Loading...
HomeMy WebLinkAbout03-3420KAREN WOLFE, Plaintiff TIMOTHY WOLFE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO. 03- 3q'3>q57 CIVIL TERM : IN THE COURT OF COMMON PLEAS OF PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Karen Wolfe, Plaimiff, to proceed in forma pauperis. The Family Law Clinic, attomeys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the Costs and that we are providing flee legal service to the party. Date Respectfully submitted, Lara M. Mammana Certified Legal Intern KAREN WOLFE, Plaintiff TIMOTHY WOLFE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : NO. 03- _736,,20 CIVIL TERM 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 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, 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 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. KAREN WOLFE, Plaintiff TIMOTHY WOLFE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW : 1N DIVORCE : NO. 03- ~~c/,1, ,~ CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. §§ 3301 (a)(5), (c) & (d} OF THE DIVORCE CODE The plaintiff, Karen Wolfe, by her attorneys, the Family Law Clinic, sets forth the following cause of action for divorce: 1. Plaintiff is Karen Wolfe, whose home address is confidential. Her post office box number is 355, Newville, Pennsylvania, Cumberland County, Pennsylvania 17241. 2. Defendant is Timothy Wolfe, who is currently incarcerated at Wakulla Correctional Institution, 110 Melaleuca Drive, Crawfordsville, Florida. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married in Newville, Cumberland County, Pennsylvania, on June 24, 1980. 5. Plaintiff and Defendant have lived separate and apart since July of 2002. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 8. The Defendant was convicted of a felony Driving Under the Influence of Alcohol and sentenced to serve more than two years imprisonment. A true and correct copy of the Defendant's sentence of imprisonment is attached as Exhibit A, and incorporated herein by reference. 9. 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. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Certified Legal Intern Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 717/243 -2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me tot he penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Da;~~ ~(~ ~ ~- / 0 ~ 0'~ Plaintiff, Karen Wolfe KAREN WOLFE, Plaintiff TIMOTHY WOLFE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 03- CIVIL TERM IN THE COURT OF COMMON PLEAS OF PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Karen Wolfe, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Respectfully submitted, Certified Legal Intern DCt4 0 758301 USER ID: DRECCXP PAGE: 01 + IISO006 OVERALL INMATE RECORD AS OF 03/25/03 TIME: 11:30 NAME: WOLFE, TIMOTHY L. DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING INFORMATION IS FROM THE RECORD OF THE INMATE NAMED ABOVE. SOME DATA AS WELL AS RELEASE DATE(S) ARE SUBJECT TO CHANGE WITH THE AWARD OF AND/OR FORFEITURE OF GAIN TIME OR PROVISIONAL CREDITS OR WITH A CHANGE IN SENTENCE STRUCTURE OR INMATE STATUS. LOCATION: ll8-WAKULLA C.I. OVERALL TERM: 5 YRS 5MOS 21DAYS CUSTODY GR: CLOSE SINCE: 09/05/02 DATE OF BIRTH: 01/31/56 SEX: MALE BIRTHPLACE: PENNSYLVANIA HT: 5' 9" SOC.SEC.NO.: PROVISIONAL RELEASE DATE: NO CREDITS TENTATIVE RELEASE DATE: 10/31/2007 LAST PROV.AWARD: 0 DAYS ON / / LAST GAIN TIME: 10 DAYS ON 02/28/03 RACE: WHITE EYES: GREEN FBI NO: FDLE: FILE IMAGING: CURR. INCARCERATION RECS IMGD. THE FOLLOWING DATES ARE SET BY THE PAROLE COMMISSION. QUESTIONS ABOUT THESE DATES SHOULD BE DIRECTED TO TEAT AGENCY AT (904) 488-1655. CONTROL RELEASE DATE: INELIGIBLE PRESUMPTIVE PAROLE DATE: 99/99/9999 CERTIFIED TO BE TRUE AND CORRECT COPY OF DOCUMENT AS SAME APPF. ARS IN OFFICIAL DC14 0 758301 NAME: WOLFE, TIMOTHY L. USER ID: DRECCXP PAGE: 02 + INMATE SENTENCES AS OF 03/25/03 TIME: 11:30 DOC NO: 758301 STATUS: ACTIVE THE CURRENT INMATE RECORD IS COMPRISED OF CONCURRENT AND/OR CONSECUTIVE SENTENCES WHICH ARE COMBINED TO ESTABLISH THE OVER3tLL TERM. --- PRIOR INCARCERATION --- IMPOSED COUNTY CASE NO. OFFENSE YRS MO DY 08/03/94 PASCO 51-8800301 FELONY DUI 4TH/SUBS. 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL 08/03/94 PASCO 51-8801822 FELONY DUI 4TH/SUBS. 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL 08/03/94 PASCO 51-8802596 RESISTING OFFICER W/ 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL 08/03/94 PASCO 51-8802596 AGG ASSLT-W/WPN NO I 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL 08/03/94 PASCO 51-8802596 AGG ASSLT-W/WPN NO I 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL 08/03/94 PASCO 51-8802596 BATTERY LAW ENFORCEM 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL 08/03/94 PASCO 51-8802596 BATTERY LAW ENFORCEM 2 0 0 03/01/95 SPEC.PROV.: PAROLE INEL --- CURRENT INCARCEPJtTION --- 08/14/02 PASCO 51-9501928 FELONY DUI 4TH/SUBS. 5 0 0 SPEC.PROV.: PAROLE INEL SENTENCING GUIDELINES OFFENSE LEVEL: 06 08/14/02 PASCO 51-9700639 FELONY DUI 4TH/SUBS. 5 0 0 SPEC.PROV.: PAROLE INEL SENTENCING GUIDELINES OFFENSE LEVEL: 06 85% MINIMUM RELEASE DATE: 10/26/2006 08/14/02 PASCO 51-9700639 DRIV W/LIC S/R/C/D F 0 5 21 SPEC.PROV.: PAROLE INEL SENTENCING GUIDELINES OFFENSE LEVEL: 01 85% MINIMUM RELEASE DATE: 10/05/2007 08/14/02 PASCO 51-9803085 FAIL.TO APPEAR/FEL.B 5 0 0 SPEC.PROV.: PAROLE INEL SENTENCING GUIDELINES OFFENSE LEVEL: 04 85% MINIMUM RELEASE DATE: 10/26/2006 DC14 0 758301 NAME: WOLFE, TIMOTHY L. USER ID: DRECCXP PAGE: 03 + INMATE DETAINERS AS OF 03/25/03 TIME: 11:30 DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING REFLECTS DETAINERS AGAINST THIS RECORD, AND/OR REQUESTS TO BE NOTIFIED PRIOR TO RELEASE OF THE INMATE. FILED TYPE --- PRIOR INCARCERATION --- AUTHORITY CHARGE(S) REMOVED NO DETAINER RECORDS FOUND DC14 0 758301 USER ID: DRECCXP PAGE: 04 + INMATE MOVEMENT/TRANSFER HISTORY AS OF 03/25/03 TIME: 11:30 NAME: WOLFE, TIMOTHY L. DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING ENTRIES REFLECT MOVEMENT BY THE INMATE BETWEEN DEPARTMENT FACILITIES AS WELL AS RELEASES AND RETURNS FROM OUTSIDE AGENCIES. DATE 08/18/94 08/26/94 10/14/94 10/20/94 03/01/95 MOVEMENT TYPE NEW COMMITMENT TRANSFERRED TO TRANSFERRED TO TP~ANSFERRED TO EXPIRATION PRIOR INCARCERATION --- DESTINATION/LOCATION N.F.R.C.- MAIN UNIT N.F.R.C.- WEST UNIT MADISON C.I. MADISON WORK CAMP HILLSBORO FROM PASCO N.F.R.C.- MAIN UNIT N.F~R.C.- WEST UNIT MADISON C.I. MADISON WORK CAMP 08/29/02 10/07/02 --- CURRENT INCARCERATION --- NE~ COMMITMENT CFRC-MAIN TP,3kNSFERRED TO WAKULLA C.I. PASCO CFRC-MAIN DC14 0 758301 USER ID: DRECCXP PAGE: 05 + INMATE DISCIPLINARY ACTIONS AS OF 03/25/03 TIME: 11:30 NAME: WOLFE, TIMOTHY L. DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING ENTRIES REFLECT DISCIPLINARY ACTIONS AGAINST THE INMATE FOR VIOLATION OF THE RULE CITED AND INDICATE THE GAIN TIME DAYS LOST. DATE --- PRIOR INCARCERATION DAYS VIOLATION LOCATION NO DISCIPLINARY ACTIONS DC14 0 758301 USER ID: DRECCXP PAGE: 06 + INMATE CLASSIFICATION ACTIONS AS OF 03/25/03 TIME: 11:30 NAME: WOLFE, TIMOTHY L. DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING ENTRIES REFLECT CLASSIFICATION ACTIONS TAKEN REGARDING THE INMATE. DATE 08/29/94 --- PRIOR INCARCEP. ATION TYPE CUSTODY LOCATION LEVEL INITIAL MINIMUM N.F.R.C.- MAIN U 1 --- CURRENT INCARCERATION --- 09/05/02 INITIAL CLOSE CFRC-MAIN 01 DC14 0 758301 USER ID: DRECCXP PAGE: 07 + CONTROL RELEASE ACTIONS AS OF 03/25/03 TIME: 11:30 NAME: WOLFE, TIMOTHY L. DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING ENTRIES REFLECT CONTROL RELEASE ACTIONS TAKEN BY THE PAROLE COMMISSION FOR THIS INMATE INCLUDING ANY ADVANCEMENTS OF THE INMATE'S CONTROL RELEASE DATE. --- PRIOR INCARCERATION --- DATE TYPE DAYS REASON 08/26/94 INMATE DETERM STAT INELIG-CRIS 000 CR/8 - CRIME AGAINST L.E. DC14 0 758301 NAME: WOLFE, TIMOTHY L. USER ID: DRECCXP PAGE: 08 + OFFENDER NAMES AS OF 03/25/03 TIME: 11:30 DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING ENTRIES REFLECT ALL NAMES BY WHICH THE OFFENDER IS KNOWN. TYPE NAME TRUE WOLFE, TIMOTHY L. COMMIT. WOLFE, TIMOTHY ALIAS HAWK, FDLE NM WOLFE, TIMOTHY L. DC14 0 758301 USER ID: DRECCXP PAGE: 09 GAIN TIME(GT)& PROVISIONAL CREDITS(PC) AS OF 03/25/03 TIME: 11:30 NAME: WOLFE, TIMOTHY L. DOC NO: 758301 STATUS: ACTIVE THE FOLLOWING ENTRIES REFLECT ONLY T}{AT GT AMD PC WHICH HAS BEEN USED TO COMPUTE TNE INMATE'S OVERALL RELEASE DATE. NOT SHOWN IS GT AND PC PREVIOUSLY EARNED THAT DOES NOT AFFECT THE RELEASE DATES DUE TO MANDATORY TERMS, OTHER SENTENCING PROVISIONS, REVOCATIONS, OR ESCAPE CONVICTIONS. --- PRIOR INCARCERATION --- AWARDED TYPE DAYS AWARDED TYPE DAYS 08/31/94 INCENT. 4 09/30/94 INCENT. 20 10/31/94 INCENT. 20 11/30/94 INCENT. 20 12/31/94 INCENT. 20 01/31/95 INCENT. 10 --- CURRENT INCARCERATION --- 08/31/02 STP GT 4 09/30/02 STP GT 4 10/31/02 STP GT 10 11/30/02 STP GT 10 12/31/02 STP GT 10 01/31/03 STP GT 10 02/28/03 STP GT 10 KAREN WOLFE, Plaintiff TIMOTHY WOLFE, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW : 1N DIVORCE NO. 03- 3420 CIVIL TERM AFFIDAVIT OF SERVICE I, 1[~,%..,/.,.o , hereby certify that I am a competent adult and that I served a true and correct copy of the Complaint for Divorce on the Defendant, Timothy Wolfe, at the Wakulla Correctional Institution, 110 Melaleuca Drive Crawfordville, Wakulla County, Florida. Service was complete upon receipt by Timothy Wolfe on the _ .~ day of '4 ~,)'t., ~ 3L' , 2003. 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 unsworn falsification to authorities. PROVIDED TO WAKULLA CI ON AUG-! 4 2003 VS. . OF O~voRr.. F Cov.~ K ' ' T ~ I~ L ~ oF: :~ AFFI ~AVl~r ;: ~£RTI F I CATE ¢ o/V F£/V F$ oP FACTS ColVCLU$14VV ...... oF SEPtVt(~...' - 5'TATS' M ~T e,~ FAC'T.~ PEFfNDAN'T,~ TII'~OTH¥ L.¥VoLF~. Co~o'~-e.y~.3- T~5 PIVOI~cE o~ O/~oU~OD5 .5~T FoRg'~ HER~. ft RC~Unn ~ T ..T. T-RIEO g~. FORE ~lvoO. c~ P~OCEE~REg weRE THE D/~F~'~P/~NT TIPlol't-i~ L.,¥voLi--£ IN ~P. OUMD ~ oF CO~VTEgT¥...,EWT 5"ratE5 71-1A'r No ~F-PiA'TIoM V, IA5 EU~A TI~,~I::-O, OR O~VEW TO 'l't--/S co~Rt-1-o l~:~P Hi~,7 IW I~15 t'IA£RIAdE. THE DF-FEIODAWT TtlVloTUy L_. WOLFF ..ST."rFES . BY ~tc~14Tj-' AS Cq P,qP. ENT 4tVl) I:A. THE~ d-HAT ltO · NO 'Tie'l/:: I-~A~ OEFEND,,'0~T I~vER V~AiVL:0 OR ..C[VEN UP P,qRFWTAL RIC--HT5 TO $~1o TIMOTHy L.VUDLF~ I'tU~r~L'( Al'OD C6~T~sT<. TI~i$ DIVOP. CE F3A£F-I~ oM ~qLL 9-,,tC~l-t't'.[ To [-/AVE CN(L,D VI£1YATIolv~ AlvO I~'F~A~DLES..~' o/:: ~)LL THt~' Rt~.-i.~kj' OF FATRF~t~.HOOD,. 7-0 ALL L/t~v' ,M.4K.~' 9UOLi.'F_ P,~ff ~ALF OF' I1,,I COIVr'L q -~ I ONi 'I-HE IDEFIF~/PAIdl'- TIMo'tt-~'t' L.','UDI-FE tTumsz . ~'rAruD.~AO_~ o~: kAW [3~_q£o b'PoN /~ PRO'-SE OPTio~).S GRa~T 1-i1.~ PFT~T~O~J, C~H;.c)t~ P,a t7ot3 PROVIDED TO WAKULLA Cl ON AUG 1 4 2003 KAREN WOLFE Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE TIMOTHY WOLFE : Defendant : NO. 03-3420 CIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. ~ER SECTION 3301 d OF THE DIVORCE CODE 1. The parties to this action separated on July 12, 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. ~ Date Plaintiff KAREN WOLFE Plaintiff TIMOTHY WOLFE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 03-3420 CIVIL TERM CERTIFICATE OF SERVICE I, Jason C. Evans, hereby certify that I am a competent adult and that I served a correct copy of the Plaintiff's Affidavit under {}3301 (d) of the Divome Code, through regular mail postage prepaid on July 12, 2004, to TIMOTHY WOLFE, at Marion Correctional Institution, 3269 NW 105th Street, Marion County, Lowell, FL 32663-0158, NY 11590. I verify that the statements made in this certificate are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Jaso~C. Ewans Certffied Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 KAREN WOLFE Plaintiff TIMOTHY WOLFE Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COU3qTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE :NO. 03-3420 CWIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divome: irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Defendant on August 5, 2003. 3. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: by the Plaintiff: July 12, 2004. Date of filing of the Affidavit: July 12, 2004. Date of service of the Plaintiff's Affidavit upon the Defendant: July 12, 2004. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of §3301(d) Divorce Decree, a copy of which is attached: Notice mailed to Defendant at Marion Correctional Institution, 3269 NW 105th Street, Marion County, Lowell, FL 32663-0158, by regular U.S. mail, first class, postage prepaid on August 4, 2004. Date Respecl / Jason Certific ~ully Submitted, Evans l Legal Intern XNNE ~A .~ONALI~LFOX - LUCY JOHNSTON-WALSH ROBERT E. RAINS THOMAS M. PLACE Supervising Attorneys The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717)243 -2968 Fax (717)243 -3639 KAREN WOLFE Plaintiff TIMOTHY WOLFE Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 03-3420 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT, Timothy Wolfe You have been sued in an action for divorce. You have tailed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after August 24, 2004 the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothontary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Associatic.n 32 South Bedford Street. Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. KAREN WOLFE Plaintiff TIMOTHY WOLFE Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW : IN DIVORCE : : NO. 03-3420 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): [] (a) I do not oppose the entry ora divorce decree. [] (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The Parties to this action have not lived separate and apart for a period ora at least two years. [] (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I rnust also file all my economic claims with the prothonotary in writing and serve them on the other party. IfI fail to do so before the date set forth on the Notice of Intent to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 unsworn falsification to authorities. Date Signature Notice: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. KAREN WOLFE Plaintiff TIMOTHY WOLFE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 03-3420 CIVIL TERM CERTIFICATE OF SERVICE I, Jason C. Evans, hereby certify that I am a competent adult and that I served a correct copy of the Plaintiffs Affidavit under §3301(d) of the Divorce Code, through regular mail postage prepaid on July 12, 2004, to TIMOTHY WOLFE, at Minion Correctional Institution, 3269 NW 105th Street, Marion County, Lowell, FL 32663-0158, NY 11590. I verify that the statements made in this certificate are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Jasor~ C. Ewans Cert~kSed Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF KAREN WOLFE Plaintiff VERSUS Defendant PENNA. No. 03-3420 PLEAS DECREE IN DIVORCE AND NOW,~ IT IS ORDERED AND DECREED THAT Karen Wolfe , PLAINTIFF, AND Timothy Wolfe ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TB~S ACTION FOR WHIiCH A FINAL ORDER HAS NOT YET BEEN ENTERED; None BY T~Cou ATTEST: ~ '(' j. · / ' ~r PROTHONOTARY KAREN WOLFE, Plaintiff TIMOTHY WOLFE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : NO. 03-3420 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted divorced from the bonds of matrimony on the ]6th day of September 2004, hereby elects to retake and hereafter use her previous name of Karen Johnson, and gives this written notice avowing her intention to do so pursuant to the provisions of 54 Pa. C.S. § 704. Wishes To Be Known As: ~/&~ (5~~ Karen Johnson ~/ ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF SS. On this o9/-]ta day of ~49P~r~ O_x.~ , 2004, before me, a Notary Public, personally appeared Karen Wolfe, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notadal Seal Laurie L. Wolf, Notary Public &luth Mlddleton Twp., Cumberland County MY Commission Expires Jan. 7, 2006 Member, Pennsylvania Assodation Of Notaries (._....--~NO~TARY PLEB~IC/ 6;