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Home My WebLink About97-06603 I I I ! \ ~ ., ~ , ~ , , ! i i I ~ I ~ I ~ \) ~ \i "~"'" " r;#;';;~ / ." I,' & ~ , .~ ,~ ') ~I ~I . I ~! I i .3'.;(5 ~y tJ,,-/ ctp$ ...,,~4 ~ ~2-tj XJ~ .3',;& ~r L/r""I ' a J- Ah# 7~ ~Ha. ~ 4fI ~T' . " . " " .... ! I j , i , , , I j I , j I IN lllE cnJRT OF CCM100 PLEAS OF CtHBERLIIND ro.m:t'i'. PENNSYLVANIA WILLIAM R. SELOSXY, 00. 6603 CML 1997 Plaintiff ACTION IN DIVORCE VB. TRACJ McLAIN, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotaryl Transmit the record. together. with the following inforT'Nition; to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~) of the Divorce Code. ' (Strike out inapplicable section) 2. Date and manner of service of the canplaint: by certified mail December 3, 1997 3. Canplete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff March 5. 1998 by the defendant March 5, 1998 B. (1) Date of execution of the pleintiff's affidavit required by SectiOn 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pendingl 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section Both Plantiff and Defendant signed 3301 (d)(l)(i) of the Divorce Code Waivera of Notice of Intention to File Praecipe to Transmit Record. ~;J;L C I Attorney for Plaintiff . . . (', ,-' ~" ~ :!": , 1 .'n --.~. I' ,. J , II".'; 1("'"; I, ';' -" ,.;',i .;'; " -::> (",I Q99999-OOO2OINovcmbcr 21. 1997IMCDI,PARJ65484 WILLIAM R. SELOSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ql-la~03 C~T~lfl'l 1># TRACY McLAIN, Defendant IN DIVORCE ., TO DEFENDANT: TRACY McLAIN 1011 Oak HIli Road Lewlsbeny, PA 17339 You have been sued in court. If you wish to defend against the claims set forth In the following pages, you must lake action within twenty (20) days after this coMplaint and notice are served, by entering a written appearance personally or by attorney and filing In writing with the court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed In the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights Important to you. ~ L YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TI:!LEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240.6200 f 099999~)()()201Nnvembc:r 21. 1997/MCDiPARlIOJS79 WIL.L.IAM R. SEL.OSKY, Plaintiff IN THE COURT OF COMMON PL.EAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Ch-LPlJJD3 TRACY McLAIN, Defendant IN DIVORCE AND NOW, comes the Plaintiff. William R. Selosky, by and through his attorneys. Johnson, Duffle, Stewart & Weidner. and files the following Complaint: 1. Plaintiff is William R. Selosky who currently resides at 21 Drexel Place. New Cumberland, Cumberland County, Pennsylvania, since August 25, 1997 2. Defendant Is Tracy Mclain who currently resides at 1011 Oak Hill Road, L.ewlsberry, York County, Pennsylvania, since 1974. 3. Plaintiff and Defendant have been bona fide residents In the Commonwealth for at least six (6) months Immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 14. 1997,In Towson, Maryland. 5. There have been no prior actions of divoroo or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the Court require the parties to participate in counseling. 099999-lXXllOlNu,omh<, 21. 1997/MCDlPARlIOJS79 8. Plaintiff requests the Court to enter a Decree of Divorce. 9. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff Intends to file an Affidavit consenting to a divorce. Plaintiff believes that the Defendant may also file such an Affidavit. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. Respectfully submitted. JOHNSON, DUFFIE, STEWART & WEIDNER ,~// By: /'/' C. u Ie, Esquire /, ttomey 1.0. No. 75906 L 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attomeys for Plaintiff .' c; .0 n , ....l ." . , , ", : ; ',-:':1 f tts .r, ;-'.l u C\ ~ ~ CJ I ..., " #- It.. " '1 , I n 01 ~ g '" , , , I ~ ~~ ',J ~; ! ...,j .... - - QQ -a- (f\ } 01098J.OOOO1IFrtday. Fobruary 27. 19981MCDlPAR/107246 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6803 WILLIAM R. SELOSKY. Plaintiff TRACY McLAIN, De~ndant IN DIVORCE I hereby certify that on the December 3, 1997, I served a true and correct copy of the Complaint In :livorce upon the Defendant, TRACY McLAIN, by certified mall, restricted delivery, to her at 1011 Oak Hili Road, Lewlsberry, PA 17339, retum receipt requested, attached hereto and made a part hereof. JOHNSON, DUFFIE, STEWART By: Mark C. Duffle Attomey 1.0. No. 759 6 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 7614540 Attomeys for Plaintiff ~ !; ,y '. ., l"" ,.1 ...... l , , ; - \ -~] I , , c , ; , . ,> ;1 -.. : " ::-) , .,-. . I ! i i ! I ! , I I WILLIAM R. SELOSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-6603 TRACY McLAIN, Defendant IN DIVORCE AFFIOA vir OF CONSENT. 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filet! on jJ.~,;2(.. . 19~. 2. The marriage of Plaintiff and Defendant Is Irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of Intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and. being so advised, I do not request that the Court require that my spouse and I participate In counseling prior to the divorce becoming final. 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. ~904 relating to unswom falsification to authOritles~ _ / J / J ~./r)U Date: J Y qg tL::!.~( f .., William R. Selosky, Plaintiff c:. c'-' .~') ~... " , I , . " 1 J I '.J , , ",I ; .;..; - , ,.. 'A , :') .. .o.::--J J r .) ". n ,n n ~-: w , I -,. - I rii , " ., ) " ~ "., . ~-~ ;1'"1'\ I'':. !'__J I " , , IC) I "01 ...;j ,. , ) ;} 1";1 " I :.1 ':':'> :d -c I., -< . '~a;. '--::, ~.