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HomeMy WebLinkAbout04-3012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. Oc.(- ~() Id.. ~ : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant 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 Cumberland County Courthouse, Carlisle, Pennsylvania. If YOU DO NOT FILE A CLAIM FOR AUMONY, 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 0'1. 30/-<., ~ --&.-. : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Anita Lynn Ocker who currently resides at 18 Holly Court, Shippensburg, Cumberland County, Pennsylvania, since April1?, 2004. 2. Defendant is Randy Allen Ocker who currently resides at 1100 David Street, North Myrtle Beach, Horry County, South Carolina, since June 5, 2004. 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 September 19, 1996 at Myrtle Beach, Horry County, South Carolina. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably 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 requests the Court to enter a decree of divorce. COUNT TWO 9. Paragraphs 1 through 8 are incorporated herein by reference as fully as if set forth at length. 10. In violation of his marriage vows the Defendant did after the date of marriage set forth herein at various times in and around the Borough of Shippensburg commit acts of adultery causing great harm to Plaintiff the injured and innocent spouse. Wherefore Plaintiff requests that she be granted a divorce from the bonds of matrimony. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 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. Date:~ ~. OUu.-- Anita Lynn oc~ ~!~ ",. r". --- u.... - 5J.-- C> .~ 0 --h S\ V'\ _. ....f'I Q > I"'-- \..J ~, cY 1--) ., -', e;/\ 00'\ j "",", . \'-, ~ .". IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 04-3012 Civil : Civil Action - Law vs. : In Divorce Randy Allen Ocker, Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the .above matter, having been granted a Final Decree in Divorce on the J 3,. J) day of \Jou~ 'f'J'.~~, 2004, hereby elects to resume the prior name of Anita Lynn Kepner, and gives this written notice pursuant to the provisions of 54 P.S. Section 704. Date: JL/';)..(p lo'f I ~,~ Anita Lynn Oc er ,-u., h. ~;;r "'- ~ Anita Lynn Kepn ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNl'Y OF CUMBERLAND On the~'4V\ day of JJnue~~, 2004, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing document for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. \~C~, "'- Notary Public My Commi~sion Expires: - ~ Notarial Seal H. Anthony Adams, Notary Public Shippensburg Boro, Cumberland County My Commission Expires May 15, 2006 MemlJer, PennsylvanlaAssocialion 01 Notaries -tq ~ g F! ~ ~ ~ -r- f ~ "- ~ ~ o f~ ~3f?' ~.:;;: ~."': 1;:~-! I;~. ~i:: i~:;2 ~ ~ ~ :z: C> ...::: 1') \.D b -n -I :r: l"11;? ;Be l:_:~ (') :J;: ::H <;',~("'i :':'')l-n .::=-t 5'; -< ~ :1: s:- a\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 04-3012 : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 29, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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 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. Date:~ \ CL I h_ (~( :''''f.1\ ('Cf;)L Anita Lynn Ock r J Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 04-3012 : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 29, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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 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. Date: 10/;)"-/0'1 J2Jr (JJL- OJ- Randy Allen Ocker Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 04-3012 : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 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. Section 4904 relating to unsworn falsification to authorities. Date:~ ~~ (tel ~(f(/1\- CO)th ~- Anita Lynn Ocke Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 04-3012 : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 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. Section 4904 relating to unsworn falsification to authorities. Date: /0/;;1.5 Jc:;'-j ~~ au- OJ- Randy lien Ocker Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Anita Lynn Ocker Plaintiff vs. Randy Allen Ocker Defendant : No. 04-3012 Civil : Civil Action - Law : In Divorce ACKNOWLEDGEMENT OF SERVICE H. Anthony Adams, Esquire state that a complaint in divorce was mailed to Randy Allen Ocker, of 1100 David Street, Apartment 1305, North Myrtle Beach, South Carolina, 29582, certified mail, return receipt requested on July 2, 2004 and was accepted on delivery by J. Stevens on July 6, 2004. An acceptance of service was signed and filed by Randy Allen Ocker to verify his receipt of the said complaint. ill !" u:g =;;O~ . . . f I! ~1:i~;Ug } t~J i OSl)-a,3i . ::'Ig.i<,(lo. ~ S-"ll"'l1 r~ (I) 2: ...,:.tI G) ~ H~~n ~ I~ 3 7 I € rJ1..c.. ~ ~. g _ c (>~;"O-~R ic;h3.:" ~ f -30. I\) r: ~ ~O f.lii!T8:~~ 8 'ill'.. ~ - ~ro~~ 3.a!;.; ~~tJ\ct-~ ii~c;~C.8 --.J "''S !T!3.~ '" 3c"'! '" v' ~. ~''2. I u.J J' ~ ~ '" lJ1 f CI D '" '" !J I D I ~ j fl D D u.J '" Kg,I8.~ lJ1 l(;!: ~ ...D !!1. _ ...D rtJ i cr<<.o lJ1 o~1 '" i g ~ r-' ~ ~ H 'S i if ;;: I i f ~,c,((;O~ -" H. Anthony Adams, squire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 U.S. Postal Service", CERTIFIED MAIL,. RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) .., <0 U1 ~ r~;:~~i"j~~&'~~:~;';i';~~\L" 'I "i "i'''',,''': U1 - . r"- Postage $ $0.37 $2.30 Certified Fee J rn D D Return Aeciept Fee Cl (Endorsement Required) C1 Res\Tictea Oali'l61)' Fee. e (Endorsement Required) U1 Cl Tota' postage & Fees 0257 O~j postmark Here $1. 7~ W.Of) $ H..2 071021200. rn C1 enl To CJ .._u..._nn_____ _ _nOo_n_ n_n.__n_ t"'- sfn;el.oAPt:iiio~;.-.o.-__o.._non..n or pO Box No. _un n_n nn_u__nO___nH_n_ 0 ___u_n..._no.nnnnn . n_ CJrY~ Stai6~ZiP+4 . . VERIFICATION I verify that the statements made in this statement 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. Date:44-0 y r \ (j~'. '-.. ,,'. ~---_\:c;>.~>':::::::>k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Anita Lynn Ocker, Plaintiff : No. 04-3012 : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. I certify that I am authorized to accept service on behalf of defendant. Date je I ;)S J 0<1 . ~~ 0JlJ2-~ CO cJ-~ Rand Allen Ocker 1100 David Street Aoartment 1305 North Mvrtle Beach. SC 29582 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Anita Lynn Ocker Plaintiff : No. 04-3012 : Civil Action - Law vs. : In Divorce Randy Allen Ocker Defendant 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on July 2, 2004. The return receipt was signed by J. Stevens on July 6,2004 not by the Defendant. The Defendant signed an acceptance of service to confirm his receipt of the complaint. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff November 11, 2004; by Defendant October 25, 2004. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice was signed on November 11,2004 and is filed herein and Defendant's Waiver of Notice was signed October 25, 2004 and was filed November 10, 2004. ~~ H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 :+:+::+:+::+: , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , :+::+:+::+:+: :+: :+::+::+::+::+:+::+:+::+::+::+::+::+::+::+::+::+::+: :+::+::+::+::+::+: :+::+: :+::+::+::+::+::+::+::+::+::+:~:+:+::+:+::+::+::+::+::+::+:+::+:+::+:+::+::+::+::+::+::+:~:+:+::+:+::+:+::+:~ . . , , . . . . . . . . , . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ 'fi Of. Of. Of.:+: Of.:+::+:;to: '+ Of. Of. OfT. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Anita Lynn ocker NO. 04-3012 VERSUS Randy Allen Ocker DECREE IN DIVORCE AND NOW, t\)~ 2004 , iT is ORDERED AND z? DECREED THAT Anita Lynn Ocker , PLAINTIFF, AND Randy Allen Ocker , DEFENDANT, ARE DiVORCED FROM THE BONDS OF MATRiMONY. Civil THE COURT RETAiNS JURiSDiCTiON OF THE FOLLOWiNG CLAiMS WHiCH HAVE YET BEEN ENTERED; BEEN RAiSED OF RECORD iN THiS ACTiON FOR WHiCH A FiNAL ORDER HAS NOT None --~- ,-.' .....~\~ 3_ . i . ..-/:- ~ '~.;., ~ ~ - :. ~;. ~'':-.....', , / ,.......~ ~ ~ "..-.....~ , ~ - ..... \v , ,. By TH,S c.. OU /.R. V '~:~~ A~:d~ . "' '. .~ ~~~,:.'.~,~r~V .. lO~:molOOOO:O:O:O: :+: ,+;ti:+:;F.Of.'F. +::+: ~;ti:+:~:+:;F.:+::+: ~ :+: :+:~:+:;F.+: Of.:+:+: +::+:;F.+: :+:~ PROTHONOTARY J. -h ,e /fl'--' ~ 40",,1/ ro&/lJ f~ 1-, r. 4I.;.1fl.J Ail h f" -II