HomeMy WebLinkAbout99-06230
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Nu.........??.-.?.z.3o ................. (0
JENNIFER.A. NICKEY.. _._ ..............
Versus 118
?11
RONALD E. NICKEY
AMENDED DECREE IN
DI VORCE I9.
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at 3:55 P.M.
AND NOW, .....Aprii.Y ................. ig zoon . , it is ordered and !
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decreed that ...J.enuifer.A_..Nickey ......................... plaintiff,
and ... Ronald. 9, . Ni.G>Bey .................................... 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;
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.......................one.............................................. .
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Prothonotary
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IN THE COURT OF COMMON PLEAS s
' OF CUMBERLAND COUNTY
r STATE OF 7 PENNA. ;t
JFSIIIIFER L. NICKFY,
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t t. 99-6230 .. ............
...RDm m E. NICKER
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DECREE IN 3??PM
DIVORCE
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AND NOW,. ....... ............. . . , it is ordered and k
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decreed that ...... ?>:?0NTM.Ii.. NTCM.......................... plaintiff,
and ............... RCN E.. M= ......................... , defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
t been raised of record in this action for which a final order has not yet
been entered; Q
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JENNIFER A. NICKEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99.6230
RONALD E. NICKEY CIVIL ACTION - LAW
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 Section X_ 3301(c).
2. Date and manner of service of the Complaint:
Personal Acceptance of service by Defendant on October 12, 1999; certificate of
acceptance filed 10/15/99.
3.
A. Date of execution of the Affidavit of Consent required by Section
3301 (c) of the Divorce Code by Plaintiff. 1/17/2000.
by Defendant: 1/17/00.
4. Related claims pending: None-economic claims have been settled by agreement
NICHOLAS & FOREMAN-
Bruce D. Forem1n, Ey'puire
4409 North Front Street
Harrisburg, PA 17110
(717)236-9391
Attorney ID #21193
Dated: February',, 2000
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JENNIFER NICKEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
RONALD NICKEY,
Defendant 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 make 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, Domestic Relations Section, Dauphin County Courthouse, Harrisburg,
Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BETORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOST THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOU 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 WHI.ItE YOU CAN GET LEGAL HELP.
Cumberland County Isar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
N1CI FOR A
By
Bruc • ). Foreman, Es utrc4409 North Front Street
i lurrisburg. PA 17110
(717) 236-0391
Pa. Supreme Court ID #21193
Attorneys i'or Plaintiff
JENNIFER NICKEY,
Plaintiff
V.
RONALD NICKEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. NO.
: CIVIL ACTION -LAW
: IN DIVORCE
ON TICIA
Le han demandado a Usted en la corte. Si Usted quicre defenderse de estas demandas
expuestas en las paginas siguientes, Usted tiene viente (20) dias de plazo al partir de la fecha de
In demanda y la notificacion. Usted debe prescntar una aparicncia escrita o cn persona o por
abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en
contra de su personal. Sea avisado quc si Usted no se defiende, la corte tomara medidas y puede
entrar una orden contra Usted sin prcvio aviso o notificacion y por cualquier queja o alivio quc es
pcdido en la peticion de demands. Usted puede perder dinero o sus propiedades o otros derechos
importantes pans Usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249.3166
NICHOLAS K FOREMAN
By ?Y
Bruce D. 'oreman, EsduirJ '4
4409 North Front Street
Harrisburg, PA 17110
(717) 236-9391
Pa. Supreme Court ID 421193
Attorneys for Plaintiff
JENNIFER HICKEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 9 9.4 z .?o 61.44 T -
RONALD NICKEY,
Defendant CIVIL. ACTION - LAW
IN DIVORCE
WAIVER OF COUNSELING
1. 1 have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
2. 1 understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised. I do not request that ilic Court require that my spouse and 1
participate in counseling prior to a divorce decree being handed down by the Court.
.II IFB NICKEY
JENNIFER NICKEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. qcq. 6-2 ,?o RONALD NICKEY,
Defendant CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE.
AND NOW, comes the above-named Plaintiff, JENNIFER NICKEY, by his attorney,
James L. Walsh, of Nicholas & Foreman, and seeks to obtain a Decree in Divorce from the
above-named Defendant, RONALD NICKEY, upon the grounds hereinafter set forth:
1. Plaintiff is JENNIFER NICKEY, an adult individual, ou juris, presently residing
at 844 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043.
2. Plaintiff's Social Security Number is 198-52-7688.
3. Defendant is RONALD NICKEY, an adult individual, 5u' iurlS, presently residing
at Rd 1, Moulstown Road, Box 84, Abbottstown, Pennsylvania 17301.
4. Defendant's Social Security Number is 187-58-2959.
5. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the tiling of this Complaint.
6. The Plaintiff and Defendant were married on April 18, 1987, in Gettysburg,
Pennsylvania.
7. Two children have been born of this marriage: Jared Nickey bom May 1, 1988;
and Emily Nickcy bom March 29, 1993.
8. There have been no prior actions of divorce or for annulment between the parties.
9. Plaintiff and Defendant are both citizens of the United States of America.
10. Neither of the parties in this action is presently a member of the armed services of
the United States.
11. The Plaintiff has been advised of the availability of counseling and she
understands that he may request that the Court require the parties to participate in counseling, but
avers that she does not require marriage counseling.
12. The Plaintiff avers that the grounds on which the action is based are:
(a) That the marriage is irretrievably broken;
(b) That Plaintiff and Defendant have be separated in excess of two (2)
years.
13. Plaintiff requests the Court to enter a Decree in Divorce.
Wherefore, Plaintiff prays your Honorable Court to enter an Order dissolving the marriage
between the parties.
Respectfully submitted,
NICHOLAS & FOREM
By -7/; //)
Bruce D. •oreman, tsq i
4409 North Front Street
Harrisburg, PA 17110
(717) 236-9391
Pa. Supreme Court ID #21193
Attorneys for Plaintiff
JENNIFER NICKEY, : IN TIIF. COURT OF COMMON PLEAS
Plaintiff : CUMIII:RLAND COUNTY, PENNSYLVANIA
V.
NO.
RONALD NICKEY,
Defendant CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
1 verify that the statements made in this Complaint are true and correct. 1 understand that
false statements herein are made subject to the penalties of IS Pa. C.S. Section 4904, relating to
unworn falsification to authorities.
JEN :I:R ICKEY
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JENNIFER NICKEY,
Plaintiff
V.
RONALD NICKEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99-6230
: CIVIL ACTION-LAW
: IN DIVORCE
AFFIDAVIT OF SERVICE,
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public, in and for said Commonwealth and
County, Bruce D. Foreman, Esquire who, being duly sworn according to law, deposes and says:
1. That on October 12, 1999, a Complaint in Divorce in the above-captioned matter
was filed on behalf of the Plaintiff, Jennifer Nickey.
2. That on October 12, 1999,1 forwarded a clocked-in copy of the said Complaint by
certified mail, return receipt requested, to the Defendant at RD I, Moulstown Road, Box 84,
Abbottstown, PA 17301.
3. That the aforesaid clocked-in copy of the Complaint was delivered on October 15,
1999, as evidenced by the return receipt card signed oy Defendant, Ronald ey
Bruce D. Foreman, E quit'
SWORN to and subscribed
before me this 19th day
of October, 1999.
?N. 1 ?1
Notary Public
My Commission Expires:
NOTARIAL SEAL
Steve C. NIcWjs, Notary Public
ToWWV Of lkao"hsma, County W Dk#*l
My Commission Expires Sept. 25, 2003
JENNIFER NICKEY,
Plaintiff
V.
RONALD NICKEY,
Defendant
1
s e
1 ¦ Complete hems 1.2. and 3. Also complete
Item 4 If Restricted Delivery Is desired.
to Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailplece.
I or on the front If space permits.
1. Ankle Addressed to:
Ronald'Nickey .
RD 1, Moulstown Road
Box 84
Abbottstown, PA 17301
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6230
CIVIL ACTION-LAW
IN DIVORCE
PROOF OF SERVICE
P 511 122 517
.
US Postal Service
Receipt for Certified Mail
No Insurance Coverage ProvWed.
A. Difoelved by (plsaw Print
X 17 Ad?drressee
D. Gdcwery address dn+aem horn a?rrl 17 0 Yes
If YES. enter dellvery Worm below: 0 No
K Certified Man O Express Mss
0 Registered %Retum Receipt for Merchandise
0 Insured Men 0 C.O.D.
4. Rntrlcted Delrvery7 Xxtra Feel 0 Yin
postage $ .55
CaMW Fn 1
.40 .
Spedel Desrery Fee
ReslMed Dehery Fee
Rehm rlecoo Sta*" to
Wiwi A Date Defwred
1.25
Remm Peceq Sfoerg bah^
Dn. A Msemss Mdrm
TOTAL Postage a Fns i s ,. ,.
2. Article Number (Copy from wvwo 4W CO
P 511 122 517
i PS Form 3811, Juy iogg Domestic RM= Rsceipl msoss?w1ro
NICHOLAS &: FOREMAN, P.C.
fly: -
I3ruce D. I.orcman, :squi
4409 North Front Strcct
Ilarrisburg, PA 17110-1709
(717) 236-9391
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JENNIFER A. HICKEY,
Plaintiff
V.
RONALD E. NICKEY,
Defendant
IN T I IE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6230
CIVIL ACTION - LAW
AFFIDAVIT OF CONSENT AND 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 §3301(c) of the Divorce Code was filed on
October 12, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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 without notice.
4. I understand that I may lose rights concerning alimony, division of property,
attorney's fees or expenses if I do not claim them hef'orc a divorce is granted.
5. 1 understand that I will not be divorced until a Decree in Divorce 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. 1 understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification to authorities.
Date: al aCt? C)o
t"r 'ER A. NICKEY, Plaintiff
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JENNIFER A. NICKEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RONALD E. NICKEY,
Defendant
NO. 99-6230 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
October 12, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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.
4. 1 understand that 1 may lose rights concerning alimony, division of property,
attorney's fees or expenses if I do not claim them before a divorce is granted. '
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.
Duto: r r', r (_ I I AA -,'r-
JE IFEWA. NICKEY, Pla ritiff
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JENNIFER A. NICKEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6230 CIVIL
RONALD E. NICKEY, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
October 12, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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.
4. I understand that I may lose rights concerning alimony, division of property,
attorney's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit arc true and correct. I understand that
false statements herein arc made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification toc?u? thorities.
or,.( 7? c ?' ??
Date: 1/17
RONALD E. NICKEY, Defendant
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JENNIFER MICKEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
:NO. Q1- u l30
RONALD NICKEY,
Defendant : CIVIL ACTION -LAW
: IN DIVORCE
WAIVER OF COUNSELING
1. I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, 1 do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
RONALD NICKEY
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STEVE C. NICHOLAS
BRUCE D. FOREMAN
JEFF FOREMAN
YVONNE M. HUSIC
JAMES L WALSH
uw o?rncn
NICHOLAS & FOREMAN, P.C.
TELEPHONE
4409 NORTH FRONT STREET (717) 238-9391
HARRISBURG, PENNSYLVANIA 17110.1709 ?AX
(717) 238.8802
August 23, 2000
Curt Long, Prothonotary
Cumberland County Court
Of Common Pleas
1 Courthouse Square
Carlisle, PA 17013
In re: Jennifer A. Nickey v. Ronald E. Nickey - Divorce
99-6230
Dear Mr. Long:
1 am writing to you with regard to a clerical error in my office with regard to the
above-captioned matter. A review of the documents in this case indicated that all of the
documents have the above-caption, which is a correct caption. Unfortunately, when we
prepared the final Divorce Decree, we, in error, listed the Plaintiffs name as JENNIFER
"L" NICKEY. The middle initial of "L", should have been an "A".
1 consulted with staff in your office that indicated to me that the Divorce Decree
could be resigned on our supply of corrected decrees. I enclose herewith those decrees,
identical to the original except with a corrected middle initial for the Plaintiff.
If there is anything further that I must do, please feel free to contact me. I
apologize for any confusion or added work caused by our error,
;'ru'y yours,
Bruce D. -or an
BDF/mlr
Enclosure
Cc: Jennifer Nickey
3ENNIFER A. NICKEY,
Plaintiff
V.
RONALD E. NICKEY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 99-6230
CIVIL ACTION - LAW
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
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 the 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: Z/'Z F/ov U'r 4 OJ (?
RONALD E. NICKEY d
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