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HomeMy WebLinkAbout09-87754b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Bryan John Sicklinger Plaintiff VS. Kirby Paulette Sicklinger Defendant 0.0, a -r* . No. 09 - 8'15 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 in divorce or annulment may be 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 the custody or visitation rights 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 at the Franklin County Courthouse, Chambersburg, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOUR CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Bryan John Sicklinger Plaintiff VS. Kirby Paulette Sicklinger Defendant COMPLAINT UNDER SECTION 3301 OF DIVORCE CODE 1. Plaintiff is Bryan John Sicklinger, an individual, who currently resides at 216 Ridge Avenue, Shippensburg, Cumberland County, Pennsylvania, since January 5, 2007. . No. Civil Action - Law In Divorce 2. Defendant is Kirby Paulette Sicklinger who currently resides at 216 Ridge Avenue, Shippensburg, Cumberland County, Pennsylvania, since January 5, 2007. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on May 26, 1995 at Philadelphia, Pennsylvania. w 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievable broken. 7. 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. 8. Plaintiff request the Court to enter a decree of divorce. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 Ah. VERIFICATION 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. ?n Date: ;0,&7 Bryn John Sicklinger 17 717 » ` ti "11 °,RY 1 .1 ?ii6'1 Qr;, 21 Pi'i ')'= 48 s35a . c o PA A-mq cx; amag&!s oaf ao13q asaa(oS t3a8'1 e a553a.5 TPE 17 IN THE COURT OF COMMON PLEAS 2010 JAPE 14 P« 3: 19 OF CUMBERLAND COUNTY - PENNSYLVANIA Bryan John Sicklinger : No. 09-8775 Civil Term Plaintiff : Civil Action - Law VS. In Divorce Kirby Paulette Sicklinger Defendant AFFIDAVIT OF SERVICE N g I O O M L-j 03 W 0 0 0 O Ln 0 X7 0 ON O C3 -i H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Kirby Paulette Sicklinger, of 216 Ridge Avenue, Shippensburg, Pennsylvania, 17257 by certified mail and was accepted on delivery by Kirby Paulette Sicklinger, on December 30, 2009. I ?sL 0 >8 ]F=0 -b ? 3 H. Anthony Adams, Esquire 5 116 t Attorney for Plaintiff N 0 0 49 W. Orange Street, Suite 3 6 s ' a, m 0 Shippensburg, PA 17257 0 0 0 0 ° _ 1 (717)-532-3270 c...=, I C . D A W C /D w C1 (D 3 m ?a? O m a 0 3 ? m d. v' 3 v ? y M C CD ma L a ? a N N a CL ? N v 3 CD I CD IOD m M N N NO_ N O. 3 Ir 4 Ca rN ;Oay3 COL =O D M O CD -< ° m y w c ' 3 (D. m co iD 0 (D m Sworn to and subscribed this , 201 day of CUUDAI Notary Public My Commission Expire . x n Cn COMMONWEALTH Ot PENNSYLVANIA NOTARIAL SEAL Z MICHELE R. DUR1F, Notary Public g Boro of Shippensburg, Cumberland County r ^ My Commiswon Expires July 16, 2012 m m 0 a ? ? r RCD? ? ? F Of \ a ceD rid ~l ,: r .T-~ r IN THE COURT OF COMMON PLEAS ;'~ ; _ `~'~`~~ O CUMBERLAND COUNTY -PENNSYLVANIA L~10 Ji~~_ I v ~ ~ 4 ~ ~~.~ ,4~ Bryan John Sickling r : No. 2009-08775 Ci~r~~ `.-m , ,; ~ ,,~ Plaintiff :Civil Action -Law vs. In Divorce Kirby Paulette Sickli~ger Defendant i . PRAECIPE TO TRANSMIT RECORD TO THE PROTHONCDTARY: Transmit thel,record, together with the following information, to the court for entry of a divorde decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. ~ 2. Date and mann r of service of the complaint: Service was made by Certified Mail Return Re eipt Requested on December 29, 2009 and received by Defendant of D cember 30, 2009. An affidavit of Service was filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Coe; by the Plaintiff July 12, 2010; by Defendant ]uly 7, 2010. 4. Relating claims pending: None i 5. Plaintiff's Waiv ~r of Notice was signed on July 12, 2010 and is filed herewith and Defendant Waiver of Notice was signed July 7, 2010 and is filed herewith. i H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 `.~~ TI -'r ~~ ~ ~~~r ,, 2~"i0 .~.±~ ~ ~S Ili Y ~ ~ vu IN THE COURT OF COMMON PLEAS Ct,~~` -~ ` ~~'~'~~ F CUMBERLAND COUNTY -PENNSYLVANIA a~~~-- c~~77~ Bryan ]ohn Sickling r : No. 68~3#}- Plaintiff :Civil Action -Law vs. '' , In Divorce Kirby Paulette Sickliinger , Defendant ' _ AFFIDAVIT OF CONSENT 1. A Compla nt in Divorce under Section 3301(c) of the Divorce Code was filed on D cember 21, 2009. 2. The marri ge of Plaintiff and Defendant is irretrievably broken and ninety da s have elapsed from the date of filing of the Complaint and service o Defendant. 3. I consent Ito the entry of the final decree of divorce after service of notice of i~htention to request entry of the decree. I verify that understand that fa Pa. C.S. Section 49 Date: ?" 7- ~ statements made in this affidavit are true and correct. I statements herein are made subject to the penalties of 18 relating to unsworn falsification to authorities. ~~ ' y Paulett Sicklin er ~~`~~° 9 ~~~li G ~ ,, ~~~ ,t'L IN THE COURT OF COMMON PLEAS (~F CUMBERLAND COUNTY - PENNSYLVANIAZ~ l ~ .~' L E 6 fP'~~ ~' l ~ `~ Bryan John Sicklin er : No. ~8-~'~9 ~+z 1 2010 Plaintiff Civil Action -Law vs. In Divorce Kirby Paulette Sickl nger Defendant WA VER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I underst nd 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 unders nd that I will not be divorced until a divorce decree is entered b the Court and that a copy of the decree will be sent to me immediat ly after it is filed with the Prothonotary. I verify that the understand that 18 Pa. C.S. Secti~ Date: 7' 7 - `o ~tements made in this affidavit are true and correct. I Ise statements herein are made subject to the penalties of i 4904 relating to unsworn falsification to authorities. ~~-E~, Ki y Pau tte Sicklinger Defendant IN THE COURT OF COMMON PLEAS F CUMBERLAND COUNTY -PENNSYLVANIA oQ- ~~~~~ Bryan John Sicklin er : No. (~8-~3~9 Plaintiff VS. Kirby Paulette Sickinger Defendant :Civil Action -Law In Divorce AFFIDAVIT OF CONSENT cn ^~ -- ~- ~.~ . ~; ~ ` ' r ~ ---- , ~-~ ' t'`:t _ == ~~' ~ ~ ~ :: 1. A Compla nt in Divorce under Section 3301(c) of the Divorce Code was filed on cember 21, 2009. 2. The marri ge of Plaintiff and Defendant is irretrievably broken and ninety da s have elapsed from the date of filing of the Complaint and service o Defendant. 3. I consent Ito the entry of the final decree of divorce after service of notice of i tention to request entry of the decree. I verify that t e statements made in this affidavit are true and correct. I understand that fals statements herein are made subject to the penalties of 18 Pa. C.S. Section 490 relating to unsworn falsification to authorities. V Date: ~ a ~ ~ Bryan Joh Sickling ~~~G~~ I~ IN THE COURT OF COMMON PLEAS ±~`'" Tk `" ` '~"~ ~ ~~ , ~s~?~~{ F CUMBERLAND COUNTY -PENNSYLVANIA ZQ14 ~~` I ~ ~'r C ~ ~` v p r3 7 7~ ~ ~~ j _ ;s,~~ ~1- C~r1 ,1 r,~ Bryan John Sicklin er : No. (j8-~3.1~4--~ t ~ _ '` 5 ~" ~~. ,'t Plaintiff Civil Action -Law vs. ~ In Divorce Kirby Paulette Sickl~nger Defendant '. WA VER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ECTION 3301(c) OF THE DIVORCE CODE 1. I consents to the entry of a final decree of divorce without notice. 2. I underst nd 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 unders nd that I will not be divorced until a divorce decree is entered b the Court and that a copy of the decree will be sent to me immediat ly after it is filed with the Prothonotary. I verify that the tatements made in this affidavit are true and correct. I understand that alse statements herein are made subject to the penalties of 18 Pa. C.S. Secti n 4904 relating to unsworn falsification to authorities. Date:~~~~ /~ ~ Bryan ohn Si linger Plaintiff Bryan John Sickl~nger V. Kirby Paulette Si~klinger IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-08775 NO. DIVORCE DECREE AND NOV1~ Bryan John Sickli Kirby Paulette / °~~ ~d l ~ , it is ordered and decreed that ger plaintiff. and finger bonds of matrimony. defendant, are divorced from the Any existin~ spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court r tains jurisdiction of any claims raised by the parties to this action for which a final o der has not yet been entered. Those claims are as follows: (If no claims remain indi ate "None.") None By the Court, Attest' _ / J. `J P `] , ~O , ~ b l~.'c' ' cam. t~(~IIc.:~ ~Q. C~ -b aa~