HomeMy WebLinkAbout99-07206
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IN THE COURT OF COMMON PLEAS
OFCU M BERLAND COUNTY
STATE OF PENNA.
No. 7206 Civil 1999
KRISTAL BLAKE
VERSUS
W. BRADFORD BLAKE, JP..
DECREE IN
DIVORCE
AND NOW, 2-!j , 4C L, IT IS ORDERED AND
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BY THE COURT:
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PROTHONOTARY
DECREED THAT
KRISTAL BLAKE PLAINTIFF,
AND W. BRADFORD BLAKE, JR. ,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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KRISTAL BLAKE
VS.
W. BRADFORD BLAKE, JR.
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 7(}?g}t 3301 (c)
9{QAK4)A>(A? of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint: December 20, 19991
Certified mail, restricted delivery , return receip t reguested
3. (Complete e ither paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by section
3301 21A(c) of the Divorce Code: by the plaintiff 4/15/02
by defendant 4/8/02
(b) (1) Date of execution of the plaintiff's affidavit required by
Section 201(d) of the Divorce Code:
(2) Date of service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: None
IN THE COURT OF COMMON PLEAS OF
CU,K3ERLAND COUNTY, PENNSYLVANIA
NO. 720C CIVIL 19 99
PRAECIPE TO TRANSMIT RECORD
5. Indicate date and manner of service of the notice of intention to file
praecipe to transmit record, and attach a copy of said notice under section 201
(d)(1)(1) of the Divorce
/' attar-n8y for (Plaintiff)
P. Richard Waoner,F;sc0D3af )
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KRISTAL A. BLAKE,
Plaintiff,
V.
W. BRADFORD BLAKE, JR.
t
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW C??U L
IN DIVORCE
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 in divorce or
annulment may be entered against you by the Court. A judgment
may also be entered against you for another 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) 24 9-3 166
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KRISTAL A. BLAKE, : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v. :NO. 7.2 t, e1v.l Te-f?
CIVIL ACTION - LAW
W. BRADFORD BLAKE, JR.,
IN DIVORCE
Defendant.
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, KRISTAL A. BLAKE, by and through her
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Complaint in
Divorce:
1. The Plaintiff, Kristal A. Blake, is an adult individual currently residing at
927 Willcliff Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant, W. Bradford, Blake, Jr., is an adult individual currently
residing at 927 Willcliff Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this
Complaint.
4. Plaintiff and Defendant are husband and wife having been married on May
31, 1980, in Harrisburg, Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the
parties in this or any other jurisdiction.
6. Neither Plaintiff nor Defendant are members of the Armed Forces of the
United States or any of its Allies.
7. Plaintiff has been advised of the availability of counseling and that she has
the right to request that the Court require both parties to participate in counseling.
8. The Plaintiff avers as grounds on which this action is based are:
A. That pursuant to §3301(c) of the Divorce Code, the marriage is
irretrievably broken; and
B. That pursuant to §3301(d) of the Divorce Code, that as of
August 1, 2001, the parties will have lived separate and apart for
a period of at least two continuous years.
WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in
Divorce.
COUNTI
EQUITABLE DISTRIBUTION
9. Paragraphs 1 through 8 above are incorporated herein by reference and
made a part hereof.
10. During the marriage, Plaintiff and Defendant have acquired various items
of marital property, both real and personal, which are subject to equitable
distribution under Section 401 of the Divorce Code of 1980.
WHEREFORE, Plaintiff prays this Court to:
A. Enter a Decree in Divorce;
B. Equitably distribute all property, both real and personal, owned
by the parties; and
C. Grant such further relief as the Court may deem equitable and
just.
Respectfully submitted,
Mancke, Wagner, Hershey & Tully
By
Richard Wainer, Esquire
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
Date: // d?
i verify that the statements made in the foregoing
document 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.
DATE: ?? ?," %.z
KRISTAL BLAKE,
Plaintiff,
V.
W. BRADFORD BLAKE, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7206 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of
MANCKE, WAGNER HERSHEY & TULLY, do hereby certify that on this
date a copy of the COMPLAINT IN DIVORCE was served upon the
following person and in the manner indicated below, which service
satisfies the requirements of the Pennsylvania Rules of Civil
Procedure, by depositing the same in the United States mail,
Harrisburg, Pennsylvania, certified, restricted delivery, return
receipt requested, and addressed as follows:
Mr. W. Bradford Blake, Jr.
927 Willcliff Drive
Mechanicsburg, Pa 17055
DATE: 12/20/99
Debra K. Spi er, Secretary
MANCKE, WAGNER, HERSHEY & TULLY
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorney for Plaintiff
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
n? -tucn In. Intarnatinnal Mail (Sao rovorso)
re"
. Bradford Blake Jr.
Slmel & Nambee
927 Willcliff
Drive
Post Dllice, State, 8 ZIP Coda
14echanicsbu q,
PA 170l
Postage $ .55
Cerefied Fee 1.35
Special Delivery Fee
Restricted Delivery Fee 2.75
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' flelum Receipt Slowing to
valom 8 Dale Delivered
i RewmeptshowigWw1hon.
• Dale, AAdeesleesPddrm
1.10
TOTAL Postage & Fees $ 5.75
I Posunark or Date
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12/13/99
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m SEND
t v .Complete Name 1 andror 2 for addidonal servkes.
m •CanWela lleme3,41a,erM4b.
i 0 ?Ppent to l1uorrn name and seeress an the mveree of this form se that we can return
Z! c I aAaach Nle farm to the from of the mallpiece, or an the back if space does not
o eWrite'ReNm Receipt Requestee'an the mallpiece below the nnicle number.
The Return Receipt wla show to wham the article was delivered and the date
i C delivered.
0 3. Article Addressed to: 48. Artie
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E Mr. W. Bradford Blake, Jr. ab.ser
0 927 Willcliff Drive ? Reg
0 Mechanicsburg, PA 17055 ? Exp
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11! 7. Date
d 6 Pdnr memo) e. Addr
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I also wish to receive the I
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following services (for an
extra fee):
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s Address
1. ? Addressee
2. ® Restricted Delivery
Consult postmaster for fee.
5. Receive y. ( and lee is pald)
6.SignattJure: AddresseeorAgent)
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dress (only it requested
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KRISTAL BLAKE,
v.
Plaintiff,
W. BRADFORD BLAKE, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7206 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on November 30, 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 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
?zl-c sub]-=CL to t-ie p-3nalties of 13 Pa.C.a. Secc.-*Qn 4904,
relating to unsworn falsification to authorities.
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DATE: ' LI5h// ) /?//ty
Kris'tal Blake
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II_ N
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KRISTAL BLAKE,
Plaintiff,
V.
W. BRADFORD BLAKE, JR.,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7206 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. 1 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. §4904 relating to
unsworth falsification to authorities.
Kristal Bake
DATE : ?/ /5 /' L
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KRISTAL BLAKE,
Plaintiff:,
v.
W. BRADFORD BLAKE, IR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7206 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on November 30, 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. 1 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. Section 4904,
relating to unsworn falsification to authorities.
DATE: L
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W. B dfor ace, r.
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Y,RISTAL BLAKE,
V-.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
W. BRADFORD BLAKE, JR.,
Defendant
NO. 99-7206 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE UNDER
SECTION 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. §4904 relating to
unsworn falsificarion to authorities.
Bi r.
W. Brad orp lake, r.
DATE:
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KRISTAL BLAKE,
Plaintiff
V.
W. BRADFORD BLAKE, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-7206 CIVIL TERM
RDER OF COURT
AND NOW, this 26th day of January, 2001, upon
consideration of the petition filed in the above-captioned matter,
and scheduled for hearing on this date, and pursuant to
information presented in open court by Plaintiff's counsel,
P. Richard Wagner, Esquire, that the matter may be deemed moot,
the petition is deemed moot.
By the Court,
P. Richard Wagner, Esquire
For the Plaintiff
W. Bradford Blake, Jr. - NOT APPEARING
1948 Lake Atrium Circle, Apt. 121
Orlando, FL 32839
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KRISTAL BLAKE, : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff/Petitioner
V.
W. BRADFORD BLAKE, JR.,
NO: 99-7206
CIVIL ACTION - LAW
IN DIVORCE
Defendant/Respondent
ORDER
AND NOW, this 2-(-' day of 1e-r r -, L,(•) , 2000, upon Petition of
Kristal Blake, a Rule is hereby issued upon the Respondent, W. Bradford Blake, Jr.,
to show cause why, if any, the relief requested should not be ganted.
RULE RETURNABLE the a(o day of a Lt ? 200 at
/ 30 o'clock --p-.m. in Courtroom No. _I of the Cumberland County
Courthouse, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania.
BY THE COURT:
Cow ?1
12-13 -00
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KRISTAL BLAKE, : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff/Petitioner
: NO: 99-7206
V.
CIVIL ACTION - LAW
W. BRADFORD BLAKE, JR., : IN DIVORCE
Defendant/Respondent
PETITION
AND NOW, comes your Petitioner, Kristal Blake, by and through her
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Petition:
Your Petitioner, Kristal Blake, is the Plaintiff in the above-captioned
divorce action, having an address of 714 Shaffer Street, Enola, Cumberland County,
Pennsylvania.
2. The Respondent, W. Bradford Blake, Jr., is the Defendant in the above-
captioned divorce action, having a residence of 1948 Lake Atrium Circle, Apt. 121,
Orlando, Florida, 32839.
3. The Respondent vacated the marital home in December of 1999, and
moved to Florida, and has made no contributions to the Petitioner for maintenance
of the home, which is a marital asset.
4. From time to time, there have been checks coming to the home that are in
both names, which said checks exceed $2,000.00 to date.
5. Petitioner has requested the Respondent to execute the checks to assist her
in maintaining the home which includes a $1,280.00 per month mortgage payment
and a $300.00 per montli loan for the down payment.
6. Respondent has not made any payment to the Petitioner to assist with the
mortgage since December of 1999, and has made no contributions towards the
maintenance or upkeep of the liome despite the fact that it is a marital asset and
despite the fact that it is on the market for sale.
7. Petitioner believes and therefore avers that the checks that are mentioned
above can and should be cashed, placed in an account and used for the payment of
the upkeep and mortgage on the property to preserve the integrity of the marital
estate.
WHEREFORE, Petitioner prays this Court to direct the Respondent to
endorse the cliecks along with the Petitioner, place them in escrow, and use the
proceeds for payment of the mortgage on the property until such time that the
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property can be divided, sold, or otlierwise disposed of through the equitable
distribution proceedings.
Respectfully submitted,
Mancke, WaLmer, Hershey & Tully
By
Attorneys for Petitioner
Date: I Do
-3-
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
VERIFICATION
I verify that the statements made in the foregoing
document 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.
DATE : 112:2?,7'lJ4