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Home My WebLink About01-03597 . . . -...I., . . . ".',....c,'_.."'" , I.,:", , " ~ ~ ~~i",' ;-, ~'d.'" ',"" ,""'," .', c ,,)., ", ""," f. . . .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF M..1i...." S. Finkt'ly, . . PENNA. l"lail1ltit! No. 3597 Civil Term VERSUS Josltph J.. Finkey, Defendant DECREE IN DIVORCE AND NOW,-1) ~ tL( , ~f, IT IS ORDERED AND . . . DECRE:ED THAT Melissa S. Finkey . AND , Pl.AINTIFF, Joseph A. 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 BE:EN ENTERED; . . . Jl 03 .>3 I ~!l l! ;: ;~ 1:1 :;;1 'I ,,[ :"",=- -" ''1~ J,~ ~,~ 0- 1/./(.tJ/ 1f.!!1 01 tU. ~ M~ ~ 4d:1~ 71~ ~;? djI" -- , .~~~$1"\f,'...,~__,~~~ ..4! 1-~~~~t~~.~f!Nli~\M~"_,, " _ _ l.~~ ",..~....". " '- '" I~, ," .,.1.' ,', 'M'O:~~~,V .. MELISSA S. FINKEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 3597 Civil Term JOSEPH A. FINKEY, Defendant : ACTION 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. Ground for divorce: irretrievable breakdown under 93301 (c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receipt requested. delivered on: June 22, 2001. 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff: By Defendant: October 23, 2001 October 23, 2001 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: November 7, 2001. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: November 7, 2001. Date: ~ l- l ~ (5) ne Adams, Esquire I. No. 79465 ' 11 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff W~':'"~'';';''';'''''''iIi~~M<>ij;l'~l~!fi\njj!t:ljf.i2!.;W~~'''lt~M;;!'!'1l1'''-'0,\jJ<"''';'i";o';~li""'N"C.'f:-'<i,Qj,,,,,~'"~ii!ix~~."~"":~""''''''"''"'U~~~,i:lllilf~1Iii ~r""c,.,,,~q_,^ .,"~ .~ _I,,~,"-"=." ~~_" , .,~. ._, . ~ ~ -~ . .,,~ ~~i!l~ T -~~, . '<I :;1 IJI Iii 'I I I :1 II' I: !;I ,:: ,'I JI 1:1 1'1 I i] I 'I I " II (~ ~ , II I: I' I ') I, i: I II I i 0 0 C:' (~t C ,- -',', ~ "1:7;:';;-' ~ fT1;":; CJ 2:~i' ,,- <: 2"1" 0:\', .-J .-..J i;~ '-n ---- >c CN 2: ,::..Jr '" =< ~<' ~ en :'i] -< [.5 eo L..' " _L' , ,', .,~, 'IiJiilRi"''''' .i. ~~~i' t '~',~, . . MELISSA S. FINKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01- 3~'t7 Civil Term JOSEPH A. FINKEY, Defendant : ACTION IN 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 I,",,~ "'" 'oJ ,-" . Vc ,- .' >'-<(j:!!<.[il';:'! . " MELISSA S, FINKEY, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. DJ- 35'11 Civil Term JOSEPH A. FINKEY, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Melissa S. Finkey, a competent adult individual, who has resided at 604 Copper Circle, Carlisle, Cumberland County, Pennsylvania, since February 2000. 2. Defendant is Joseph A. Finkey, a competent adult individual, who has resided at 13 S. Hanover St., Carlisle, Cumberland County, Pennsylvania, since 1999. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4, The Plaintiff and the Defendant were married on July 3, 1996 in Mount Holly Springs, Cumberland County, Pennsylvania. 5, There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling; however, Plaintiff waives her right to pursue counseling. 7. Plaintiff and Defendant have two children together, namely, Cheyenne Nichole Finkey, dob, 10-3-96, and Seneca Rose Finkey, dob, 8-22-98. 8. Plaintiff and Defendant are both citizens of the United States of America. 9, Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. ". . .-- .;-- ^"' . ,'~ ;I~,~ ~~"=' ;;", . -~,',-"" -$., J.."_ 'J, c'.' 0'" ,,'~ 't', . , . 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the irmocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in 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 of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. 4jA~ J. ~)eI Melissa S. Finkey, Plaintiff Respectfully submitted, Date: C, , lr.O J ~ J e Adams, Esquire .D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF iilIi~!!diil!!lM~!,;3!'!'a"'#d!<,~-,\;oi;i~~~lit_:tIl!"tfliM~l~o5.;~Mii~~~'~,.1f'~- - . ~ ~= ~ ' ' """""'....~. ~ ~~ 'O~ . , 0 CJ Cj C -n s: <- vet) c --:j t:pn; z ;-";'lS} ~:r. r :z:~- "c~ITl ~~.~: ~~~ !;=C'"::' u ~o :-:-w: '~;~}t~ -0 5>c W of'n :z: N ~ =<! 1'-' -< [S ~ [0 ~ ] , .. - - cl' " v., (r, d . - ~~ t ~~ r ..... -t. ..... " I..- "l "- ~ ",,>", ^ ,~,,,,,,,., ~= _*~,~= ~ , u.~ _ ^~, ~, _..~," ~> ~,~. '''" . ,,'",~.~ ~~>,~ ~ <" ~, . .~ -,",_.. ~ -, r - , ~. .I~, ,-.'i, ^1i~; MELISSA S. FINKEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V5. No. 01 - 3597 Civil Term JOSEPH A. FINKEY, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on June 11, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: I () - ~ 3- 01 ~.i^;'/I J,. ~'.("7 Melissa S. Finkey,l'laintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301 leI OF THE DIVORCE CODE 1. I consent to 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. 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: 10' 93- 0 I liilhiln''''-'' '~""l1l~J_'i!l,n,;i;ih1b\\HIj;"*'i\i~il1ilirfMm\Wijiwii~,M_~,'w,;w,,:m',,,"-4~'"-'\~';;''''~tli.r"--'J!!'''~.!il'li'i:#.,~.@:,,jl4liii.-4lIIIk:llWiI!l;aIiiililW:,-t~I\;i;'.!ili~'''''';'' '" 1 ~['I_~. . ~ _1;Mj ,'0 '0' ~-'-"-~'- 0 0 0 c: S: - C ""'0 CD ::::) 0 S2~: " ~~ <:: Zr- I --J ~~",g, .-.) r:'- :':::::'-J "'0 ">':"",-- - ;?;~; )>'--. r- W Z "0:: J\ ~, :~) -<' (')'~ ::0 "" -: "5 [5 to ~,~-,~ ,~~"~ ",~"~._~ .. "" ~ ,I _. c ,,~!IIl~~ ~ ,- "~. , 1,,- , ' .,~l ~ "\~",~ ;;" .;:,. "';'H ,. MELISSA S. FINKEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 3597 Civil Term JOSEPH A. FINKEY, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on June 11, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: I 0 ~~o \ WAIVER OF NOTICE OF INTENTION TO REQUI;ST ENTRY OF A DIVORCE DECREE UNDER 633011c\ OF THE DIVORCE CODE 1. I consent to 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. I understand that false statements herein are made subject to the penalties of 18Pa.C.S. ~904 relating to unsworn falsification to authorities. Date: I<{)-J~~D\ ~" ~ " '"'--~:,.c.""'_""-, '" ,,~,,~, ~','in'~'; . , MELISSA S. FINKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01 - 3597 Civil Term JOSEPH A. FINKEY, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICEOF NOTICE TO DEFEND AND COMPLAINT. AND NOW, this June 25, 2001, I, Jane Adams, Esquire, hereby certify that on June 22, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Joseph A. Finkey 13 S. Hanover St. Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: Jan Adams, Esquire LD. o. 79465 11 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~~~~!le~~iail'.&J;;jiW~~~~~-tK,&~:~~~.i"" ~ ;,~~~,,"'--<-N"" " -~,~,;" 1><"" ~" ,. .~ - " Q 0 C:J s:;; ~ :s:.., '- Y3f? C' ~ -"'- zf- T'0 , N ~(! <.J', , " V' (; :5>(;, -r' -" ("~ -'"1 Z,-j ~,'" J ('') -,--0' " Pc (~~ '" -F- Z ''':' ~> --i :JJ .." -< ,,- ,< ? ['5 [0 ~ 1'~ . Complete ii;;m~1; 2. a~d3.Ai~ooompie1:e itfVI 4 if Restricted Delivery is desired. . Print your n~me and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. ArlICieAdd~to: ~5~~ A,f,'('\::a \~ S. t+o.-.o..,.e..-sh ~\\s.\e_ f'\Or \10\~ - ''''; -~ ,",' '"'(,1,,;. ',', ,~ "~ ,~ '.;; .,~ "or.-' D Agent o Addressee DYes D No 31IVice Type CEjrtlfled Mail Registered o Insured Mail 4, Restricted Delive o Express Mail o Return Receipt for Merchandise DC.a.D. (Extra Fee) 2, Article Number (Copy from service label) p~ Fol~ 3!i1; ,; j~I~1100bi · . .! 7~iUl1:?~e;n /() q 110 ~ 7~5~'!O'M'0952 r