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HomeMy WebLinkAbout99-06576 A G. ? `? F i S ,?ttF >Y J:` to ,. fF;T;?;? >T l r 6,{ 3 t_ M1 ? F p 4 * f not l" ' q4? ! °??F t . t a P'Y ; t ANY. ?y ry 1 5 vrv xi Y Y 4 U• ?y a` • a f Q a d f u ' l r < E a S # a t x x ?& .? ? Z } Y x k n ?? x A {4 5'` go- w rj > , , y?i 2 X4 N 1 hot Ant 4 f ?o iiy iy - t 3 '.9 JY + 1 k t AS h'1pp 'gy ty S ?#• ; q KYT p r# 1y. ?4µ?q v' d Y: t J a i•#'1. art ?+?r y ' y .4$ jp (Y. r ) S! N A Y k J' ?+) P{ y F P?4 f I Y 4 53 ?, S? 3 f 1 ? 1 Nom r:. Now cp} yJ?l { Y f •? a fY'?S } r { y q, a,y{ t a g _ 4 ?3 I T'. ) 4 -1i 1 } 3 ?^ C e fr f n $ t a v ? 71 y f? 1 1 J J S r 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. ? 4ii? y 4 fit/ .??7 Faye ,na. ?•® 7? a4 V i 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 r .4 cy,? co i : a iYy<?Y'? Pt +y )+tr ?S .7s p? t T I ct?{?k{i tj G 1 • M. aim. t MM), a for k" 3? 4a, WW 4b. card io MOM w. WMrotlr aon Mtlr m.lpl.q({o f MU Rohn Rw*4 W rtnm?tlw )8 '` Timothy D.oSToey 13 B Forge Road Boiling Springs, pp i 6. H.aIwO Or. (FrM1 Nams) fj 9.6gnauua, (, d&-n Orq R X, ps Form 3811, DaCMlllaf 1684 I Ww wm to row" IM y? blm*g uMC.a (br an 0*8 h.): 1. O Add?'a Afton om" Po.trnubrf" Fry ) rI 13 ?crlaw t bl9P OIftnd 1 u?COD ruvlo a ? Addr.u ragwald i Pud) ! rnneat c 0 tum eM- pt a? u1S3 c? 7 'y 1* it} i? y j F ? J g )' a L y ? A 4; 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 A t hJG fa-f dgg??hii 1r;- w-. l .f 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 c? o, ?.. `? ?; - ? =? o ?, °_ ? ? ? ??? h ? ? ? ???? ._. -;'- ? O v o, (? V 41 U \ ?I ?t1V ?.. 'r `ffi 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 r. :..y..,. r...... .:....?.v...r. w..:.:. • ..?:.. . n-....... .u....... ?...?a.._.....-titer....,.?...?..?...aw.`._..?.?..1 .. MI 4 xa a ' $ o 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 ?,