HomeMy WebLinkAbout04-3611FRANK GERARD WOLFE,
Plaintiff
VS.
DENISE MICHEALLE WOLFE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004-~[
CIVIL ACTION- LAW
IN DIVORCE
Civil Term
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 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 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 of Cumberland County, Cumberland
County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013.
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
1-800-990-9108
FRANK GERARD WOLFE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 2004 - .~ ~.[j Civil Term
DENISE MICHEALLE WOLFE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
The Plaintiff is Frank Gerard Wolfe, an adult individual whose current
address is 3427 Bedford Drive, Camp Hill, Cumberland County,
Pennsylvania 17011, and whose social security number is 184-48-3517.
2. The Defendant, Denise Michealle Wolfe, is an adult individual, whose
current address is 421 North Third Street, West Fairview, Cumberland
County, Pennsylvania 17025, and whose social security number is 187-58-
8649.
3. Plaintiff and Defendant were married on April 30, 2000, in Las Vegas,
Nevada.
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania
for a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff is a citizen of the United States and Defendant is a citizen of the
United States.
7. There has been no prior action for divorce filed in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are no minor children bom of the marriage.
10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant
a Decree in Divorce.
Date: July 21, 2004
Respectfully submitted,
1017 North Front Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
VERIFICATION
I verify that the statements made in this Complaint in Divorce 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.
FRANK GERARD WOLFE
Date: July 21, 2004
FRANK GERARD WOLFE,
Plaintiff
VS.
DENISE MICHEALLE WOLFE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - 3611 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on July 23, 2004.
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.
I consent to the entry of a final Decree in Di[vorce 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 made herein are made subject to the penalties of
18 Pa. C.S. §4904, relating to unsworn falsification to authorities./] /
Date:~'ff~,o IC.~;~_~~~~~olf~f~~'/~_ ~ . .- --.-__.
FRANK GERARD WOLFE,
Plaintiff
VS.
DENISE MICHEALLE WOLFE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - 3611 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(c) OF TIlE DIVORCE CODE
1. I consent to the entry of a final Decree in Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I d.o 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 Waiver 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: ~-~_ . I~ ~_D~_ ~' ~-'~nk~ - Gerard~ '--'~- -' ~ or6/lf;,- mla,ntl~-' ' / --
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VERSUS
DENISE MICHEALLE WOLFE,
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'f+"''''+;+; :+:++++:f.+:f.+;+;;+;+++++++:f.+ "'++++++'" +:+:++++++;+;+++++?
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTy'
STATE OF
PENNA.
FRANK GERARD WOLFE
Plaintiff
NO. 2004-3611 Civil Term
Defendant
DECREE IN
DIVORCE
AND NOW,
.1;:> ;-7 V ,> ) '1
\
7(
, 2L~, IT IS ORDERED AND
DECREED THAT
FRANK GERARD WOLFE
, PLAINTIFF,
AND
DENISE MICHEALLE WOLFE
, 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;
No claims raised.
. i
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