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IN THE COURT OF COMMON PLEAS
NINLE L. STOEY,
Plaintiff
VERSUS
TIMOTHY D. STOEYo
Defendant
No.
99-6576
DECREE IN
DIVORCE
1999
AND NOW, \? ~-d2- \ , 2000 , IT IS ORDERED AND
DECREED THAT Nicole L. Stogy , PLAINTIFF,
AND Timothy D. Stoey 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;
none
BY THr- COU
ATTEST: J.
PROTHONOTARY
OF CUMBERLAND COUNTY
STATE OF PENNA.
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NICOLE L. STOEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6576 Civil Term
TIMOTHY D. STOEY, : IN DIVORCE
Defendant
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 3301(c).
2. Date and manner of service of the Complaint:
Certified mail, restricted delivery November 11, 1999, as attached.
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 the Plaintiff: 2/27/00;
By Defendant: 2/28/00
(B)(1) Date of Execution of the Plaintiff's Affidavit
required by Section 3301(d) of the Divorce Code:
(2) Date of Service of the Plaintiff's Affidavit upon
the Defendant:
4. Related claims pending: No claims were 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 Section
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'` Timothy D.oSToey
13 B Forge Road
Boiling Springs, pp
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ps Form 3811, DaCMlllaf 1684
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Nicole L. Stoey, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. CIVIL 199q G Jl7?
Timothy D. Stoey,
Defendant IN DIVORCE
NOTICE
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 Court
House, High and Hanover Street, Carlisle.
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.
SAIDIS,
SHUFF &
MASLAND
ATRIIUMM-ANAW
26 W. High 6lreer
Carlisle, PA
Cumberland County Bar Assn.
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Nicole L. Stoey,
Plaintiff
V.
Timothy D. Stoey,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL 199 • 6,Y76 ?tuUTlIN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OR 301(d) OF THE DIVORCE CODE
1. Plaintiff is Nicole L. Stoey, who currently resides at
729 Petersburg Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Timothy D. Stoey, who currently resides
at 13 "B" Forge Road, Boiling Springs, PA 17007, Cumberland
County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 27,
1992 in Plainfield, Pennsylvania.
5. There have been no prior actions of divorce or for
SAIDIS,
SHUFF &
MASLAND
A710RK111MMAW
26 W. 111gh Siren
Carlisle, PA
annulment between the parties.
6. The Plaintiff has been advised of the availability of
marriage counseling and the Plaintiff may have the right to
request that the Court require the parties to participate in
counseling. Having been so advised Plaintiff does not desire
the Court to order counseling.
7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff prays Your Honorable Court to enter a I I
decree of divorce.
Respectfull
Jo nna De E q.
Attor v for Pla tiff
SAIDIS,
SHUFF &
MASLAND
ATIORMWAT"If
16 W. IIISb Sued
Carlisle. PA
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VERIFICATION
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. Section 4904, relating to
unsworn falsification to authorities.
Dated: ?-J ??v
Nicole L. Stoey
NICOLE L. STOEY,
Plaintiff
V.
TIMOTHY D. STOEY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- ?57G ?+i1
IN DIVORCE
AFFIDAVIT
I, Nicole L. Stoey, being duly sworn according to
law, depose and say:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling.
(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, I do not request that the court
require that my spouse and I participate in counselling prior
to a divorce decree being handed down by the court.
I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: /0-6 -q`7 -L. ?J?yc
Nicole L. Stoe, P aint
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NICOLE L. STOEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6576
V.
TIMOTHY D. STOEY, IN DIVORCE
Defendant
PLAINTIFF'S
AFFIDAVIT OF CON .NT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
CRY 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 October 29, 1999.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date
of the filing of the Complaint.
3. I consent to the entry of a final decree of divorce
without notice.
4. 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.
5. 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. Section 4904
relating to unsworn falsification to authorities.
DATED: ? •?
Nicole L.?Stt7'P
oey, Pla ntiff
SAIDIS,
SHUFF &
MAC
26 W. High Street
Carlisle. PA
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NICOLE L. STOEY,
Plaintiff
V.
TIMOTHY D. STOEY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6576
IN DIVORCE
DEFENDANT'S
SAIDIS,
SHUFF &
MASLAND
A MM-AT-LAW
36 W. IIISh Street
Carlisle, PA
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on October 29, 1999.
2. Defendant acknowledges and accepts service of the
Complaint on November 1, 1999.
3. The marriage of 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
counselling and understand that I may request that the court
require counselling. I do not request that the ccvrt require
counselling.
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. Section 4904 relating to
unsworn falsification to authorities.
DATED: 27"00 -; nI `?- O? -
T mothy D. Stoey
Defendant
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