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HomeMy WebLinkAbout04-1886 ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. STRICKLAND, Defendant NO. 2003 -11?f.:. CIVIL TERM 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 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Court House, Carlisle, Pemlsylvania. 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 lLAWYER 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 LAW OFFICES OF PETER J. RUSSO, P.C. The Chelsea Building 3800 Market Street Camp Hill, PA l7011 (717) 591-1755 Attorney for Plaintiff ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. STRICKLAND, Defendant NO. 2003 - U'Jt,. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named PlaintiJIby and through the Law Offices of Peter J. Russo, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 2119 Susquehanna Avenue, Enola, Cumberland County, Pellllsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 219 Susquehanna Avenue, Enola, Cumberland County, Pellllsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 41 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pellllsylvania for 33 years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on October 13, 1990 in Dauphin County Pellllsylvania. 6. There are two children of the parties under the age of eighteen (18): Eric L. Strickland Cody 1. Strickland July 30, 1991 December 2, 1992 COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8. There has been no prior action for divorce by either party against the other. 9. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. 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, but does not request the same. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant Section 3301 of the Divorce Code. COUNT 11- CUSTODY 13. Plaintiff hereby incorporates by reference averments 1 through 11 of this Complaint as if each averment were set forth fiIily hereunder. 14. Plaintiff is Alice F. Strickland residing at 219 Susquehanna Avenue, Enola, Cumberland County, Pemlsylvania. 15. Defendant is Eric D. Strickland residing at 219 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania. 16. Plaintiff seeks custody of the following children: Name Eric L. Strickland Present Residence 219 Susquehanna Avenue, Enola, P A 17025 DOD July 30, 1991 Cody D. Strickland 219 Susquehanna Avenue, Enola, P A 17025 Dec. 2,1992 17. The children were not born out of wedlock. 18. The children are presently in the custody of the Plaintiff and Defendant, who reside at, 219 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania. 19. In the last five years the children have resided Witll the following persons and at the following address: Persons Plaintiff & Defendant Plaintiff Plaintiff & Defendant Address Carlisle, P A Harrisburg, P A 219 Susquehanna Ave., Enola, PA Duration Mar. 1999 to June 2000 June 2000 to Oct. 2000 Oct. 2000 to Present 20. The Plaintiff, the mother of the children, is Ali<:e F. Strickland, residing at 219 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania. She is married. 21. The Plaintiff currently resides with the following plJrSons: Name Eric D. Strickland Eric L. Strickland Cody J. Strickland Relationshio Spouse Son Son 22. The Defendant, the father of the children, is Eric D. Strickland, residing at 219 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania. He is married. 23. The Defendant currently resides with the following persons: Name Alice F. Strickland Eric L. Strickland Cody J. Strickland Relationship Spouse Son Son 24. Plaintiff has not participated as a party or witIless, or in another capacity, in other litigation concerning the custody of the children in this or anoth,~r court. 25. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 26. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation right with respect to the children. 27. The best interest and permanent welfare of the children will be served by placing joint legal and primary physical custody of the subject children with Plaintiff and giving Defendant partial physical custody because the children have resided with their mother all their lives and at the present time, she is best able to provide a stable home life. WHEREFORE, Plaintiff requests this Honorable Court to order that joint legal and primary physical custody of the subject children be placed with Plaintiff and that Defendant receive partial physical custody. Date: '1/'0(0 '1 Respectfully submitted, Law Offices of Peter J. Russo, P.c. By: 4~u Ilr~ Scott A. Stein, Esquire Attorney for Plaintiff ID No. 81738 LAW OFFICES OF PETER J. RUSSO, P.c. The Chelsea Building 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney for Plaintiff ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. STRICKLAND, Defendant NO. 2003- IN DIVORCE CIVIL TERM VERIFICATION I, Alice F. Strickland, verifY that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 P.C.S. 14904 rewmgto -= ","."tioo '" OO~ti~. C '0~ Date: 64- \D-OY J~lir) ~ '"~ Alice F. Strickland ~\ " :i ~ iN w , ~ 9 ~~ a 0 ~ () 0 ff <> c-: ~T -,,; :3" ~CJ ;;; ~:.~< ::J>.c' z :< w w ..., ~ ~ ~;~ @ 3: 9 :iJ ~ olrl ~ ~ ALICE F. STRICKLAND PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 04-1886 CIVIL ACTION LAW ERIC D. STRICKLAND DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, May 11, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _ Dawn S. Sunday, Esq. _, the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, June 01, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or per\nanent order. The court hereby directs the parties to furnish any and all existin~: Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT, By: Isl Dawn S. Sunday, Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ p ~ ,?"Pt?~"" 4-kJ /Jf?'/J.? .~ ~ ~ ~u./;(/'//F ~ P 7- ~ ~.l T7J/?f?//.,f' VihNI\~VE:i\1r"J:jd I 'N'lr....\ r". ;'. F-"- """~'\!"'" IU I ;\j\,) I, 'I ~. ti,:':!tiV'~I1C) 60:~ l.ld II .l.V\,P100Z AUv'lONOH10CJd 3Hl :10 38l:klO:031l:! v- JUN 2 9 2004 ALICE F. STRICKLAND Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-1886 CNIL ACTION LAW ERIC D. STRICKLAND Defendant IN CUSTODY ORDER OF COURT AND NOW, this r;. ~ day of ~'t1l ' 2004, upon consideration ofthe attached Custody Conciliation Repod, it i ordered and directed as follows: 1. The Mother, Alice F. Strickland, and the Father, Eric D. Strickland, shall have shared legal custody of Eric L. Strickland, born July 30,1991, and Cody J. Slrickland, born December 2,1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuarlt to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody ofth~: Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 7:00 p.m. through Sunday at 7:00 p.m., begilllling Friday June 18,2004. In addition, the Father shall have custody of the Children every Thursday during the school year from 3:00 p.m. until 9:00 p.m. and during the summer school break from 5:00 p.m. through 12:00 midnight. 4. The parties shall have custody of the Children on holidays as follows: A. ChristInas: The ChristInas holiday shall be divided into Segment A, which shall run from ChristInas Eve at 12:00 noon through ChristInas Day at 12:00 noon, and Segment B, which shall run from ChristInas Day at 12:00 noon through Dec,ember 26 at 12:00 noon. The Mother shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall havll custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. The parties shall share having custody ofthe Children during the remainder ofthe holiday school break as arranged by agreement. B. Thanksgiving: The parties shall have custody of the Children on Thanksgiving in accordance with the regular custody schedule under which the Mother has custody ofthe Children on Thursdays until 3:00 p.m. and the Father has custody from 3:00 p.m. until 9:00 p.m. In the , ViNWIl,i.SNN3d I I "nn~ ,"" '1' "'-'''1'"' I\.Lj\t \..)..) urf\,J It~:JtJ,.! v 62 :21 Wd 9- lnr ~ooz ).HiflONOHlOod 3Hl :10 38t~:iO-0311:1 event the Father's regular weekend period of custody faills immediately following Thanksgiving, the Father's periods of holiday and weekend custody shall run continuously without interruption. C. Father's Day: The Father shall have custody of the Children every year on Father's Day from 9;00 a.m. until 7;00 p.m. D. Remaining holidays: For Easter, New Year's, Mother's Day, Memorial Day, July 4th and Labor Day, the parties shall either follow the regular custody schedule or establish special arrangements by agreement. E. The holiday custody schedule shall supercede and tak~: precedence over the regular custody schedule. 5. Each party shall be entitled to have uninterrupted periods of custody during the sununer school break each year for two non-consecutive (unless agreed otherwise) weeks. Each party shall schedule periods of custody under this provision to include that party's regular weekend period of custody. Each party shall provide at least two weeks advance notice to the other party of his or her selection of vacation dates under this provision. The party providing notice first shall be entitled to preference on his or her selection of vacation dates. 6. Each party shall notify the other promptly of any emergency medical care provided to either Child or the Children during his or her periods of custody. 7. Unless otherwise agreed between the parties, the party receiving custody shall provide transportation for the exchange of custody, with the exception of Thursday evening periods for which the Father shall provide all transportation. 8. The parties agree that while the Father's roommate remains on probation, either the roommate shall not be present in the Father's residence or otherwise have contact with the Children when the Father has custody or the Father shall provide verification from the roommate's probation officer that the roommate is undergoing regular random drug testing and is in compliance with all conditions of her probation. 9. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 10. This Order is entered pursuant to an agreement ofth,e parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, I .... /1~ J. cc: Scott A. Stein, Esquire - Counsel for Mother , Joseph D. Caraciolo, Esquire - Counsel for Father ~(.? ~ '7 -tJt. . b'l C)-, ALICE F. STRICKLAND Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERI"AND COUNTY, PENNSYL VANIA vs. 04-1886 CNIL ACTION LAW ERIC D. STRICKLAND Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAN][) COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the fOllowing report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Eric L. Strickland Cody J. Strickland July 30, 1991 December 2, 1992 Mother Mother 2. A conciliation conference was held on June 16, 2004" with the fOllowing individuals in attendance: The Mother, Alice F. Strickland, with her counsel, Scott A. Stein, Esquire, and the Father, Eric D. Strickland, with his counsel, Joseph D. Caraciolo, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ ,.,) ~~ ckJcl<( Date t2~~ o~ Dawn S. Sunday, Esquire Custody Conciliator ,. i r LAW OFFICES OF PETER J. RUSSO, P.c. The Chelsea Building 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 Attorney for Plaintiff ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. STRICKLAND, Defendant NO. 2004 -1886 IN DIVORCE CIVIL TERM PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT AND NOW, COMES, Scott A. Stein, Attorney for PlaintitI, Alice F. Strickland, and certifies that on April 24. 2004 , he did serve the Defendant, Eric D. Strickland with a true and correct copy of the Divorce Complaint filed against him alleging the parties' marriage was irretrievably broken under Section 330l(d) and Section 330l(c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope sent by certified mail, restrictcd delivery, return receipt requested and addressed to Eric D. Strickland at 219 Susquehanna Avenue, Enola, Pennsylvania 17025. ~ Service of Plaintiffs Complaint on the Defendant, Eric D. Strickland was affected on April 29. 2004 . A true and correct copy of the U.S. Postal Service Return Receipt is attached hereto and the original is affixed to the reverse of this document. [ ] Service of Plaintiffs Complaint on the Defendant, Eric D. Strickland was effected on_ . A true and correct copy of Defendant's Acknowledgment of Service is attached hereto and the original is affixed to this document. Date: 1/;;''5/0(, .. .' . Complete Items 1. 2, and 3. Also complete Item 4 W ResIrtcled DeIlvery Is desired. . PrInt-your name and addlllSS on the I8V8I88 so that we can I8lum the card to you_ . Allach this card to the back of the mallplece, or on the front W space permits. 1~ Artk:Ie Addressed to: Ert"v 0- S+nc'/:'I~f1d ~ , 'I SVJ1r.JfAQl1nc.. 41ft,. l::.,.,,,!fIt J 1'11 ItOlS Agent _.-eo -1;Iy(~Name) Cl..~ \). :::>\-c'C."-"'- D. Iodollv8ry__from Item 1 lJ Yes W YES, enter deIIv8I)' address below: lJ No 3. _1)pe J1( CerIIlIod Moll lJ Expooo MaU lJ Reg-.cl lJ Return ReceIplIor MercI18ndI8e lJ _ MeII lJ O.O.D. 4. Rbdbk.llod D8IIvIlry? (&tnIFee) 7002 2410 0004 1005 0439 'DOol1MtIo Re\um ~ 1025l16-02-M-1540 2. _Nu_ (IIBt&w--~ PS Fonn3a1'1,Aligulit'2001 ~J c: " , ~.. c< ~ 'S>-l -0 '-1;.-\ r"f'\", if, r;~> , . -~~\.> ~i% y,,?, (,'j C.J -:-;~~ ;"\'"- f:- "'(" 'i~' ~-\~S:, - , ::/- ""-')- ~ ton , _\ ?5: ..- .' ,1"", c.' - ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. STRICKLAND, Defendant NO. 2004 - 1886 IN DIVORCE CIVIL TERM PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 28, 2004. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if! do not claim them before a divorce is granted. 5. I understand that I wi 11 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's Office. 6. [have been advised ofthe availability ofmaniage counseling and understand that [ may request that the court require that my spouse and I participate in counseling. 1 understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Alice F. Strickland, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. [ 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. / ~ Lc ( ~ /-<, / ( ,oJ '0-' / t: (., . .) ll?:;?' 17 (11: / 1,'" . Alice F. Strick and I 'J (C- '- ..<... '> . f") / '--- (c-.J DATE o ',f. ""'(."/(;- fT1f1 -.7 -~ z( en " 2:_1 ~.t_ 'z-, =< ,..., = c;..-'> <>"' <- ;po "$ "" o -0 -t'" _~l" o -n %::n S ~o /'c- ':;~i~ C)C-~l r~:::)r-n ....'. :'c;: ~ <.11 Cf) - ------- ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ERIC D. STRICKLAND, Defendant NO. 2004 - 1886 IN DIVORCE CIVIL TERM DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on April 28, 2004. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service ofthe Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses in do not claim them before a divorce is granted. 5. 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's Office. 6. 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. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Eric D. Strickland, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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. 94904 relating to unsworn falsification to Authorities. 1/;;"'.7)0(, I I DATE 0- (), ~-----~ Eric D. Strickland "' --- ~ C? Cc <.:.- '"\1~~ '1'\ ~ \-,j'.). "";;:;:>, ';;i. ~ <- ~ <6 ~~~,\ 'p.': ;::';:(:-. :i- ".>\ .--<. t;f\ -0 ::J:C ..-\ ~:D ?fir-: 'rrJ "",,,;: -:-:'0" '~)l"" ~~.~~ 6')' "". ~ ~~ :~ --' .' {J' c:> - LAW OFFICES OF PETER J. RUSSO, P.c. PETER J. RUSSO, ESQUIRE PA Supreme Court ill: 72897 SCOTT A. STEIN, ESQUIRE 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorneys for Plaintiff ALICE F. STRICKLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW ERIC D_ STRICKLAND, Defendant NO. 2004 - 1886 IN DIVORCE CIVIL TERM 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: Complaint served on Eric D. Strickland by Certified Mail, Restricted Delivery with return receipt on April 29. 2004 . 3. the Divorce Code: Date of execution of the plaintiffs affidavit required by Section 3301(c) of January 25,2006 Date of service of plaintiffs affidavit on defendant: Januarv 27,2006 the Divorce Code: Date of execution of the defendant's affidavit required by Section 3301(c) of January 27.2006 4. Related claims pending: None Date: I tn /0[, Respectfully submitted, _~[J~~~/ Scott A. Stein' - o ~i 'net:: r1'1r,n. ~;.. " ~, /. U' -<, . ,..., = c".) "'~ <- :P" Z W C> :7 -;;,- ..., ::Il: ~ ~-n Pl~ ~c:) (~j (-J ~::::l.-, , t~~ L~; ;\rt"l ~-i;~ 'D '-<. cJ' CP ?~~~~+~~~~~~~~~+ +~+~+ +~~+~++~~~~~++++~+ ~+++++~+~~~+~~++:~+ ++++:++:++~+~++++~~ , , : IN THE COURT OF COMMON PLEAS : . , : OFCUMBERLANDCOUNTY : + + + , + + + + + STATE OF PENNA. + + + + + + + + + + + . + , + + + + . . . . . . + . . + . . . . + . + . . . . . . . . . + . . . . + AIICF F ~TRI~K:l4.ND, 2004 - 1886 Plaintiff No. VERSUS ERIC n STRI~I{I ANn, Defendant DECREE IN DIVORCE f-..,,) ALICE F. STRICKLAND AND NOW, JI , ~O~, iT is ORDERED AND DECREED THAT , PLAiNTiFF, ERIC D. STRICKLAND AND , 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; ;.JON€. By THE COUR;g ~. 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