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HomeMy WebLinkAbout00-08091 . . . . . ,-, -.."". d oJ' . :+::f.:F. '" '" :Ii . Of. '" '" Of. '" "'''' Of. Of. '" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . STATE OF . MARY J. FINKEY, . . . VERSUS . . DON ALD L. FINKEY, . . . . . . . . . . AND NOW, DECREED THAT . AND PENNA. Plaintiff No. 00-8091 Defendant IN DIVORCE DECREE IN DIVORCE ~ \,,\ ~, , IT IS ORDERED AND MARY J. FINKEY , PLAINTIFF, DONALD L. FINKEY , 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; . . NONE. . . . . . . . . . . ATTEST: PROTHONOTARY '" '" ff.:F.:f.:f. :f.ff.:f. . . J. . ~iIlll~ff~,_ ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ .\.- 'j, ,'" )~l dd"~~~4~ 3~/o1 ~ ,IU~ ~ 1/1. ,,- _~1_ -, r', ~,~"," ~ , ~ -. ~ " " , ; Vi"~- ";'='~~- Lr.!' '-"":- ,~. ,"""~---,,,_., - ,'~ - - ,e,' < _'" __._,_,_.-,-,11 .~ ~'~ ~~'-~'liOl.1.k.i~WI" MARY J. FINKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-8091 CIVIL TERM VS. DONALD L. FIN KEY, Defendant IN 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. Grounq for divorce: irretrievable breakdown under Section 3301 (c) ;3;301 (d)(1) of the Divorce Code. (Strike out inC\pplicable section). 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant, Donald L. Finkey on November 21,2000, and filed November 28,2000. 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 the Plaintiff on March 1, 2001; by the Defendant on February 28, 2001. (b) (1) Date of execution of the Plaintiff'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 pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: March 12,2001 (b) Date Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: March 7, 2001 Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: March 7, 2001 /""l r Plaintiff " ,~~ :iI:jrlJ l!lirtITj'~~ilj M i1llKil:W~i!(.iL lfl)"d' .1i'1til- J][" '" , ...~-- . (') C () C -q g: ::ll:: '"Oro ~ " mrn = 1=;;; Z.::rJ ",,-,,:-'n zr N -;'10 CD}<; " , ~O -0 .~~?, ?~~5 :.Q ~8 :J!: z() ca om ::i>c --I ~ ?D -< iii:; SAlOIS SHUffi.~WER &UNUSAY AlIUIII'<IIl1l!i'AlolAW 26W. BlghStreet Carlisle, PA .' '-,:' ,,-,-' ,'-. ,',.,-',"",,'-,+ ",,,,~.-,, ,,^ ~- ,<._, ,'--,' --~-,- '-';{?-,; ,--'",-',-/-,.. , -',-'('c; '-";.,,"'-- MARY J. FINKEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. DIVORCE NO. 00 -?tJ9! CIVIL TERM Plaintiff vs. DONALD L. FINKEY, Defendant IN DIVORCE NOTICE 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 at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: squire Date: I///Lff~ t I Ii SAIDIS SIlllffi.~ &UNUSAY ATIDIlNE\'SoAl'.IAW 26W.mghStroet CarlWe,PA 'c_1 -. '_','-.'--'J--- ~-'~- ,,)-,--~- finkey 0" divorce complaint tjb 11/15/00 MARY J. FINKEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 00 - fMI CIVIL TERM IN DIVORCE Plaintiff V5. DONALD L. FINKEY, Defendant COMPLAINT MARY J. FINKEY, Plaintiff, by her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Mary J. Finkey, who currently resides at 3 South High Street, Newville, Cumberland County, Pennsylvania, where she has resided since March, 2000. 2. The Defendant is Donald L. Finkey, who currently resides at 13 South Hanover Street, Apt. 501, Carlisle, Cumberland County, Pennsylvania, where he has resided for at least two years. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 23, 1970. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. SAIDIS SIll.J!"B.!!OWER &LlNuSAY ATRJJlNEYSoAT.IAW :1/i W. IDgh Street CarDsl., PA .,'"' "-C,'" --"," -- -'- '-', :,~:,'~-':-\"i"',,,-c' _ finkey ." divorce complaint ljb 11/13/00 7. 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. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: y, Esquire Date: /l/1/#V i I il II II Ii SAIDIS S~uNn~ ii d I: """"""",,olAW 26 W. mgh Street CarlIsle, PA ,-",,-',--" finKeYe" dIvorce complaint tjb 11/13/00 VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. ?1I0tM P. ~* " J. Finkey Date: TIOIy. 1<-0 [)(jDlJ I' I! I , Ii " SAlOIS SHUFF, FLOWER & LINDSEY A'ITORNEYS-AT-LAW 26 W. High Street Carlisle, P A 'I" , . . .. n -,' . '':'' "- ~ .. c .. >-,c,;~""I, , , . ~ .';;'0."_-,,,~.~~ , l.",-P, 0 . """ ,'= MARY J. FINKEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 00 - 8091 CIVIL TERM Plaintiff vs. DONALD L. FINKEY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on November 15, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. /}11J;~, ~ J. Finkey, laintiff Date: :3 -j-()/ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER s3301(c) OF THE DIVORCE CODE 1. 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 Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. mt1tf ~, iA1)~ arfJ. Finkey, P Intiff Date: ~~ - / -0 J jl II -'v. < ~~ -""~1:'-~-'""'"'-~iilDlJli!,,~ -~ '"~tl;;~_~~"1J1If!ii# ~fi{nliil.i!b~ 'H -;.-'_h~ fJI '~"",',='" " " " ,I H II 'I II II 11 , (') 0 0 c: "'tl~ "T/ :JC '-1 "'" -r- , S?l'Tl ;;u rY1;rJ :0 t;5; I '-prr.l -..J cu,:? ~4 0<" 0 '< .", ::;:J..'f ~o :JC (~ :ri ):>0 ra g~ c: ~ 0 s;! 2i! f: ,~.. , . ~I' ~, I , , -,--...- "',m '---~" .", I i '-<"-J""""'~'M , , .-ii. _ -;,':'l-'.'~_,~ , . 'iJiiiililliliM~G,i: SAlOIS SHUFF, FLOWER & LINDSEY ATIORNEYS-AT-lAW 26 W. High Street Carlisle. P A MARY J. FIN KEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 00 - 8091 CIVIL TERM Plaintiff VS. DONALD L. FINKEY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on November 15, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. I verify that the statements made in this Affidavit are true and correct to the best of my ',I knowledge, information and belief. I understand that false statements herein are made subject Ii; to the penalties of 18 Pa.C.S. 4904 relating to unswo~falsification to authorities. !I v i/~ / ' ii, Donald L. Fi ,Defendant Date: J../:Z1/a / ( ( WAIVER OF NOTICE, OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER s3301(c) OF THE DIVORCE CODE it I!! II! l:: " " ;'1 ., ii: 'i. :, 1. 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 Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. V' Donald L. F" e, efendant D""51 ~?/. / II ~~illlil~ll1lM' w~:O",L;[m:I" '0 "" ";iw~~~"::'1.1.1dU '"""", '."""""- o~~ ".~,".1 ,'-~ 'u ' ~ ",,~,-. """~~ ,., ,-. @ 0 0 -(j :;;::: :x --l ~9J :no f\rt-! ;;;0 l -om Zl:" :of ~;e -J C) "> ~,o ..~ --"- -0 'T"-YI ~8 ::JC: ?S:n -0 ""-en > !.:t ~ ~ 0 ~ -< . SAlOIS SHl.Jffi.~WER &UNIJSAY ATIORNEYSoAT.UW :z6 w. HIgh Stre.t Carlisle, PA < finkey .. divorce complaint tjb 11/20/00 MARY J. FINKEY, Plaintiff vs. DONALD L. FINKEY, Defendant ,'_0 O"'_~_~', ,__"-,,,,_,.,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 00 - WJ?t CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce in the above captioned matter. Date: I/?~~~J Witness: I' Ii Do aid L. Finkey 13 South Hanover St e Apt. 501 Carlisle, PA 17013 0= c:,j.0~'"_ loa.... :.--c..~_ '-.-, , .--, ;;- ...- . ,#",.,-"--,"",,".,,,." <~".,..".".. ""'~"""..M c.' .....y.. ,.....~. "'''''''''" .. . NOV 2 7 _ q , i: !' ffl