The URL can be used to link to this page

Home My WebLink About03-1571Angel Stuckey, Plaintiff Bart William Stuckey, Sr., Defendant IN THE COURT OF COMMON PLEAS Cumberland County, Pennsylvania CIVIL ACTION--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 in the Office of the Prothonotary, Cameron County Courthouse, Emporium, PA. 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 N. FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 Angel Stuckey, Plaintiff Bart William Stuckey, Sr., Defendant IN THE COURT OF COMMON PLEAS (Cumberland County, Pennsylvania Civil Action - Law IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Angel Stuckey, who currently resides at 505 Boston Court, Mechanicsburg, PA 17055 2. Defendant is Bart William Stuckey, Sr., who currently resides at 141 S. Enola Drive, Enola, PA 17025. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. or more. The Plaintiff and Defendant were married on February 14, 1998,. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken and the parties have been separated for two years 7. Plaintiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. Respectfully submitted, Shawn A. Bozarth, Esquire Attorney for Plaintiff _VERIFICATION I, Angel Stuckey, verify that the statments in the foregoing complaint are true, accurate, and correct to the best of my knowledge information and belief subject to the penalties of unsworn falsification contained at 18 P. S. §4904. Angel Stuckey, Plaintiff Bart William Stuckey, Sr., Defendant lN THE COURT OF COMMON PLEAS OF Cumberland County, Pennsylvania Civil Action -- Divorce NOTICE Ifyou 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 UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 19, 1998 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 fights concerning alimony, division of property, lawyer's fees or expenses ill do not claim them before a divorce is granted. I verify that the statements made in this afl~davit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.$. Sec. 4904xelating to unsworn falsification to authorities. Plaintiff Angel Stuckey, Plaintiff Vo Bart William Stuckey, Sr., Defendant IN THE COURT OF COMMON PLEAS OF Cmnberland County, Pennsylvania NO. Civil Action -- Divorce COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) 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) 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): (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 ifI 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: Bart William Stuckey, Sr. NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit with the Court. Angel Stuckey, Plaintiff VS. Bart William Stuckey, Sr. Defendant IN THE COURT OF COMMON PLEAS Dauphin County, Pennsylvania No. 03-1571 Civil Term CML ACTION--LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Shawn A. Bozarth, hereby certify that I served a copy of the Complaint, Plaintiff's Affidavit and Defendant's Counter-affidavit in the above captioned matter upon Barbara Morgan, the mother of the Defendant, at Defendant's residence at 141 S. Enola Drive, Enola, PA 17025 at 7:15 a.m. on April 7, 2003. DATE: Angel Stuckey, Plaintiff Vo Bart William Stuckey, Sr., Defendant IN THE COURT OF COMMON PLEAS Cumberland County, Pennsylvania No. 03-1571 Civil Action - Law IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Bart William Stuckey, Sr., You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the plaintiffs affidavit. Therefore, on or a after May 12, 2003, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counteraffidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 N. FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 served April 28, 2003 Angel Stuckey, Plaintiff VS. Bart William Stuckey, Sr., Defendant IN THE COURT OF COMMON PLEAS Cumberland County, Pennsylvania 03-1571 CIVIL ACTION--LAW IN DIVORCE PRAEClP~. TO TRAN.~T RgCOl~n 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 ~ of the Divorce Code. 2. Date and manner of service of complaint:~. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff .; by Defendant (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: ~_; (2) date of service of the Plaintiff's affidavit upon the Defendant: A~_~p_~E~ '7 2_~003. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached ~ S . zarth, Esquire Attorney for ( x ) Plaintiff Attorney for ( ) Defendant Angel Stuckey 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. VERSUS Bart William Stuckey, Sr. NO. 03-1571 DECREE 1N DIVORCE AND NOW, ~ ~J~C Z? '~0~ IT IS ORDERED AND DECREED THAT Angel Stuckey _, PLAINTIFF, AND Sr. Bart William Stuckey, , 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; BY The COURT: /~) '-~ PROTHONOTARY