ ... ~~ '" 0 '" .oJ cYl .... c: cYlt<l .oJ c: ~ Zl:l '... ~ 08 ~ 1; ~~ III .... s:: ~~ ;: ~ ~ 000 EI ~ p I; - ffi~ sa:5 d ~ !:i ~Q I- ..J wl:! .... ~ dj~ z~ l>: > .... I~ ~ w z ~i Q l>: '0 z P ~ ~ ,: It .. iil~ III ~ In ci I-~ Q < P ~ .J ~ ~ it " It < :J: . . . . i . DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I t;), ~9,;2to ~ v. I NO. I KELLY RIFE, I Defendant I IN LAW - 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 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, First Floor, Cumberland County Courthouse, 1 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 Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. q 1-di'dC, C, \JI \ TQf Il'l I KELLY RIFE, I Defendant I IN LAW - 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 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, First Floor, Cumberland County Courthouse, 1 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 Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. Q1-C}W)w CII);/ kl'ln I KELLY RIFE, I Defendant I IN LAW - DIVORCE AMENDBD COMPLAINT UNDBR SBCTION 3301(d) OP THE DIVORCB CODB 1. Plaintiff is David Rife, who currently resides at an undisclosed address in Cumberland County, Pennsylvania. 2. Defendant is Kelly Rife, who currently resides at an undisclosed address in Dauphin County, Pennsylvania. 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. Plaintiff and Defendant were married on June 27, 1986, in Denton, Texas. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The parties to this action separated on November 30, 1994, and have continued to live separated and apart for a period of at least two years. 7. Neither of the parties to this action is a member of the American Armed Services. ...... Cl i'- .'" I ,V- ",,"" ." ." lU' (1' ,., l-t' i";'_ ~ . ..' " 9' (1 (. l..!:) 0' I ";. I", ~ . j -', : u:. ; ~.1- I . 3 l..:_ r- U 0' ,.J DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I NO. q7- .-<'I;.fD ~ r~ v. I I KELLY RIFE, I Defendant I IN LAW - DIVORCE NOTICB If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDBR SBCTION 3301(d\ OF THE DlVORCB CODB 1. The parties to this action separated on November 30, 1994 and have continued to live separate and apart for a period of at least two 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 I 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 are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date:!d!1jq7 dl'J.~. 'aN~ t:; - Ie David Rife. 'I '- C" . (" .. - I:~: .. ~ u..~ ~ ~..: ..... c.:' , If >~ "':i 0 - , :.:1 :'') C .; u ;- _.J_ :(j w..:' , 'L .. : ,. r- ~-:i c' c' 0 DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO'q'7 -.;Adlo C\J",II.erlf) I KELLY RIFE, I Defendant I IN LAW - DIVORCE VERIFICATION OF SERVICB I, Kelly Rife, hereby acknowledge that I received a one count Complaint in Divorce in the above captioned divorce. I further acknowledge that I understand that I am the Defendant in that action and that my husband, David Rife is the Plaintiff. I verify that the statements made in the foregoing document are true and correct to the best of my knowledge. 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. ~~-v~ Kelly Rife Datel ,.... DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 97-2926 Civil Term I KELLY RIFE, I Defendant I IN LAW - DIVORCE VERIFICATION OF SERVICE I, Kelly Rife, hereby acknowledge that I received a certified copy of Plaintiff's Affidavit in the above captioned divorce. I further acknowledge that I understand that I am the Defendant in that action and that my husband, David Rife is the Plaintiff. I verify that the statements made in the foregoing document are true and correct to the best of my knowledge. 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. Dat'lW 11,17 " tfff#/K~ Kelly Rife 1:: ..... r~ .' i:=: C;; :5..... u~,g :),.-:; c'<>3 .- i.):;: "- H:jL u.. f"l:- j ";'. ~n "I ~.,' (I) ,y I --.J~ ~Ll.. _I '~~-f(D -t': (C..;.:-.. =;, ILIa... f';: -. ~. t'. r- 5 0 Ci' U . , DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 97-2926 Civil Term I KELLY RIFE, I Defendant . IN LAW - DIVORCE . VERIFICATION OF SERVICE I, Kelly Rife, hereby acknowledge that I received a Notice of Intention to File Praecipe to Transmit Record in the above captioned divorce. I further acknowledge that I understand that I am the Defendant in that action and that my husband, David Rife, is the Plaintiff. I verify that the statements made in the foregoing document are true and correct to the best of my knowledge. 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. ~~/L- Kelly Rife Date?.R $;;; 97 -- -- Iz; tJ~ (- ,... /. I- e;; -:-"'),~ ,.uQ (...)~~ ,~).:) -c' .~ \..-:"" !tiE <1_ l:"~ ~... .'~": ( It: N ~-~~~ I ~,:, ,....-.. _I to-it!} 0:.,- -, r-= =5 UJo... ::::: lL. r- ::J 0 01 U >- ~ ~ to lUQ C;; ::)~ UJ'~ C);..:) G:~":-~ c: ,'J::.? -- ~g :71 ~..J (.'. c-l :..~u; ~u. I -):~ ...J 1'-7 u:H-' ~:iilj /-: =- ~~) c:.. -. :;~ ::5 r- ;:) C'> U .. . to I . ., . DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 97-2926 Civil Term I KELLY RIFE, I Defendant I IN LAW - DIVORCE WAIVER AFFIDAVIT I, David Rife, hereby acknowledge that I have been served the Complaint in Divorce, that I have been advised of the availability of marital counseling, that I have specific knowledge of the filing of a Praecipe to Transmit Record, and that I understand that a Final Decree in Divorco should be issued in the near future. I hereby waive any othor notice required by statute or practice and agree to the immediato ontry of a Final Decree in Divorce. I verify that tho statements made in the foregoing Affidavit are true and correct to the best of my knowledge. I understand that false statements harein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date t~ II Iqqf) 'Q . I,~./ A- fiv,J ~ / ,~ David Rife I ..... o- cr: \r. f;; >=: -- LlI~ ~ ;"2< '.J--__ 0-. .,.,. C);-;.: [CO l!'r~ c... ":"~ "."'r ~c <'I <~'.f) r":: I ..:J... u...~. ".,'~ -. _11,- _I t";\(b [C-' :2 1'"!..l0- r- '"'" , ,'- lI. r- :::l 0 cr. u , .' , . .. , DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 97-2926 Civil Term I KELLY RIFE, I Defendant I IN LAW - DIVORCE WAIVER AFFIDAVIT I, Kelly Rife, hereby acknowledge that I have been served the Complaint in Divorce and Plaintiff's Affidavit, that I have been advised of the availability of marital counseling, that I have specific knowledge of the filing of a Praecipe to Transmit Record, and that I understand that a Final Decree in Divorce should be issued in the near future. I hereby waive any other notice required by statute or practice and agree to the immediate entry of a Final Decree in Divorce. I verify that the statements made in the foregoing Affidavit are true and correct to the best of my knowledge. 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. Datel' ~~\ l.l I ~~r I4jd Kelly Rife U /' , ..... ;- f.r; Lr. ~' ,'- :z I- t-': ?< ~8 . ) =. u:L. -- ':",":f' .', 0.. t',;~1 ~~' :- C'ol '", ~:: I :Jj.~ ~~., -,._- '-- .'- C;:' ::i ~, H!J i.!= \"nu... -; ~~ lJ_ r- :.-., 0 0' U " . . I I . -. , DAVID RIFE, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 97-2926 Civil Term I KELLY RIFE, I Defendant I IN LAW - DIVORCE COUHTBR-AFPIDAVIT UNDER SECTION 3301(d) OP THE DIVORCE CODE 1. Check either (a) or (b)1 ~) 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 (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)1 ~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 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 verify that the statements made in this counter-affidavit are true and correct to the best of my knowledge. 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 I ~~/--,