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Home My WebLink About99-03672 ,? a; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ??? PENNA. ERIN M. PERKEY 1141 Plaintiff No. 99 - 3672 VERSUS JASON M. PERKEY Defendant DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT ERIN M. PERKEY AND JASON M. PERKEY ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, , DEFENDANT, 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; NO CLAIMS PENDING A2 -,247 ERIN M. PERKEY, v Plaintiff JASON M. PERKEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.99- 3672 CIVIL CIVIL ACTION - LAW 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 (X)3301(c) ( )3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: June 21, 1999, First Class Certified Mail, Return Receipt Requested, Restricted Delivery. 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 Plaintiff: October 27, 2000; Defendant: April 13, 2000. (b) (1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code:_; (2) Date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None. J .. ,i r? /? /// ?. Srff . .... .:?pr+ .....- ?. a?r_ .f oii+?fi $' iii i.:; i /? ! sirr .. Y=? r? _ i'_ "' I-' ,i __i i_ ?'-' ?'i,-i3 .. ? ?_ _. ERIN M. PERKEY, Plaintiff v JASON M. PERKEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION - LAW NO. 99-36"eiVIL : 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 ERIN M. PERKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL DIVISION - LAW 91 JASON M. PERKEY, : NO. 99- CIVIL Defendant IN DIVORCE COMPLAINT Plaintiff, Erin M. Perkey, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: Plaintiff, Erin M. Perkey, is an adult individual residing at 213 Hedgerow Drive, Chambersburg, Franklin County, Pennsylvania. 2 Defendant, Jason M. Perkey, is an adult individual residing at 328 Pine Grove Road, Gardners, Cumberland County, Pennsylvania. 3 The parties were married on March 21, 1998, in Carlisle, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 6 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7 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. 8 Plaintiff requests the court to enter a decree in divorce. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROUJOS & GILROY, P.C. By a Hubert X. Gilr , Esquire Attorney for aindff 4 North H over Street Carlisle, P 17013 717-243.4574 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. &I-"qvg Erin M. Perkey L Ir. ??..._ i ?. ?L' ?T' ?,' - .. -' ?? ; . v n:' e? ?., ', ?? ,? •.;? ? U ?6 T O w ERIN M. PERKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 99- 3672 CIVIL JASON M. PERKEY, : CIVIL ACTION -LAW Defendant AFFIDAVIT OF SERVICE 1, Hubert X. Gilroy, being duly swom according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant, Jason M. Perkey, by certified mail on June 21, 1999. A copy of the Certified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. //( ?e 64 ??/lam' ?? DATE Hubert X. y, Esquire Attorney or Plaintiff Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before me this _ AA day of lb _) , 2000 (2rte 6_A Notary Publi Notarial all Bridgot Ann Corcoran, Notaryy Public C: ?; lido E3oro, Cumbarland Ccunly Gi,uanise_un Explrnn Juno L). is SENDER: t 'h 4 e Completo items t andn' 210r a ld,OOnal sent.. . Cumplole hems a. 4a. and 4b P I also wish to receive the following services ((Or an Y • eat yom name and addJU Ss on meanness of this term so th care f0 yyaaV at wa can mare INS extra too): • AeaohIhis form to Ihu front of the mailpiaco. or on the back d space does not 1. ? Addressee's Address ; nao n?srr e rete 'Return amot Will the llplece below Inenumber. 2. p4 RBSIriC10d Delivery • The Return Raolpt wsll show show 10 whom the ar erlKle w d l Zu 0 es ivered er orad and the data e eallvered. Consul) postmaster for fee N fi 3. Article Addressed to . 4a. Article Number }! I Sason M.?ek key 4S y /af 7 32Y I fne Crrrove Rood b. service r ype E = u Ls`fMckL,ruA.a r?A )73ay egislered eddied ? Express Mail ? M0 , Insured c slum Receipt for Merchandise ? COD 7. Date of De ery / E 6. Receivetl By: (Print Nam e) 12 1 y ?/ B. Address e's Address (Only if requested o '• .C and lee is paid) ? 6. igna ure: Addressee orm enf) F • 0 x PS Form 11, December 1994 102595 se a 0229 Domestic Return Receipt EXHIBIT l.. " U ERIN M. PERKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JASON M. PERKY, 99-3672 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT ilt&SOMMOdgM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on June 17, 1999. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about June 21, 1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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 unswom falsification to authorities. Date: ?o2g Z I -L Ln. M. Perky I Plaintiff o• r M Y5 p U ERIN M. PERKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JASON M. PERKY, Defendant AFFIDAVIT OF CONSENT AND DEFENANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 99- 3672 CIVIL TERM IN DIVORCE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on June 17, 1999. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about June 21, 1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 1 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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 unswom falsification to authorities. Date: t OCO J on M. Perky / Defend It ERIN M. PERKEY, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL. DIVISION - LAW : NO. 99-3672 JASON M. PERKEY, AN DIVORCE Defendant. PRAECIPE TO ENTER AN APPEARANCE TO CURTIS R. LONG, PROTHONATARY.• Please enter my appearance on behalf of the Defendant, Jason M. Perkey, in this matter. Respectfully submitted, IRWIN, McKNIGHT & HUGHES August 4, 1999 By: Marcus A. McKnight, If 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Atty. ID# 25476 Attorney for the Defendant, Jason M. Perkey ERIN M. PERKEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - LAW : NO. 99-3672 JASON M. PERKEY, :IN DIVORCE Defendant. CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that on this date a true and correct copy of Defendant's Praecipe To Enter Appearance was served by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, upon the following: Hubert X. Gilroy, Esquire BROUJOS & GILROY 4 North Hanover Street Carlisle, Pennsylvania 17013 IRWIN, McKNIGHT & HUGHES 1. By: Marc s A. McKnight, wire 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Date: August 4, 1999 O? D V ?? n { 11 ? 1D V?^ W LLO W?) m N ; ? p Z N I? . yy 04 !! w j LL. a 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA CIVIL ACTION - LAW ERIN M PERKEY Plaintiff File No. g4 _ 3672 Vs. IN DIVORCE JASON M PERKEY _ Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 18th day of DnCEdBER , 30902000 , hereby elects to resume the prior surname of ERIN M STATLER and gives this written notice pursuant to the provisions of 54 Pr.S. S 704. DATE: 'W 'fi) 6 Ium - -- - Signature r?nature of name being resumed COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND On the _26th--____ day of JpNUpgY_-__ , RR 200.1• before me, a Notary Public, personally appeared Lie above affianl. known to me to be the person whose name is subscribed to the wi.Lhin document and acknowledged that tie/she executed the foregoing for the purpose therein contained. In Wi.lness Whereof, I have hereunto set. my hand and offici.al. seal. No ary Public Notadel seal gmbegy A Wrilckard, mb eiY Public Mie myC om mmUea bn 90 roe Sept 19; 2C ppdN Member, penneylvenle Aee0c100on 0114012663 '-1 W J ? \ Q ll. ' Chi .1,/ l L - V . - } ? ? •/ O U