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Home My WebLink About05-1104 n LAW OFFICES OF EDWARD J. MIMNAGH EDWARD J. MIMNAGH, ESQUIRE Attorney I.D, No, 87860 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Email: mimnagh.1aw@verizon.net Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA elO"~"T1 CHRISTOPHER A. PARSONS, Plaintiff NO. OS - 1101 DORTHEA PIKEY a/k/ a DORTHEA WAGNER, Defendant CIVIL ACTION - LAW IN DIVORCE 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 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. 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 LAW OFFICES OF EDWARD J. MIMNAGH EDWARD J. MIMNAGH, ESQUIRE Attorney J.D. No. 87860 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Email;mimnagh.law@Verizon.net Attorney for Plaintiff CHRISTOPHER A. PARSONS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Of: - / 16~ {!;u~L ~fLl DORTHEA PIKEY afkf a DORTHEA WAGNER, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Christopher A. Parsons, who has resided in Pennsylvania, for the last two (2) years. Plaintiff's address is being withheld for fear of physical harm. 2. Defendant is Dorthea Pikey afkfa Dorthea Wagner, who has resided at 42 Altoona Avenue, Enola, Cumberland County, Pennsylvania, for several years. 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 7, 1997, in Cahokia, II1inois. 5. There have been no prior actions of divorce or for annulment between the parties, 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. COUNT I - DIVORCE UNDER SECTIONS 3301 Ie) AND 3301(d) OF THE DIVORCE CODE 9. The paragraphs 1 through 8 of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. 11. The parties separated in March 2002. 12. Plaintiff will submit an affidavit alleging that the parties have lived separate and apart for at least two years. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree in Divorce. Respectfully Submitted: LAW OFFICES OF EDWARDJ.MI, I Date: February 24, 2005 "'--. CP~ By: EDWARDJ.M NA Attorney 1.0- No. 8786 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Attorney for Plaintiff Christopher A. Parsons VERIFICATION I, CHRISTOPHER A. PARSONS, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.SA S4904 relating to unsworn verification to authorities. DATE: (/;;;f=~ ~ h~-- r2 C RISTOPHER A. PARSONS (J ~ - 8 -p r:\b. ...() ....' Q. 0 ,;;:::> \) = ~ c: ~," ~:P :.~' :;Jl: "'"C'l,\'Yj ~ till'! ~ -nln - "'" r:y ~:'~::,:" 1 :,,,0 r -~ U'f- N S~h ..:l ~.<~ :r::t\ }L r:::: ~ ~ ',*G .." <:;;?C'> :;:It ,..,-tn -F :,;CJ '-i! 2 - 'C ;!:,. 2: ~~ .'.q :.t 0' .- . . LAW OFFICES OF EDWARD J. MIMNAGH EDWARD J. MIMNAGH, ESQUIRE Attorney 1.0, No, 87860 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Ernail rnirnnagh.law@verizon.net Attorney for Plaintiff CHRISTOPHER A. PARSONS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-1104 CIVIL TERM DORTHEA PIKEY AIKI A DORTHEA WAGNER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, EDWARD J. MIMNAGH, ESQUIRE, do hereby certify that a true and correct copy of the Complaint in Divorce was served upon the Defendant by certified mail, return receipt requested, on March 8, 2005. The original signed return receipt, number 7003 1010 0000 6249 2270, is attached hereto ~ade a part here f. LAW6FFI~ES ~ iPWARDl MiMI l By:~Ji- EDWARD J. MlMNAGH, ESQUIRE Attorney J.D. No. 87860 Date: March 10, 2005 Sworn to and subscribed before me this ;L/11i day of f/)tJ.rt'A ,2005. 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Attorney for Plaintiff Karen A ~ria' Seal Palmyn, 'aoro erift, Notary Public My Corninissioo ,lebanori County Member, Penns Expires May 16, 2006 l'Ivallla ....SOCialion Of No ' lanes \ SENDER: COMPLETE THIS SECTION . . . . . Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Signature x o Agent o Addressee c.. qate of ,DeliVery !JJ'3/c Is delivery address different from item 1? 0 Ves If YES, enter delivery address below: 0 No Dorthea Pikey a{kIa DortMa Waper f2 AJtoona Avenue Enola, PA 17025 '1 ) 3. Service Type )( Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC,Q.O, 4. Restricted Delivery? (Extra F88) Yes 2. Article Number (Transf.r from s.rv;c.,ab'______7~~0~QQ.o.O_g~ 9 PS Form 3811, August 2001 Domestic Return Receipt 2270 102595-01-M-0381 ,,) CHRISTOPHER A. PARSONS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1104 Civil Term DORTHEA PIKEY a/k/a DORTHEA WAGNER, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this Affidavit has been served on you, or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on March 1, 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, attorney's fees or expenses if I do not claim them before a divorce is granted, L,I .... CHRISTOPHER A. PARSONS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1104 Civil Term DORTHEA PIKEY a/k/ a DORTHEA WAGNER, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this Affidavit has been served on you, or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. The parties to this action separated on March 1, 2002 and have continued to live separate and apart for a period of at least two years. 2, The marriage is irretrievably broken. 3, I understand that I may lose rights concerning alimony, division of property, attorney's fees or expenses if I do not claim them before a divorce is granted. --./ . 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. S 4904 relating to unsworn falsification to authorities. Date: c/ /0 J' thJhL ~ CHRISTOPHER A. PARSONS, Plaintiff () , , :-(\ ..... "."r' \\'\ :,:.., -~l uo --0 ....:: r.:, co ). . . CHRISTOPHER A. PARSONS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1104 Civil Term DORTHEA PIKEY a/k/ a DORTHEA WAGNER, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE 1. Check either (a), (b), or (c): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two (2) years, (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be ~ ~ ..... unable thereafter to file any economic claims. I verify that the statements made in this counter-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: DORTHEA PIKEY a/k/ a DORTHEA WAGNER, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ~ ...., = = 00 ,- ~E ~ :? 61p ?~? '23 '_::~:: (\"~ -r'l {j "0 -,:" , ( I ~::!rr1 :::~ ~;o -< f'-.} c::> -n ::.1: N ()1 ~... ,_}J. FILE COpy EDWARD J. MIMNAGH, ESQUIRE Attorney I.D. No. 87860 Law Office of Edward J. Mimnagh 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Email: mimnagh.laW@Verizon.net Attorney for Plaintiff Christopher A. Parsons CHRISTOPHER A. PARSONS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1104 CIVIL TERM DORTHEA PIKEY A/K/ A DORTHEA WAGNER, Defendant CIVIL ACfrON - LAW IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF & 33011d) DIVORCE DECREE TO: Dorthea Pikey aIkIa Dorthea Wagner 42 Altoona Avenue Enola, P A 17025 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the ~ 3301(d) affidavit. Therefore, on or after June 2, 2005, the other party can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the Court is attached . . ,~ to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the rights to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PRONDE YOU WITH INFORMATION ABOUT AGENGIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 Telephone: (800) 990-9108 Date: May II, 2005 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Attorney for Plaintiff Christopher A. Parsons (') (; ~ ~ '-<- \~:;:,: ,0 ,- (<: ~':'\ -< ~ (:> "" .-\ -rl ?f\~ -ero -l,.> \ C?t(;'1, "<- -, .....q -=,.. ;':)-~ ':":\,-f1 ';:> A }oo :.4 .- .' I'~ U' - ", ...... LAW OFFICES OF EDWARD J. MIMNAGH EDWARD J. MIMNAGH, ESQUIRE Attorney I.D. No. 87860 203 Wesl Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Attorney for Plainliff CHRISTOPHER A. PARSONS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-1104CIVILTERM DORTHEA PIKEY NKJA DORTHEA WAGNER, Defendant CIVIL ACTION - LAW IN DIVORCE 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(d)(I) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on the March 8, 2005, by certified mail, return receipt requested, receipt number 7003 1010 0000 6249 2270. 3. Date of execution of the Affidavit of Consent required by ~ 3301(d) of the Divorce Code: April 1, 2005. Date of filing of the Plaintiffs Affidavit: April 19, 2005. Date of service of Plaintiffs Affidavit upon the Respondent: April 21, 2005. 4. Related claims pending: None. .... 5. (Complete either (a) or (b).) (a) Date and manner of service ofthe Notice oflntention to File Praecipe to Transmit record, a copy of which is attached: May 12, 2005, by first class mail, postage prepaid, addressed to Defendant. (b) Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: Date: June 8, 2005 By: EDWARD J. MI NAGH, ESQUIRE Attorney J.D. No. 87860 203 West Caracas Avenue Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Attorney for Plaintiff .....' co' ~ ~. s~:; ,.;':-- N o ::2 .....0 o -.1 .--\ ""R-n r-t"'1r- -g jTl "UO (')Cn, :~i~:.\'i (;+9 :__")11< '::::-t -> ""'J :< _:.,-, \"-' U'j . .. . .. . . . ... iIi !+iIi :+::f. 11::+' ... Of. !+,., :+::f.iIi !+ !+ . . IN THE COURT OF COMMON PLEAS . OFCUMBERLANDCOUNTY . PENNA. . . STATE OF . . CHRIsrOPHER A. PARSONS, . . 05-1104 CIVIL rERM . . Plaintiff No. . VERSUS . PIKEY a/k/a WAGNER, Defendant . DORrHEA DORrHEA . . . . . . DECREE IN DIVORCE . . . . . . . . . . f , IT IS ORDERED AND .z/~ ,2005 AND NOW, . . . . CHRISrOPHER A. PARSONS , PLAINTIFF, DECREED THAT . . . DORrHEA PIKEY a/k/a DORrHEA WAGNER , DEFENDANT, AND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Of Of;+;;f Of. iIi '+i;f. 't'!+:+: 'f '+' +.+ . . . . . . . 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; None . . . . . . . . . Of,..,:+: ;t; 'I' Of 'f:+:'+''I' '+' 'f !+:+::+;:+;'ti'f . . . . . . . . . . . . . . '. PROTHONOTARY . . . . :+:iIi:+i:+::+"":t; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. .* '%~ ~ 50- )e-~ ~ pp ~~ 'r1J SO- Je-'?/ or"\ . :' ~ ' - -