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Home My WebLink About04-2619FATIMA A. SKIMIN : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : No. 0% : ROBERT E. SKIMIN : CIVIL TERM DEFENDANT : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish m defend against the chims 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 annulmem maybe entered against you bythe Court A Judgment maya]so 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 divorce is indignities or irretrievable breakdown of the marriage, you mayrequest man'iage counseling. A list of marriage counselors is available: Office of the Prothonotaxy Cumberland County Court House One Courthouse Square Carlisle, Pennsylvania 17013-3387 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYERS' FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CI.A. IM ANY OF THESE. 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 Li~Ry Avenue Carlisle, PA 17013-3387 717-249-3166 FATIMA A. SKIMIN : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA ; vs. .-No. ; ROBERT E. SKIMIN : CIVIL TERM DEFENDANT : IN DIVORCE COMPLAINT IN DIVORCE COUNT I AND NOW, comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows: 1. Plaintiff is Fatima A. Skimin, who currently resides at 442 Brook Circle, Mechanicsbum, Pennsylvania 17050. 2. Defendant is Robert E. Skimin, who currently resides at 3409 Craigo, E1 Paso, Texas 79904-1005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 11, 1998. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised of the availability of counseling and also the Plalntiffmay have the right to request that the Court require the parties to participate in counseling, and at~er being so advised, Plaintiffdoes not desire counseling. WHEREFORE: Plaintiffrequests the Court to Enter a Decree in Divorce. Respectfully submitted, DATE .,lttorney At Law Attorney I.D. No. 18727 352 S. Sporting Hill Rd. Mechanicsburg, PA 17050 (717) 737-2033 VERIFICATION I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein made are subject to penalties of 18 PA. C.S. §4904, relating to unswom falsification to authorities. ~ (PLAINTIFF) FATIMA A. SKIMIN : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA : Vs. : No. : ROBERT E. SKIMIN : CIVIL TERM DEFENDANT : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit with/n twenty days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 15, 1999, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irre~evably broken. 3. 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. 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 falsifications to authorities. ~ (PLA/INT~IN FATIMA A. SKIMIN : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA _. Vs. : No. : ROBERT E. SKIMIN : CIVIL TERM DEFENDANT : IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or Co): (a) I do not oppose the entry of a divorce decree. Co) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least three years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or Co): (a) I do not wish to make any claims for economic relief. 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. Co) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in the counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pm C.S. 4909 relating to unswom falsification to authorities. DATE: ROBERT E. SKIMIN NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. FATIMA A. 8K/M/N :/N ~ COURT OF COMMON pI.~&S OF ; : NO. 04-2619 CIV/L ~ : ROBert E. mf~f/N : D~mdmt : IN DIVORC~ D TO: ROBERT E 8KIM/N TO: ROBERT F~ 8KIM/N lI~ ATTAClt~ TO THIS NOTIC~ ..... · ,~ raU/ltONOTARY OF TI~ COURT ~ uz~, t~v TO OR 'IZR.EPHONE THE Ot'~'iCE SET FORTH BELOW TO FnqD OUT v,~m~E YOU CA~ OET LEGAL mu.p. 2 Liberty A~-,~_. Carlfn!e. PA 17013-3387 717-24~-3166 : IN THE COURT OF COMMON PLEAS OF FATIMA A. SKIMIN : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 04-2619 : : ROBERT E. SKIMIN : C2VIL ACTION. LAW DEFENDANT : IN DIVOR~ C~RTIFICATE OF SERVI(~ BY MAIl. PURSUANT TO PA. R.CP. 1920.4 fa) JAMES M. BACH, Esquire, being duly swom according to hw, deposes and sa~ that be is the Attorney for ~ and ~ be did mall a tree and con~ copy of a Complaint under Section 3301(d) of the Divorce Code of 1980, along with a Notice to Defend and Claim Right, by registered/certified ma;1. return receipt requested, deliver to addressee only, to the ~ 352 South Sporting ~ R~d Mechanicsbu~ PA 17050 717-737-2033 Item 4 If Re~ficted Delivery Is de~ired. t Prim your n~rne and addre~ on the reverse so thet we can return the card to you. Att~ch..thl? card to the Pack of the me,piece /" [] Agent or on Tne Trent If space pe~nits. 1. Article Addressed to: 17 $. Se~ice Type [] Regi~te~d [] R~urn Receipt for [] Insu~d Mail [] C.O.D. t 4. Re~ote~ Daiive~? ii,Ira Fee) [] Ye~ Article Number (C=/~y/rom .mn~ce ,oS Fon'n ~1 '1. July 1999 Dome~f~c R~turn Receipt FATIMA A. SKIMIN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA PIMntiff : : vs. : NO. 04-2619 : ROBERT E. SKIMIN : Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the foi/owing information, to the Court for retry of a Divorce Decree: 1. (]ROUNDS FOR DIVORCE: In'etrievable bre~down under Section ( ) 3301(c) or ( X ) 3301(dX1) of the Divorce Code. (Check applicable section.) 2. DATE AND MANNER of service of the Complaint: · on 14 Jurm 2004. 3. COMPLETE Eli"dER PARAGRAPH (a) or (b). (a) Date °f execuii°n °f tho Affidavit of Consent required by Section 3301 (¢)of the Divorce Code: By Plaintiff ; by Defendant (b) l. Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code 9 June 2004. 2. Date of service of the Plaintiff's Affidavit upon thc Defendant: 14 June 2004. 4. RELATED CLAIMS PENDING: NONE 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(dX1)(1) of the Divorce Code: S Jnlv 2004, by orai..ry mMl~ _n,~__~_~_e DATE: ~ By: ~ .~torney I.D.//18727 A~tomey for Plaintiff 352 S. Sporting Hill Rd. MECHANICSBURG, PA 17050 (717)737-2033 IN ThE COURT Of COMMON PLEAS Of CUMBERLAND COUNTY STATE OF PENNA. ...... FATINA..A,...SKII4IN ...................................... N ()...0.4..-.2§.1.9... Ct.Yil...Term .................................. I~LA I ~FI'IFF. ......................... VerstlS ..... · ROBRRT...E.... Sl~ ~I~T M ...................................... ............... DEFI~NDANT ................. DECREE IN DIVORCE AND NOW, ....... ~¢~....~.9 ....... ;ZOO4 .... it Js ordered and decreed that .........FATIMA. A....s~z~z~ ...................... plaintiff, and ...................~.o.~.~..~F..~.....s~z.~. T~ .................... 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; Prothonotar~