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HomeMy WebLinkAbout04-6163 TRACIE RODKEY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNA. Plaintiff, vs. NO. D t- t~/ tJ ~ HARRISON JOHN RODKEY, Defendant. CIVIL ACTION - LAW IN DIVORCE NOTICE T0 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 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 property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdow~ of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL- MENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIDS 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 32 South Bedford Street Carlisle, P A 17013 Phone: 717-249-3166 or 800-990-9108 0, TRACIE RODKEY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNA. Plaintiff, vs. NO. HARRISON JOHN RODKEY, Defendant. CIVIL ACTION - LAW IN DIVORCE COMPl.JAINT IN DIVORCE UNDER ----_.. - -- SECTION 3301{c) or (d) 01'" THE DIVORCE CODE 1. Plaintiff, Tracie Rodkey, is an adult individual who currently resides at 124 High Street, Enola, Cumberland County, Pennsylvania, 17025 since October 2003. Plaintiffs Social Security Number is 209-64-9399. 2. Defendant, Harrison John Rodkey, is an adult individual who currently resides at 3810 Mountain View Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050 since 1997. Defendant's Social Security Number is 209-46-1865. 3. The Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the commencement of this action. 4. Plaintiff and Defendant were married on August 23, 1997 in Middletown, Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties in this marriage. 6. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 7. The marriage is irretrievably broken. 8. The Defendant has in violation of his marriage vows and the laws of this Commonwealth offered such indignities of the person of the innocent and injured Plaintiff as to render her condition intolerable and her life burdensome. 9. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require parties to participate in counseling. 10. Plaintiff requests that this Honor(lbl~ Court en~er a Decree of Divorce. 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 falsifications to authorities. Respectfully Submitted, IRA H. WEINSTOCK, P.e. 800 North Second Street Harrisburg, P A 17102 Phone: (717) 238-1657 By: /JnL/I /3. A1 /J-r ~ fOiN B, DOUGHE~ 2 ~}: . ~~~ ;~d -J . ......., ~(N ;5:) (' , --., ~ C--- ~ n (.~~~ f"--.) C,"~ c~ ~t...- Cj r-rJ C) I OJ '.1," :~:~ ..,.( ~) -'n o -1'1 .-1 '.1:: -n f'nf.~ -n r;':1 ;;1t~\ -_.~, "~', - '. ':? ~~~ ,r:- r"'",) TRACIE RODKEY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 04-6163 Civil HARRISON JOHN RODKEY, Defendant. CIVIL ACTION LAW IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Divorce regarding the above,captioned matter. Respectfully Submitted IRA H. WEINSTOCK, P.c. 800 North Second Street Harrisburg, PA 17102 Phone: 717-238-1657 B~. ^~L., 76fiN EI. DOUGH RTY Attorney tD. No. 70680 -------- \"-, i;~;) () -::::) '1'1 .::.J' (...~ ,:?'" :;;t: 1"-' ;;.- :;; -",~ "" '-" -' TRACIE RODKEY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 04-6163 Civil HARRISON JOHN RODKEY, Defendant. CIVIL ACTION - DIVORCE 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! 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. Dated: "S"" - d. 3 --0<:.;- -..-- --------- ; '~.... r~ .~' -- TRACIE RODKEY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 04-6163 Civil HARRISON JOHN RODKEY, Defendant. CIVIL ACTION - DIVORCE \V AIVRR OF NOTICE OF INTENTJON 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! 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. . 5-- f;- <).. RODKEY Dated: ------- -- .,") --1\ '!."'-' - TRACIE RODKEY, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. No. 04-6163 Civil HARRISON JOHN RODKEY, Defendant. CIVIL ACTION, DIVORCE AFFIDAVIT ()}' CONSENT I. A Complaint in Divorce under Section 3301( c) of the Divorce Code was filed on December 8, 2004. 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 ofa 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. 94904 relating to unsworn falsification to authorities. Dated: ~ / ~ ')-;'') ~ ~{P~ V!:l/; v, , ~. IS N 10 RODKEY '- ! - "-0 C~) f"') ~~g 'il c_ c-~: -c, r:~) c..J TRACIE RODKEY, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. No. 04-6163 Civil HARRISON JOHN RODKEY, Defendant. CIVIL ACTION, DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301( c) of the Divorce Code was filed on December 8, 2004. 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. 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! .C.S. 94904 relating to unsworn falsification to authorities. /J // . , ,.I , Dated: S'- ~ '3-0")' / I .I , " "-, = C:::::J ;;:.J"1 t'--,) c....:.: o .j ~Ef~: C' r -\ rr. TRACIE RODKEY, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. No. 04-6163 Civil HARRISON JOHN RODKEY, Defendant. CIVIL ACTION. IN DIVORCE ACCEPTANCE OF SERVICE I, Harrison John Rodkey, Defendant in the above-captioned action, hereby accept service ofthe Complaint in Divorce filed in the above matter. , Dated: / - , ,. /) \ C) ~:-:: .":J -, "'.> C;::, (= eJ'l o -n .-, ~ ". (:::::. I'.) c..:; . TRACIE RODKEY, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA vs. No. 04,6163 Civil HARRISON JOHN RODKEY, Defendant. : Civil Action, Divorce PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: entry of a divorce decree: Transmit the record, together with the following infonnation, to the Court for Divorce Code. L Ground for divorce: irretrievable breakdown under Section 330l(c) of the Defendant accepted service and has executed an Acceptance of Service. 2. Date and manner of service of the Complaint: January 31,2005- of the Divorce Code: by Plaintiff on May 23,2005; by Defendant on May 11,2005. 3. Date of execution ofthe Affidavit of Consent required by Section 330!(c) 4. Related claims pending: None. was filed with the Prothonotary: May 27,2005. 5. Date Plaintiffs Waiver of Notice in Section 3301(c) of the Divorce Code was filed with the Prothonotary: May 27,2005. 6. Date Defendant's Waiver of Notice in Section 3301(c) of the Divorce Code -- . Respectfully Submitted, IRA H. WEINSTOCK, P.c. 800 North Second Street Harrisburg, P A 171 02 Phone: 717,238,1657 By ~H:r/) ^~J" OHN B. DOUGH TY t) ,..., c~-;, C:::l <;.:..11 \-=> -n r.......) ., c...J ._~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :t: ",,:t::+: :f.:f. :+::f.:+'1f.:f. ""'" "" iii ;t; if. if :+: :t:ili:+:"""''''''' . :f.:+::+::+::f. '" :f.;!; :f. :+::f.'+::t:;+::.dli:t'if.if.ifiififf. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TRACIE RODKEY, Plaintiff, No. 04-6163 Civil VERSUS HARRISON JOHN RODKEY, Defendant. DECREE IN DIVORCE c:;r cr:~' A.pl . AND NOW, ::r \-.L i 2005, IT IS ORDERED AND DECREED THAT TRACIE RODKEY , PLAINTIFF, AND HARRISON JOHN RODKEY , DEFENDANT, ARE DIVORCED FROM THE BONOS 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; N/A ATTEST: PROTHONOTARY . .. .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . .. . .~ ~ ~ ~I/, 5i/..ht if ~ fiP $- /'!J'~".I;#(U'P 5d.F<f J . -. ..' . ... -