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:~
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Anita Lynn oc~
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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.
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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
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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.
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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)
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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
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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
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~ '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
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PROTHONOTARY
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