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HomeMy WebLinkAbout03-6553NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF HEATHER A. WICKARD, Plaintiff TIMMY L. WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 03 - ~, ~'~ 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 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 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 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 17013. 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, Pennsylvania 17013 717-243-3166 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 64 SOUTH PITT STREET CARLISLE PA 17013 (7'17) 243-~0~0 ATTORNEY FOR PLAINTIFF HEATHER A. WICKARD, Plaintiff TIMMY L. WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 03 - ~~5~-~- CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 330t(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Heather A. Wickard, an adult individual residing at 5 Robin Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Timmy L. Wickard, an adult individual residing at 315 Juniper Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on February 23, 1991, in New Bloomfield, Perry County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. Heather A. Wickard, Plaintiff ,2003 / IR~tl. AW OFFIC;EESQUIRE '--~upreme Court ID #87380 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Attorney for Plaintiff HEATHER A. WICKARD, Plaintiff TIMMY L. WICKARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03- ~-~ CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~'~'~f/.~> // , 2003 ) Heather A. Wickard, Plaintiff HEATHER A. WICKARD, : IN THE COURT OF COMMON PLEAS OF TIMMY L. WICKARD, Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2003 - 6553 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about December 22, 2003 and served upon defendant on December 27, 2003 (see affidavit of service filed May28, 2004). 2. The marriage of phintiff and defendant is irretrievably broken and more than ninety days have ehpsed from the date of the service of the complaint. · ' ' e after service of notice of intention 3. I consem to the entry of a final decree m divorc. to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C~ S. Section 4904 relating to unswom falsification to authorities. I~ff~ ,~tC3 ,2004 HEATHER A. WICKARD HEATHER A. WICKARD, : IN THE COURT OF COMMON PLEAS OF TIMMY L. WICKARD, Plaintiff Defendant : CUMBERLAND couNTY, PENNSYLVANIA : CML ACTION - L/kW : : NO. 2003 - 6553 CIVIL TERM : IN DIVORCE ~t~/AIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DEC~E ~IJNDER SECTION 3301(C) OF THE D13rORC. E 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 propero/, hwyeFs 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 C°urt and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I vetifythat the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C~S. Section 4904 relating to unswom falsification to authorities. ~]/~ ~ ,2004 HEATHER A. wICKARD HEATHER A. wICKARD~ Plaintiff TIMMY L. wICKARD~ Defendant : IN THE COURT CIF COMMON PL~--A--~ OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - I~AW : ~) ~ CIVIL TERM : NO. 03 - : IN DIVORCE ACCEPTANCE OF SERVICE I hereby certify that on ~¢--~¢~'~ ~2.7 , 2003, I received a certified copy of the divorce complaint filed in this action. .~-~, 2003 Timm~Wi'ckard Defendant HEATHER A. wICKARD, : IN THE COURT OF COMMON PLEAS OF Plaintiff TIMMY L. wIcKARD, Defendant : CUMBERLAND CouNTY, PENNSYLVANIA : CIVIL ACTION - ILAW : : NO. 03 - ~ ~!~ CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. \ .~~.~._, 2003 ~Timmy~;~i/~ckard, Defendant~ HEATHER A. WICKARD, Plaintiff TIMMY L. WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY~ PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2003 - 6553 CML TERM : IN DIVORCE WAIyE~ R~OF_NQTICE OF INTENTION TO RF. QUEST F. NTRY QF A_ DIVORCE DEC ~REE UNDER SECTION 3_301(C) OF THE~DIV~ORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, hwyer'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 verifythat the statements made in this affidavk are tree and correct. I understand that false statements herein are made subject to the penakies of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. ZtJ~\/ I ,2004 HEATHE.R A. WICKARD~ TIMMY L. WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CML ACTION - LAW : : NO. 2003 - 6553 CML TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about December 22, 2003 and served upon defendant on December 27, 2003 (see affidavit of service filed May28, 2004). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verifythat the statements made in this affidavit are true and correct. I understand that fake statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorfies. } ,2004 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF HEATHER A. WICKARD, Plaintiff TIMMY L. WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2003 - 6553 CIVIL TERM : IN DIVORCE 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) of the Divorce Code. 2. Date and manner of service of the complaint: On or about December 27, 2003, defendant through his counsel, who was served with a copy of the divorce complaint via regular first class mail, addressed to the counsel for defendant. (See Mfidavit of Service previously filed, May28, 2004.) o Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaint'df: May 28, 2004 Bythe defendant: July 1, 2004 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/& (b)(2) Date of Fding and service of the plahtiff's affidavit upon the defendant: N/A. 4. Related claims pending: None ,2004 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: N/A. (b) Date pla'mtiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: May 28, 2004. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with · e IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATF OF PENNA. Heather A. Wickard NO. 2003 6553 VERSUS Ttmmy L. Wickard DECREE IN DIVORCE AND NOW, July ~ Heather A. Wickard DECREED THAT Tm'uny L. Wick~ AND 2004 IT IS ORDERED AND , PLAINTIFF, , 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 ~ ATTEST: J.