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