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HomeMy WebLinkAbout01-6878SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW : IN DIVORCE NI3TICF. TO Bl~.l~EN33 AND CI ,AIM RIGI-IT~ 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 Cumberland County Courthouse, 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 2 Liberty Avenue Carlisle, Pennsylvania (717) 249-3166 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 SUSAN C. LISKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : VS. : CIVIL ACTION - LAW LARRYL. LISKEY, JR., : NO. O1-- /,~,c"700 ~'gt'o~~ Defendant : IN DIVORCE COMpT,AINTT T ]~,t'DI~,R .~I~,CTION qqO1 (e) OR 3'~01 O1~ THF DtVORCF CODI~ The Plaintiff and Pennsylvania. Plaintiff is SUSAN C. LISKEY, who currently resides at 716 Allendale Road, Mechanicsburg, Cumberland County, Pennsylvania, since August, 1997. 2. Defendant is LARRY L. LISKEY, JR., who currently resides at 716 Allendale Road, Mechanicsburg, Cumberland County, Pennsylvania, since August, 1997. 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. Defendant were married on April 22, 1995 at Mechanicsburg, There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 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. Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: Sfxsan C. Li~key, Plaintiff /~ 1Anl 3th;nmYntL~ Dtree~a, [~squi~ - P.O. Box 358 Boiling Springs, Pennsylvania 17007 (717) 258-6844 Attorney for Plaintiff 0 SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 6878 CIVIL TERM 2001 AI~FIDAVIT OF MAll .lNG COMMONWEALTH OF PENNSYLVANIA: · SS. COUNTY OF CUMBERLAND : Anthony L. DeLuca, attomey for Plaintiff, being duly sworn according to law, says that he mailed by certified mail, return receipt requested, a tree and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Defendant at 716 Allendale Road, Mechanicsburg, Pennsylvarfia and that Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A". Sworn to and subscribed before me this/4 attlay of t~ff,~Z~ , 2002. NOTARIAL SEAL UAFUOFIIE A. DeLUCA, Notan/Public Sou~ Middleton Twp., Cumberland Co. . My ~ Expires Nov. 1, 2003 By: Anthony~eLuc~ E'squire 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 Resbicted Delivery? (Extra Fee) - 2 Art~ie_ Number {~opy from service labe/)~ . ~.~ <~. ~- /_. ~_ ~ /~ PS F~3811, Ju~ 1~ ~ic R~urn R~pt 102595-00-M-0952 SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6878 Civil Term IN DIVORCE AFI~I13AVIT OF C. CIN,qF, NIT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on December 4, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce af[er 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 h~rein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-6878 Civil Temi : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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 conceming alimony, division of property, lawyer's fees or expenses ifI 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: S~san C. Liskey, Plaintiff SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01-6878 Civil Term : IN DIVORCE AFFIDAVIT OF C(3NRENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on December 4, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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. I verify that 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. § 4904 relating to unswom falsification to authorities. Date: SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6878 Civil Term IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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 ifI 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 unswom falsification to authorities. Date: ~ L. Li~cey, J;., Defendant' // ' SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-6878Civil Term : : IN DIVORCE .' STIPI N .ATION WHEREAS, the parties have reached an agreement as to the custody and visitation of the children bom to the parties, LUKE L. LISKEY, CHRISTOPHER J. LISKEY and MATTHEW T. LISKEY, and wish a court order to reflect that agreement; THEREFORE, with due consideration for the welfare of said children both parties, hereby agree as follows to wit: I. Majority Custody of said children, LUKE L. LISKEY, CHRISTOPHER J. LISKEY and MATTHEW T. LISKEY, and visitation of said children shall be detcmfined by an agreement executed by the parties hereto, attached hereto as Exhibit "A", and made a part hereof and incorporated herein by reference. 2. It is contemplated and requested by the parties hereto that this agreement be adopted by Order of Court. WITNESS: Susan C. Liske~ f "~t'rY L- JTi~k~'y, :Ir. //'' I C~T TgTOD¥ ACtRg, I:(.MRNT THIS AGREEMENT, made this ,.~t~ day of April, 2002, by and between SUSAN C. LISKEY of 716 Allendale Road, Mechanicsburg, Cumberland County, Pennsylvania and LARRY L. LISKEY, JR., of 5169 East Trindle Road, Lot #1, Mechanicsburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties were married on April 22, 1995, in Mechanicsburg, Cumberland County, Pennsylvania; and WHEREAS: Three (3) children were bom of this marriage, namely LUKE L. LISKEY, bom on June 24, 1996, CHRISTOPHER J. LISKEY, bom on July 26, 1997 and MATTHEW T. LISKEY, bom on June 3, 1999; and WHEREAS, the parties have reached an agreement with regard to custody and visitation of said children, LUKE L. LISKEY, CHRISTOPHER J. LISKEY and MATTHEW T. LISKEY; NOW THEREFORE, in consideration of the mutual covenants herein made, as well as other good and valuable consideration, the receipt of which hereby is acknowledged, the parties hereto, intending legally to be bound hereby, do covenant and agree as follows: A. The custody of the aforesaid children, during minority, hereby is given to Wife, SUSAN C. LISKEY, except as otherwise may be provided by an appropriate court, having proper jurisdiction of the subject. B. The parties shall take all reasonable measures to foster a feeling of affection between themselves and the children. Neither party shall do anything to hamper or impair the children's love and respect for the other party. C. LARRY L. LISKEY, JR. shall have the fight of reasonable visitation of said children, as mutually may be agreed upon by the parties. In the event the parties are unable to agree upon visitation, LARRY L. LISKEY, JR., shall have the right of visitation every other weekend, commencing at 6 o'clock P.M. on Friday and ending at 6 o'clock P.M. on Sunday. With respect to the major holidays consisting of New Year's Day, Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. LARRY L. LISKEY, JR. shall have the right of visitation every other major holiday. With respect to Christmas, the parties shall divide the Christmas holiday with one party having visitation from 12:00 noon on December 24th to 12:00 noon on December 25th while the other party shall have visitation from noon on December 25th to noon on December 26th. Said visitation shall also be on an alternating basis commencing with Christmas of 2002. D. LARRY L. LISKEY, JR. shall notify SUSAN C. LISKEY, not less than 24 hours in advance, of any change in plan to exercise such visitation rights. E. It shall be the responsibility of each parent to keep the other advised of the address where the children will be living and of any medical emergencies concerning the children. F. SUSAN C. LISKEY and LARRY L. LISKEY, JR. agree that in making this agreement there has been no fraud, concealment, over-reaching, imposition, coercion, or other unfair dealing on the part of the other. G. SUSAN C. LISKEY and LARRY L. LISKEY, JR. hereby agree and therefore stipulate that it is their intent and request that the Court of Common Pleas of Cumberland County, Pennsylvania adopt this agreement as a decree and Order of Court. IN WITNESS WHEREOF, the parties hereto have executed this the day and year first above written. WITNESS: 6~usan C. Li's~ey ~'~a~ L. L)s/k~y, Jr. ' // ' SUSAN C. LISKEY, LARRY L. LIS~EY, Plaintiff VS. JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 6878 2001 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: requested signed December 11, Ground for divorce: Irretrievable breakdown under §3301 (c) 3~:(~](d~[ of the Divorce Code. (Strike out inapplicable section). Date and manner of service of the complaint: Certified mail return receipt 2001. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff April 5, 2002 ; by defendant Apri'l 5, 2002 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: NONE 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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ~ /¢'. ~o ,, ~.. Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: A y for Plaintiff IN tHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. SUSAN C. LISKEY ................................................. P-~a~n~if-f .............. Versus LARRY L. LISKEY, JR. Defendant DECREE IN DIVORCE decreed that ...~.u.~.~.n..c.,. ~j.~.~;~y .............................. plaintiff, and · .. [,~.z:r¥. ~,. Li~ke~,.,..Jr ................................ 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 SUSAN C. LISKEY, Plaintiff VS. LARRY L. LISKEY, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. : IN CUSTODY ORDF. R AND NOW, to wit, this ~Z',~ day of ~ld I 2002, the Court adopts the agreement of the parties concerning the custody and visitation of the ckildren, LUKE L. LISKEY, CHRISTOPHER J. LISKEY and MATTHEW T. LISKEY, as the Court's own order. A copy of that agreement is attached hereto and made a part hereof as fully as if entered specifically by the Court. We direct that a copy of this order be furnished to both parties. Jo