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Home My WebLink About01-03896t NANCY R. SPEAKER, Plaintiff V. HENRY A. SPEAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Ot ` OVF(- CIVIL TERM CIVIL ACTION - LAW 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. 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 Courthouse, Carlisle, PA 17013. 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. i! Cumberland County Bar Association 2 Libert Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 f1\div\speaker.com\G-01 I I , NANCY R. SPEAKER, Plaintiff V. HENRY A. SPEAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Tee H NO. O l - 3 ?96 CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is NANCY R. SPEAKER, an adult individual, who currently resides at 1128 Columbus Avenue, Apt. 12, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The Defendant in this action is HENRY A. SPEAKER, an adult individual, who currently resides at 811 Front Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on April 17, 1983, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -1- 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of di- vorce. COUNT II - ALIMONY AND ALIMONY PENDENTE LITE 10. The plaintiff, Nancy R. Speaker, birthdate: September 6, 1944, currently lives at 1128 Columbus Avenue, Lemoyne, PA 17043. The defendant, Henry A. Speaker, birthdate: December 31, 1930, currently lives at 811 Front Street, New Cumberland, PA 17070. 4. The plaintiff, Nancy R. Speaker, requires reasonable support and alimony to adequately maintain herself in accordance with the standard of living established during the marriage. 5. The plaintiff, Nancy R. Speaker, requests the Court to allow alimony and alimony pendente lite as it deems reasonable pursuant to § 3701 and § 3702 of the Pennsylvania Divorce Act. -2- 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 P.C.S. §4904, relating to unsworn falsification to authorities. Date: &/? / / ??' e '<'-'? NANCY R. S EAKER STONE LaFAVER & SHEKLETSKI By GERALD J. EKLETSKI, Esquire Supreme Court ID #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff -3- f1\div\accept.aty NANCY R. SPEAKER, Plaintiff v. HENRY A. SPEAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3896 CIVIL ACTION CIVIL ACTION - IN DIVORCE ACCEPTANCE OF SERVICE I, Jay R. Brademan, Attorney at Law, accept service on behalf of the defendant, Henry R. Speaker, of a certified copy of the Complaint filed on June 22, 2001, to the above term and number. JAY D or y a Law Supr me C/ urt ID# 126 Locust Street Harrisburg, PA 17101 NANCY R. SPEAKER, Plaintiff V. HENRY A. SPEAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 01-3896 CIVIL ACTION - IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as attorney for Henry A. Speaker, Defendant, in the above captioned matter. Dated: 7 / J X26 V. Box I/ocugt Street P. 7? /' Box 11489 H'_isburg, PA 17108-1489 (717) 232-6600 x? VIC x CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true and correct copy of the attached Praecipe to Withdraw Appearance on the following individual by First Class U.S. Mail addressed as follows: Gerald J. Shekletski Stone, LaFaver & Shekletski 414 Bridge Street New Cumberland, PA 17070 Dated: / bol Esquire 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 e? no v : , <. = r -r In The Court of Common Pleas of Cumberland County, Pennsylvania SPEAKER NANCY R VS SPEAKER HENRY A File No. 2001-03896 STATEMENT OF INTENTION TO PROCEED To the Court: Nancy R. Speaker, Plaintiff, intends to proceed with the above captioned matter. Date: Z61 1/4 110? AOW-- Attorney Plaintiff U 1 :fit ? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NANCY R. SPEAKER ) Docket Number 01-3896 CIVIL Plaintiff ) VS. ) PACSES Case Number 434106632 HENRY A. SPEAKER ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 16TH DAY OF DECEMBER, 2004 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other REQUEST FOR APL CONFERENCE filed on JUNE 25, 2004 in the above captioned matter is dismissed without prejudice due to: AN ORDER OF SPOUSAL SUPPORT DOCKETED AT 387 S 2001 UNDER C#659103451 HAS BEEN ENTERED. Q The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday Service Type M BY THE COURT: C D= I 9 yl Ontl JUDGE Form OE-506 Worker ID 21005 4 t77 _ 0.u ? ,:'.r R r - C D (? t'1 Curtis R. Long Prothonotary Office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ' .3 g Qb CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573