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Home My WebLink About08-6536SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 0 - ivi I (erm RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 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, One Courthouse Square, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 Susan V. Kade , Esquire. Attorney for Plaintiff SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 0 F- 4!' 3 4 RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Susan E. Cook, who currently resides at 1124 Columbus Avenue, Apartment 7, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant is Rodney L. Cook, who currently resides at 37-A North Lincoln Street, Palmyra, Lebanon County, Pennsylvania 17078. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 9, 2008, in Lemoyne, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. The parties to this action have been separated since on or about September 10, 2008. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. This action is not collusive. WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: By: Susan M. Kadel Attorney I.D. #44837 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff Susan E. Cook VERIFICATION I, Susan E. Cook, verify that the statements made in this Petition 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 unworn falsification to authorities. Date: l O/q '? / 0 2) iusan E. Cook (? OnA J 00 ?, 0 J W O C' 7 r a.> J - 4 / CD / Alip -r- -r? (7-3 ZLI `? K SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. OR - 405310 0'i Vi ni f RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, hereby elects to retake and hereafter use her former name of Susan E. Afflebach and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S.A. § 704(a). DATED: p7 ?? e Susan E. Cook TO BE KNOWN AS "VU Susan E. Aillebach Sworn to and subscribed before me this day of b??- 2008. W NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. LaRue, Notary Public Derry Twp., Dauphin County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries -{µ ci rv .r .. S ` t - um ko °? f SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-6536 RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DAUPHIN ss. AND NOW, this 2-?day of November, 2008, personally appeared before me, a Notary Public in and for the State and County aforementioned, Susan M. Kadel, Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce was served on the Defendant, Rodney L. Cook, on November 8, 2008, by certified mail number 7008 1300 0001 8216 9828, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. Susan M. Kadel, Esquire Sworn to and subscribed before me this 0 day of? , 2008. 41?tot Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. LaRue, Notary Public Derry Up., Dauphin County My Commission Expires Nov. 8, 2009 Member, Pennsvivania Assoc Edon of Notaries - a ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery 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 mailpiece, or on the front if space permits. 1. Article Addressed to: 17aZP A. El Addre. B. vbd by (Printed Name) C. Date of Delivery el- ?i-F-< ? D. Is delivery address different from item 1? ? Yss If YES, enter delivery address below: o 3. Type tied mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7008 1300 0001 8216 9828 mansibr Aym "Mae label) PS Form 3811, February 2004 DomesUc Return Receipt 102595-02401-1540 f°; ?. §j (')'?, -?' .. ?. .cw ?' ` f...._ '-i'3 SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-6536 RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 4, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. I understand that 1 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. (f` 6-4., n/K cL, Date: I' 091a y , Lei, Susan E. Cook, Plaintiff; Susan E. Afflebach 3 CJ ^, SUSAN E. COOK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-6536 RODNEY L. COOK, : CIVIL ACTION - LAW Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 4, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: V1-310 7 !?2 C..., Rodney L. Cook, Defendant I-al -q-3 -?lE qty ?? .r SUSAN E. COOK, n/k/a, SUSAN E. AFFLEBACH, Plaintiff V. RODNEY L. COOK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6536 CIVIL ACTION - LAW 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 (XX) 3301(c) ( ) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: November 8, 2008; by restricted, certified mail number 7008 1300 0001 8216 9828. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: by Plaintiff. February 19, 2009; by Defendant: February 13, 2009. (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None r 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff: February 19, 2009; by Defendant: February 13, 2009. and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce Decree: Both Plaintiff's and Defendant's Waivers are being filed simultaneously with this Praecipe. JAMES, SMITH, DIETTERICK & CONNELLY, LLP Date: February 19, 2009 Susan M. Kadel, Esquire Attorney for Plaintiff Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 44837 C-n Ch7 f Susan E. Cook,n/k/a, Susan E. Afflebach V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Rodney L. Cook NO 2008-6536 DIVORCE DECREE AND NOW, Ce ? Zy 2 0 0 9 , it is ordered and decreed that Susan E. Cook, n/k/a, Susan E. Afflebac$laintiff, and Rodney L. Cook , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, ??? °_ A`: ?s, 1? 7