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HomeMy WebLinkAbout01-1236PAMELA W. LACKEY, Plaintiff, MICHAEL LACKEY, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : 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 entered against you by the Court. A judgment may also be entered against you for another 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, 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, PA 17013 (717) 249-3166 PAMELA W. LACKEY, Plaintiff, V, MICHAEL LACKEY, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO: CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Pamela W. Lackey, by and through her attorneys, Mancke, Wagner, Hershey & Tully, and files the following Complaint in Divorce: 1, The Plaintiff, Pamela W. Lackey, is an adult individual currently residing 114 Third Street, P.O. Box 238, Boiling Springs, Cumberland County, Pennsylvania. 2. The Defendant, Michael Lackey, is an adult individual currently residing at 114 Third Street, P.O. Box 238, Boiling Springs, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Cormnonwealth of Peunsylvania for at least six (6) months pr/or to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on July 28, 1979, in Carlisle, Cmnberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that she has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based is that the marriage is irretrievably broken pursuant to §3301 (c) of the Divorce Code. -2- WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, Mancke, Wagner, Hershey & Tully P. Richard Wagner, Esquire I.D. #231O3 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: -3- ~ ~ I.fI~I~BY C~.TIFY THAT THE WITHIN IS A TRUE AND COR- RECT COPY OF THE ORIGINAL FILED IN THIS ACTION BY A*crORNSY MANCKE, WAGNER, HERSHEY & TULLY VERIFICATION I verify that the statements made in the foregoing document 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. ~ Z PAMELA W. LACKEY, Plaintiff, MICHAEL LACKEY, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1236 Civil Term CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of MANCKE, WAGNER HERSHEY & TULLY, do hereby certify that on this date a copy of the COMPLAINT IN DIVORCE was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Mr. Michael Lackey 114 3~d Street, Box 238 Boiling Springs, PA 17007 DATE: 03/10/01 Debra K. Spinner, Secretary MANCKE, WAGNER, HERSHEY & TULLY 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff Z 231 525 745 US Pestal Servic~ ' Receipt for Certified Mail No insurance Coverage Provided. Do not use for ~ntematJonat Main (See reverse) Delivery Fee · Complete Rems 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and addrees on the reverse · so that we can return the card to you. · A'~ach this card to the back of the mallpiece, or on the front if sp~ca Definite. I.~ Article Addressed to: 2. Article Number (Copy from service label) PS Form 3811, July lgg9 A. Re~ek~ed by (P/ease P~nt, X ~ C.O.D. PAMELA W. LACKEY', Plaintiff, V. MICHAEL LACKEY, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1236 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 2, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90} 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I not claim them before a divorce is granted. do 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. Section 4904, relating to unsworn falsificat.~on to authorities. Pamela W. La~ PAMELA W. LACKEY, Plaintiff, MICHAEL LACKEY, Defendant· : IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1236 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENT~iON TO REQUEST ENTR~Y OF A DIVORCE DECREE U~DF~R SECTION 3301(c) 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 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 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. DATE: ~/~/~ PAMELA W. LACKEY, Plaintiff, V. MICHAEL LACKEY, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAIqD COUNTY, PENNSYLVANIA NO. 01-1236 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 2, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety <90) 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. 4. 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. DATE: 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. Section 4904, relating to unsworn falsification to authorities. PAMELA W. LACKEY, Plaintiff, MICH3UEL LACKEY, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1236 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER Or NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNI)~R S~CTION 3301(~) OF THE DIVORC~ 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 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 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. IN THE COURT OF COMMON PLEAS OF C[~MBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · , Plaintiff Defendant File No. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that above matter, having been granted a prior surnameof this written notice pursuant to the provisions of 54 P.S. g or.me being resumed the Plaintiff/Defendant in the Final Decree in Divorce on the · hereby elects to resume the and gives $ 704. COMMONWEALTH OF PENNSYLVANIA: · . SS. COUNTY OF CUMBERLAND Notary Public. pers~lly appeared ~ ~ove affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. seal. In Witness Whereof, NOTARIAL SEAL APRIL O. SHEAFFER, N~t~ Public Carlisle, Cumberland County My Cemml~ion EN31res April 23, 2006 PAMELA W. LACKEY, Plaintiff, MICHAEL LACKEY, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 01-1236 Civil Term : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT THE 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), 33~)~d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: March 2, 2001, certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 06/08/01 By Defendant: 06/08/0 l (b) (1) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divome Code: (2) Date of service of the Plaintiff' s Affidavit unto the Defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1)(i) of the Divorce Code: ~/ Richa~er, ~ttorney for Plaintif~sq' 1N THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. PAMELA W. LACKEY NO. 01-1236 VERSUS MICHAEL LACKEY AND NOW, DECREE IN DIVORCE ~ IO:',~A.Iv1 · , go01 ,,T ,s ORDERED AND DECreED THAT PAMELA W. LACKEY AND MICHAEL LACKEY ,PLAINTIFF, ,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