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Home My WebLink About98-06317Q t? It L" Q 2 r t- a cs- 8 ap 40 ao- 4W ad a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNSYLVANIA TIMOTHY A. PENNABAKER, NO- ..6317 ............... 1998 Plajntt.ff.. Versus 1 KATHY. E. PENNABAKER, Defendant i DECREE IN A ?7D I V O R C E AND NOW, ... WP49 .../......... 19. ?1? %, it is ordered and decreed thof ....... TIMOTIIY• A•.• • PENNABAKER• • • • • • • . • • • • • • • • , plaintiff, and •••• .............K 11Y E.• PENNABAKER•••••••••••••••••, 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; '' U aAQ ........................................................................... By The c ee ete ao X 40 %* ae ata ae atax+atoc?aecxirt?aet?at+c ato:wamc a -------------- s r 3 i i r J ........................ Attest: / /? ?. v .L Prothonotary )09? '8W 111p, . iAll GA. IN, er• 4* .. ?, ?> j?lv' i'?. .? ?,.:? ?? J .?? TIMOTHY A. PENNABAKER Plaintiff V. KATHY E. PENNABAKER Defendant AN TI IE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY. PENNSYLVANIA :CIVIL ACTION - LAW :NO. 98-6317 CIVIL TERM :IN DIVORCE PRAF.CIPF. TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: November 8, 1998, by hand delivery at Defendant's place of employment at The Holly Inn. Mt. Holly, Pennsylvania at approximately 5:30 PM by Paul Bradford Orr, Esquire, attorney for Plaintiff. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff, February 16, 1999; by Defendant February 16, 1999. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 25, 1999. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February25, 1999 LA •FI 1R?tFF P lD ORR 1 I Date:1 1999 By: Paul Bradford rr 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID No. 71786 TIMOTHY A. PENNABAKER :IN TI Ili COURT OF COMMON PLEAS Plaintiff :OI' CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL AC *ION - LAW KATHY E. PENNABAKER :NO.98-W/7 CIVIL TERM Detcndant :IN DIVORCE NOTICE You have been sued in court. Ifyou 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 in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 TIMOTHY A. PENNABAKER Plaintiff V. KATHY V.PENNABAKER Defendant :IN THE COURT OP COMMON PLEAS :OP CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NO. 98- i Y/ 7 CIVIL TERM AN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301((1) OFTIIE DIVORCE CODE 2. 3. 4. 5. 6. 7 Plaintiff is Timothy A. Pennabaker, who currently resides at P.O. Box 222, Mount Holly Springs, Cumberland County, Pennsylvania, since October, 1988. Defendant is Kathy E. Pennabaker, who currently resides at 330 Motter Lane, Boiling Springs, Cumberland County, Pennsylvania, since May, 1998. Plaintiff and Defendant have both been bona tide residents in the Commonwealth for at least six months immediately previous to tiling of this Complaint. Plaintiff and Defendant were married on May 22, 1998 in Gettysburg, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under § 3301(c) and/or § 3301(d) of the Pennsylvania Divorce Code. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. 8. I'laintiff requests the Court to enter a Date: ( ?- I' yov Attorney I'm Plaintiff Supreme Court ID # 71786 50 East High Street Carlisle, PA 17013 (717) 258-8558 VERIFICATION I verify that the statements made in the Ibregoing Petition arc 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. DA,rE:, e& 22 4, _Pk lg2GYAe Timothy A. Penn aker, Plaintiff i r_ ? r, r, . ? ? _ . '? i ? i ii. ? ? -.. ?i ?...? L: U TIMOTHY A. PENNABAKER :IN'1'l IE COURTOF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW KATHY E. PENNABAKER :NO.98-(03tCIVII.T'FRM Defendant :IN DIVORCE AFFIDAVIT OF SERVICE. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this U f )t Jay of f(C frPix . f.rii , 1998, I Paul Bradford Orr, Esquire, attorney for Timothy A. Pennabaker, plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint for Divorce and Order of Court, executed by the Plaintiff in the above-captioned matter, upon the Defendant, at her place of employment at The Holly Inn. Mt. Holly, Pennsylvania by Hand Delivery on November 8, 1998, at approximately 5:30 PM. LAW OFFICES OF PAUL BP P By: Paul Bradford rr, Bs . Attorney for Plaintiff 50 E Ric- x ST ORR CARLISLE )DA 001,3 SCt?D #91996 0n) ZS 8-SSS?? 'TIMOTHY A. PENNABAKER :IN TI IE COURT OF COMMON PLEAS Plaintiff :OF CUM11FRI.AND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW KATHY E. PENNABAKER :NO. 98-6317 C'IVIL'TERM Defendant :IN DIVORCE AFFInAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of :he Divorce Code axis filed on November 6, 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 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. §4904, relating to unsworn falsification to authorities. Date:& Timothy A. nabaker, Plaintiff TIMOTI IY A. PENNABAKER Plaintiff v. KATHY E. 1'ENNABAKER Defendant :IN 'I'I IF COURT OF COMMON PLEAS :OI' CUMBEIRI.AND C'OUNT'Y. PENNSYLVANIA :CIVIL AC'T'ION - LAW :NO. 98-6317 AN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE. UNDER § 3301(c) OF THE DIVORCE CODE: I. I consent to the entry ofa final decree ol'divorce without notice. 2. 1 understand that I may lose rights concerting alimony, division of property, lawyer's fees or expenses irl do not claim tbent before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy orthe decree will be sent to nie immediately after it is filed with the Prothonotary. 1 verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties o f t 8 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: b Timothy A. Penny . cr, Plaintiff T1M0'fl IY A. IIENNA13AKER :IN'1'I IE CO1JR'I' OP COMMON PLEAS Plaintiff :OI: CJJMI31 RI.AND COUN'T'Y. PENNSYLVANIA V. :CIVIL ACTION - LAW KATHY E. PENNABAKER :NO. 98-6317 CIVIL TERM Defendant :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 6, 1998. 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 of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 1 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 unswom falsification to authorities. Date: -:9- // Kathy E. nnabaker, Defendant 'I'IMOTI IY A. PENNABAKER Plaintill' V. KATHY E.PENNABAKER Defendant :IN 'I'I Ili C'OUIt'I' OF COMMON PLEAS :OF C UMBI:RLAND COI1N'I'Y, PI:NNSYLVANIA :CIVIL. ACTION - LAW :NO. 98-6317 :IN DIVORCE WAIVER OF NOTICE. OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. Date: "A: Kathy E. ennabaker, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GlY1 rl et (? r . Plaintiff Vs File No. ?0C IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or _ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of s e? z , and gives this written notice avowing his / her intention pursuant to he provision of 54 P.S. 704. Date: //- - G c? Signatuff Ile, Sign ure of name being resumed COMMONWEALTH OF PENNSYLVANIA ) _LAabffjW COUNTY OF / On the /,0 tj day of X1??C , 2001, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Prothonotary or Notary Public NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4.2010 't :? -, .? ? `-"'? a Y_- F.._ °? C: `„ ?.°:? , ? r --...?. ;;' -? rn ?.,, '-° V _ ? ?` ^ -?.c`5. - ?. ? ? t "„',. '1 aC? fi