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Home My WebLink About01-2627SARAH L. SKJEIE, V TERRY C. SKJEIE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2001- ,,~ L, ~- '7 CIVIL TERM : CIVIL ACTION -. LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTR 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 of divorce or annulment may be entered 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 properly or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the 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 ANNIJLMENT 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 CAIN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 SARAH L. SKJEIE, Plaintiff TERRY C. SKJEIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 2001- .2 6 .z 7 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE Plaintiff, Sarah L. Skjeie, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Sarah L. Skjeie, is an adult individual residing at 65 North Middleton Road, Carlisle, Cumberland County, Pennsylvania 17013. 2 Defendant, Teny C. Skjeie, is an adult individual residing at 221 Birch Lane, Carlisle, Pennsylvania 17013. 3 The parties were married on February 25, 2000, in Richmond, Virginia. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced fi.om the Defendant. /~ndsay D. B~d, Esq~re Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I verify that to the best of my knowledge and belief, 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~4904 relating to unsworn falsification to authorities. %~ ~ b~l'ah L. Skjeie, Plaintiff ,~ ~ SARAH L. SKJEIE, Plaintiff TERRY C. SKJEIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 2001- 2627 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, May 2, 2001, and accepted on his behalf by his attorney, Johnna J. Kopecky, Esquire, a copy of the Acceptance of Service being attached hereto. Said service on May 2, 2001. /L4nd~ay D. B~r~ Esq/~ire Attorney for Pl'alntiff 37 South Hanover Street Carlisle, PA 17013 717 - 243-5732 Sworn and Subscribed to before me this ;~"f day of .~a~ , 2001. Notary Public Notarial Seal Nlven J. Baird, Notary Public ,C, arllsle Bo.to Cumberland County ~ ~,~, Corem ss~on Expires Nov. 2. 2002 SARAH L. SKIEIE, Plaintiff TERRY C. SKJEIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : : NO. 2001- CIVIL TERM : : IN DIVORCE ACCEPTANCE OF SERVICE I, Johnna J. Kopecky, Esquire, hereby accept service of the Divorce Complaint on behalf of the Defendant Terry C. Skjeie. Date SARAH L. SKJEIE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA v. : NO. 2001- 2627 : TERRY C. SKJEIE, : IN DIVORCE Defendant : CIVIL TER~'.? }f: : AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THIE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 2, 2001. 2. Service of the Complaint was accepted on behalf of the Defendant by his attorney, Johnna J. Kopecky, Esquire, on May 2 2001. , 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the of the filing of the Complaint. date 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. I understand that I will not be dive. rced 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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.o /7) Date: ~'~/ O/ /~//f~l / ~~_~ ~"SaX~-S~jef~, ~l/ff SARAH L. SKJEIE, Plaintiff TERRY C. SKJEIE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2001-2627 CIVIL TERM : IN DIVORCE DEFENDANT.S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE ~AIVER OF NOTICE OF INTENTION TO REQUES'~' ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c/ OF THE DIVORCE COD~; 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 2, 2001. 2. Defendant acknowledges and accepts service of the Complaint on May 2, 2001. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counselling and understand that I may request that the court require counselling. I do not request that the court require counselling. 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 author. DATED:_ %--/~ - ~\ Terry ~ <~ ~ Defendant- SARAH L. SKJEIE, Plaintiff TERRY C. SKJEIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 2001- 2627' CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECQRD 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) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of service by Johnna J. Kopecky, Esquire, on behalf of defendant, May 2, 2001. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 9/21/01; by Defendant: 9/14/01. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 10/2/01 Date efendant s Waiver of Not ce in §3301(c) Divorce was filed with the Prothonotary: D ' 10/2/01 ~/Lindsay Dar~ ~alrd, Esquire Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF ~ COUNTY PENNA. ~laintiff Defendant N 0 ...... 20.Q1=2617 ................. k9 DECREE IN DIVORCE AND NOW ............ .~r,~-~..~..././..~ ...... :3~. :~?:., it is ordered and decreed that Sarah L. Skjeie ................................... plaintiff, a nd ............................ T~:~. ¢,. Sk~eie ............... defendant, are divorced from the bonds of matrimony. The court retains iurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; None