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HomeMy WebLinkAbout07-5206/ '+~R FRANCES ELISE WICKARD Plaintiff v. DENNIS A. WICKARD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.' o ~- SZOIr CIVIL TERM 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 aze wazned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment maybe 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 Streets, Cazlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 •r ~-.. FRANCES ELISE WICKARD Plaintiff v. DENNIS A. WICKARD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. D ~ ~ 5 2D Co CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Frances Elise Wickazd, who currently resides at 2011 Longs Gap Road, Carlisle, 17013, Cumberland County, Pennsylvania, since January 2003. 2. Defendant is Dennis A. Wickazd, who currently resides at 2011 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania, since January 2003. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 23, 2003, at 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 mamage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. ,.i ~. 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. § 4904, relating to unsworn falsification to authorities. Date: ~ -30 ' ~~ `~ Frances Elise Wickard, Plaintiff ANDREWS & JOHNSON By: Andrews, Esq. for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717)243-0123 ry ~ C~ _.- ~ v (~ "z7 ~ ,f ( r : n, `..._ G ~ ~Tf,~--~,, W T""" ~ r ~~ C f v ~ rte., `,-, 1 v ^ ~- f`f 'J w -=~ ~, 0o cx, -< d I~RANE?E8 ELISE WIEIEARD : IN THE a©URT ©F a©1biMON PLEAS OP Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW DENNIS A. WICKARD : NO. -~~ r CIVIL 1'1/RM Defendant : IN DIVORCE Nt~"Y~~._ E PR~~R SURNAME Aiotia~ ie i~ar~by giv®n that tl~e Aiaiuti~ iu th® above rnatts~, ~csleot aaa b~ a~a~ing ~~x:s~ _,_,X~, prior to the entry of a Final Decree in Divorce, Or after the entry of a Final Dee~ee in Dsvorca dated , hereby elects to resume the prior surname of France Elise Gutshall, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 744. gate: O O Frances Elise Wickard TO BE KNOWN AS: Fraace# Ellk Gutsbatl C©MMONWEAI.'I"H C)F PENNSYLVANIA ) . 5S. COUNTY OF CUMBERLAND ) On the ~~ day of September 2007, before me, a Notary Public, personally appeared Frances Elise Getshall, 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 canto e m hand and official seal. fiH OF PE NSY! ANIA t Public OTARfAL SEAL SHELLY SEXTON, Not~y PubNc Carlisle Bono, Cumberland County Commission Ex 'res A 'I 26, 2011 ~ ~. -.r ~ ~: a .~: D. ~ ~ ~ ~ ~~' ~ v ~ ~,.. -- v ~~ ~ ~P 0 ~~ 0 1ii/iR~°.1Y211{N~9 1{~;~ N1_JA31t~IW€M~ +. `~ FRANCES ELISE WICKARD Plaintiff v. DENNIS A. WICKARD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~ -- J ~ZOZp CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Dennis A. Wickard, in the above-captioned action and I certify that I am authorized to do so. DATE: ~`'.~/ • By, C"_.. ~~ ,c in say Baird, Attorney for Defendant r~ ~ ~, ~ -r~ a ~~ s, ., ~ N -~r'".~ ~ ; ~ - tl -,.. ~ c~, ~ +~ ..~ 'rf ~ ~ ..~wJf +5, d~' F. ELISE WICKARD : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW DENNIS A. WICKARD : NO. 07-5206 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tiled on August 31, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. I verify that the statements made in this Affidavit aze 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: /~ • ~ ~• G'`~- ~, Dennis A. Wickard, Defendant C'~ ra ~ C7 - ~: ° n ~ ~`~ q ~--- ,~ ;~.,~. w~~ r~+-te~,, _~_Z ~rr ;:-,. r~-, ~ ~ jti '~ "'"'~ F. ELISE WICKARD : llv THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW DENNIS A. WICKARD : NO. 07-5206 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 falsification to authorities. Dater f~ '' ~ l _~_, _. ~__~~__ -- Dennis A. Wickard, Defendant a ~ -r- ~_ ,~, rt"4 ; r ?< .a' P' 4 i+ ~ {f,~ r ., .T'' ~ 1'~? ~--i ~' F. ELISE WICKARD : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW DENNIS A. WICKARD : NO. 07-5206 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 falsification to authorities. Date: ~~~'~_ Date: p Frances Elise Wickard, Plaintiff NOW KNOWN AS: Frances Elise Gutshall, Plaintiff ~ C' rya ~ C~ `~'1 ~t ~ ~ i~ 7 ~ . :~ ~ n .T i ~~ ~ ~: [, ~1j,~: N -cs y-~-t ',':t ,~` . `~...q h1~•a --.1.d ~-~ 19 t .., w~ ~ ~~~geyJ. ~.~ ~~ r ~' •' ~ ...~ F. ELISE WICKARD : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. DENNIS A. WICKARD Defendant CIVIL ACTION -LAW NO. 07-5206 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT i . A Complaint in Divorce uirdGr Szction 3301(c) of the Divorce Cade ~Nas filed or. Aug~:s± 31, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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. Date: Date: ~ ~-- Frances Elise Wickard, Plaintiff NOW KNOWN AS: r"'--' Frances Elise Gutshall, Plaintiff p ~ "' ~ 'T~ ~'~, ~ ~~, j.r ~ ~ _~ ~ .,....,-. ~_c_ r ;z> ~:. GJ •~` FRANCES ELISE WICKARD Plaintiff v. DENNIS A. WICKARD TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-5206 CIVIL TERM IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD 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) of the Divorce Code. 2 Date and manner of service of the complaint: August 31 2007 by personal service to Defendant's counsel Lindsay Baird She signed an Affidavit of Service on August 31, 2007. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff December 1, 2007 ; by Defendant December 21, 2007 4. Related claims pending: None 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 21.2007. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 21, 2007. ANDREWS & JOHNSON Date: December 21, 2007 By: ~ayl P~-~fndrews, Esq. est Pomfret Street Carlisle, PA 17013 (717)243-0123 Supreme Court ID No. 15641 a L~ c :a -;~-~ ,~, ~ "~'?_; ,;._, . ~n ~~ a ~- _ ~ Wi a~ --~ _, t` c~a I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ' ~ PENNA. =;~ ~ - = Frances Elise Wickard N 0.07-5206 Plaintiff VERSUS Dennis A. Wickard Defendant DECREE IN DIVORCE AND NOW, !/~ ~_~, IT IS ORDERED AND Frances Elise Wickard DECREED THAT Dennis A. Wickard AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, 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 THE~OURT: ATTEST: ~ ,J , PROTHONOTARY ? ~~~i~ ~- ~i%~~ ~~ ~~ ~_ : ~..~" ..~ ~ ,,,. ~ . , _ ~ ~, ~ ~l ~~ ~~° ~l