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Home My WebLink About99-06543 t? .W.- :. •a:• • VV 4•* ,*: "0 •:0 :?: •:r.•. }...:?c•: x?x r a:::?.: ?? ' :r,•' :w .too-.':W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ?W PENNA. MICHAEL P. HAKES, Plaintiff \ u.. 99„6543 ...... ................. 19 Versus DEBRA L. HAKES, Defendant ti? ?i DECREE IN DIVORCE AND NOW, ...........M. c.u? ...9 ... , ....... it is ordered and decreed that .. . . . . . . . MICII.. AEL P.. HAKES .... • . • • • • plaintiff, ...... and ..................DEBRA L. HAKES......................... • 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 kneon cantered: r.. M iC ?p P. v A,Wr- .............................. ................ . .. ................................................. ••.' fly Th Court J. t Attest ?? Ia Prolhonolnry j1 i 'r •Xi ?Xr fI:• •A:• •71:• 4Y,. •'JY.•?•M:• :?:• •:Y.• W. W. .'r <?:• {ti :t: {?:? titi :?:? •:?:• •:?:• •:t:• ;0:• :?:• :?:? W. •M W •:A:• 1 • ?__ } .1r ?? ? ? MICHAEL P. HAKES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION DEBRA L. HAKES, Defendant NO. 99-6543 CIVIL TERM 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 53301(c) XxRJU(XkkkgJ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Nov. 3, 1999, U.S. Certified Mail, Restricted Delivery, Return Receipt Requested, postage prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 53301(c) of the Divorce Code: by plaintiff March 3,000 by defendant March 23. 2000 (b)(1) Date of execution of the affidavit required by 53301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: NO CLAIMS RAISED 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: (b) Date plaintiff's Waiver of Notice in 53301(c) Divorce was filed with the Prothonctary: -? •?3•.?.? Date defendant's Waiver of Notice in 53301(c) Divorce was filed with the Prothonotary: "1-;11-a Attorney forte('P9l-6intifff(VJUiid=%) .., MICHAEL P. HAKES, Plaintiff V. DEBRA L. HAKES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O l9-' 21113 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEPEND 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 'telephone: (717) 249-3166 !1\d1v\hekeecom.dly MICHAEL P. HAKES, Plaintiff V. DEBRA L. HAKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 R_ - 65-q-3 elt4 P J44 CIVIL ACTION - LAW IN DIVORCE. COMPLAINT 1. The Plaintiff in this action is MICHAEL P. HAKES, an adult individual, who currently resides at 1403 Letchworth Road, Camp Hill, PA, 17011. 2. The Defendant in this action is DEBRA L. HAKES, an adult individual, who currently resides at 101 S. 2"d Street, Apt. 607, Harrisburg, PA 17101. 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 October 12, 1996, in 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. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is -1- 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. 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. 54904, relating to /uunswor?n/ falsification to authorities. Date. C?r ; •),-)- 1, ITF? MIQKAI?L N. STONE LaFAVgR & SHEKLETSKI _-E izabethfB% Stone, Esquire Supreme;Court ID #60251 414 Bridge Street, P.O. Box E New/ 6umberl d, PA 17070 e 17-774-7435 Tt1 pha Attorneys for Plaintiff -2- os v ? w > a 0 ,? r o a a U w tn W G . W ; PC M v? 3 W N M C < Q A N 4 Q 7 t K w ° Vf ? p m g o 1 w p ? ? F S B O G Xx b a p a p qq N ? N ? yy D O M ? q H Lu= C? C t V uir ? ' ? 00 T r ?h u. ? v d c„ ?-? .• ( J U \+ CJ 10 VO . 11? cd ?l 11\dlv\connnt.dl MICHAEL P. HAKES, Plaintiff V. DEBRA L. HAKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6543 CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 5 3301(c) of the Divorce Code was filed on October 28, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. 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. 5 4904 relating to unworn f??ifica- tion to authorities. 3-L3- no /G6e^ loor Date MICHAEL P. HAK , Plaintiff r? 4 T r ??: .¢ nth ? 'lf Q' "Ti • 3n ew t!\,nv\coneent.&tt MICHAEL P. HAKES, Plaintiff V. DEBRA L. HAKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6543 CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 5 3301(c) of the Divorce Code was filed on October 28, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the pena'.ties of 18 Pa. C.S. tion to authorities. 3-2 3 -enc Date 5 4904 relating to unsworn falsifica- DEBRA L. HAKES, Defendant tr to Y . , M w C:7 ??,JJJ 1 1 a e MSa f >¢'6i F: t1\d1v\1•v&1vs.not MICHAEL P. HAKES, Plaintiff v. DEBRA L. HAKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6543 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S 3301(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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating worn falsifica- tion to authorities. 3-13°l.0ae Date MICHAEL P. HAKES, Plaintiff Ln Cl) ?• N -' t c' n !1\tlly\l welvt.noc MICHAEL P. HAKES, Plaintiff V. DEBRA L. HAKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6543 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER 5 3301(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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsifica- tion to authorities. Date DEBRA L. HAKES, Defendant 17 J L] zs b b n o U II WIVUmal IN". aft MICHAEL P. HAKES, Plaintiff v. DEBRA L. HAKES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND CGUNTY, PENNSYLVANIA NO. 99-6543 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Debra L. Hakes, at 101 S. 2nd St., Apt. 607, Harrisburg, PA 17101, by United States Certified Mail, postage prepaid, restricted delivery, on November 3, 1999, as evidenced by the attached Certified Mail return receipts. SWORN TO AND SUBSgRIBED be_Lore me this day of ?,OL?Pn1cG¢AJ 1999. Not y Publi NOiANIAI - L KAY[ fa. 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