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Home My WebLink About08-5970F:\DOCS\FL\DIV\Ickes.Steve - 3301(c) complaint & verification.wpd 4 ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEVEN P. ICKES, Plaintiff V. CAROL M. GMUENDER-ICKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. v CIVIL ACTION - LAW IN DIVORCE 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 at the Cumberland County Courthouse, Carlisle, PA 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. MidPenn Lectal Services 401 East Louther Street Suite 103 Carlisle, PA 17013 Telephone: (800) 822-5288 T ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEVEN P. ICKES, Plaintiff V. CAROL M. GMUENDER-ICKES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ??='?'I0 L? TGLw^ CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is STEVEN P. ICKES, an adult individual, who currently resides at 1113 Musket Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant in this action is CAROL M. GMUENDER-ICKES, an adult individual, who currently resides at 5 Campground Road, Dillsburg, York County, Pennsylvania 17019. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on September 9, 1995, in Camp Hill, 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 Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 1 7. The Plaintiff avers that three children, MIKALA MARIA ICKES, age nine (9), whose date of birth is June 11, 1999, SIDNEY ICKES, age four (4), whose date of birth is April 12, 2004, and PAIGE ICKES, age four (4), whose date of birth is April 12, 2004, all minor children, have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. STONE LaFAVER &/SHEKLETSKI By abe B Stone, Esquire ?pre C urt ID # 60251 414 r' ge Street, P.O. Box E mberland, PA 17070 Te phone 717-774-7435 torneys for Plaintiff V E R I F I C A T I O N STEVEN P. ICKES states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Z- A'?7 STEVEN P. ICKES Date: N ti C TI F:\DOCS\FL\DIV\Ickes.Steve - AFFIDAVIT OF SERVICE.wpd 'ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEVEN P. ICKES, Plaintiff V. CAROL M. GMUENDER-ICKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-05970 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the Defendant, Carol M. Gmunder-Ickes, at 5 Campground Road, Dillsburg, Pennsylvania, 17019, by United States certig,)ied mail, postage prepaid, restricted delivery, on October 15, ?Z 08, as evidenced by the attached certified mail return receipt./ Eli' eth B./S torney La SWORN TO AND SUBSCRIBED before me this 14th day July, 2009, /J / otarw-Danic EALTH OF tiLyfiNSYLVANI_A torX, Esquire JENNIFER A. MEARKLE, Notary Public dew Cumberland Boro. Cumberland Cc My Commission Expires July 7.2012 A. X 0 Agent Addressee B. Rwaivad by ( Printed Named C. Date of D Livery l?C(??cti Id" IsJ'O? ` D. Is deifwry addmax difftat from item 1? 0 Yee If YES, enter delivery address below. 0 No 3. Service Type 8 Cerww M" 0 Egress Malt 0 Registered ¦ Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? Pft Fee) 0 Yee 2. ArticleftmowmL g i ?p$ 2150 0002 5290 0702 Ps Form 3811, February 2004 Domestic Return Receipt 102595.02-M-1540 ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Dellwy Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailplece, or on the front If space permits. 1. Article Addressed to: Mrs. Carol M. Gmuender-Ickasf;'. 5 Campground Road Nk. Dillsburg., PA 17019; O TjF tr ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEVEN P. ICKES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-05970 CAROL M. GMUENDER-ICKES, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301 (c) of the Divorce Code was filed on October 6, 2008. 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 in 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. B , Date: ?? STEVEN P. ICKES, Plaintiff All l"i 2 ,09 c;"' 28 P"i ! ? .,;-.-; ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF STEVEN P. ICKES, Plaintiff V. CAROL M. GMUENDER-ICKES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-05970 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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. ?-^ By. Date: ?j TEVEN P. ICKES, Plaintiff Il.??'ri' ; "}•'? ? "?f 2 ,09 SE,' 28 { " '• 17