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IN THE COURT OF COMMON PLEAS
.
OF CUMBERLAND COUNTY
.
PENNA.
.
STATE OF
.
PATRICIA A. STRINE
.
No.
00-6979-CTVTT, TERM
.
.
PLAINTIFF
.
VERSUS
.
.
JOHN E. STRINE
.
DEFENDANT
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.
DECREE IN
DIVORCE
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.
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, 2001 , IT IS ORDERED AND
AND NOW,
.
DECREED THAT
PATRICIA A. STRINE
, PLAINTIFF,
.
AND
JOHN E. STRINE
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAtSED OF RECORD tN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
.
.
.
PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
Civil Action - Law
v.
00-6979 - Civil Term
John E. Strine,
Defendant
In Divorce a v.m.
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(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Served upon Defendant by Defendant
personally accepting service of said Complaint on October 16,2001. (See Affidavit of
Acceptance of Service on file.)
3. (a) Date of execution of the Affidavit of Consent and Waiver of Notice ofIntention to
Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff
on January 16,2001; by Defendant on February 16,2001.
4. Related claims pending: none
5. Date Plaintiffs Waiver of Notice under Section 3301(c) was filed with the
Prothonotary: January 30, 2001
Date Defendant's Waiver of Notice under Section 3301(c) was filed with the
Prothonotary: February 20,2001
Date: J.. - J 'i)- 0 I
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IN THE COURT OF COMMON PLEAS OF THE :'9TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
Civil Action - Law
v.
: :a.~00 - b9"l?
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John E. Strine,
Defendant
In Divorce a v.m.
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 properly 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 Franklin County Courthouse, first floor, 157 Lincoln Way East,
Chambersburg, 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.
Pennsylvania Bar Association - Lawyer Referral Service
Telephone 1-800-692-7375 (P A ONLY)
or 717-238-6715
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Franklin County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the Court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the Court. You must attend the scheduled conference or hearing.
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IN THE COURT OF COMMON PLEAS OF THE 19TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
Civil Action - Law
v.
: l'I;R.2000 - (, 979 ~ -r~
John E. Strine,
Defendant
: In Divorce a v.m.
COMPLAINT UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
1.
The Plaintiff is Patricia A. Strine, who currently resides at 14106 Timothy Drive,
Greencastle, Franklin County, Peunsylvania, since on or about July 1,2000.
2.
The Defendant is John E. Strine, who currently resides at 56 Edgelea Drive,
Chambersburg, Franklin County, Peunsylvania, since on or about March, 1998.
3.
Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Peunsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4,
The Plaintiff and Defendant were married on March 11, 1989, at Hagerstown,
Washington County, Maryland.
5.
There have been no prior actions of divorce or aunulment between the parties.
6.
The marriage is irretrievably broken.
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Plaintiff has been advised that marital counseling may be requested and that a list of
marriage counselors is available in the office of the Franklin County Prothonotary. Plaintiff has
further been advised of the right to request that the Court require the parties to participate in
marital counseling.
8.
Plaintiff requests the Court to enter a Decree of 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 ofpeljury contained in 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
Date: //J - to - 0 ()
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J 'ce M. Hawbaker, Esquire
Attorney for Plaintiff
Of Counsel:
KAMINSKI & HAWBAKER
221 Lincoln Way East
Chambersburg, P A 17201
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IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
Civil Action - Law
v.
;'/Y,XJ
6979 - Civil Term
John E. Strine,
Defendant
In Divorce a v.m.
AFFIDAVIT OF ACCEPTANCE OF SERVICE
I, John E. Strine, Defendant in the above-captioned action, do hereby accept service of
the Notice To Defend and Claim Rights and Complaint in Divorce filed in the above-captioned
action.
Date: I D! ( ~ ( Q~IJ
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IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
Civil Action - Law
v.
00-6979 - Civil Term
John E. Strine,
Defendant
: In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October II, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service ofthe Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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. Section 4904 relating to
unsworn falsification to authorities.
Date: January 16, 2001
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IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
: Civil Action - Law
v.
00-6979 - Civil Term
John E. Strine,
Defendant
: In Divorce a v.m.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
I. I consent to the 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! 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 Waiver are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
Date: January 16, 2001
unsworn falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
Civil Action - Law
v.
00-6979 - Civil Term
John E. Strine,
Defendant
: In Divorce a v.m.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
I. I consent to the 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 Waiver are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Date: Flll:>ruary16, 2001
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IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT
OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
: Civil Action - Law
v.
: 00-6979 - Civil Term
John E. Strine,
Defendant
: In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 11, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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. Section 4904 relating to
unsworn falsification to authorities.
Date: Fmruary. 16, 2001
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
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i: PATRICIA A. STRTNR :
." Plaintiff :
:
vs. :
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JOHN E. STRINE
Defendant :
File No. 00-6979 - CIVIL TERM
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter. having been granted aFina~ Decree in Divorce on the
7TH day of MARCH, 2001 . hereby elects to resume the
. and gives
P.S. S 704.
prior surname of
this written notice pursuant to
DATE: ~ /'id/b.
COMMONWEALTH OF PENNSYLVANIA:
: 55.
COUNTY OF CUMI'lERJ'.AUD ~eAJ\lll..Ll AJ:
On the 30M day. of ~ 20.llL.c... before me. a
Notary Public. personally appeared the above affiant known to me to
be the person whose name is subscribed to the within document and
acknow~edged that he/she executed the foregoing for the purpose
therein contained.
In Witness Whereof. I have
and official
seal.
Notarial SaaI
Annette E. DOily, Notary Public
Greencasde BOlO, Franklin County
My Commission expires Nov. 29, 2004
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IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF
PENNSYLVANIA - CUMBERLAND COUNTY BRANCH
Patricia A. Strine,
Plaintiff
: Civil Action - Law
v.
: J
00 - 1s.971
(};u~l~~
John E. Strine,
Defendant
In Divorce a v.m.
STIPULATION OF PARTIES TO VENUE
This Stipulation, made and entered into this --L- day of (?) r k6 U' ,2000, by and
between Patricia A. Stine, Plaintiff in the above-captioned matter, and John E. Strine, Defendant
in the above-captioned action,
WITNESSETH:
WHEREAS, Plaintiff and Defendant are husband and wife and reside in Franklin County,
Pennsylvania; and
WHEREAS, the parties have agreed upon a no-fault divorce, same to be filed pursuant to
Section 3301(c) of Pennsylvania's Divorce Code; and
WHEREAS, the parties wish to submit to the jurisdiction of the Cumberland County,
Pennsylvania, Court of Common Pleas with respect to the processing and final disposition of
said action.
NOW, WHEREFORE, the parties intending to be legally bound hereby, do further
stipulate and agree, pursuant to Pennsylvania Rule of Civil Procedure 1920.2(a)(2)(i) that they
have, freely, knowingly, and voluntarily entered into an agreement this date providing that the
contemplated action in divorce, same to be filed concurrently with this Stipulation, shall be filed,
processed, and disposed of in Cumberland County, Peunsylvania.
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IN WITNESS WHEREOF, the parties intending to be legally bound hereby, have
hereunto set their hands and seals to two counterparts of this Stipulation, each of which shall
constitute an original, the day and year first above written.
WITNESS:
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I verify that the statements made in the foregoing Stipulation to Venue are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
Date: If} - to - 0 ()
.
I verify that the statements made in the foregoing Stipulation to Venue in are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
Date: /0 -fl; - ()O
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