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Home My WebLink About01-3468 ?Yn%7 Y ~ ~~ ~if~ ~~.pl l~ . ) rJ./11 -II ItJ.l1/ -/1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLYN. ICKES, PLAINTIFF v. No. 3468-2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE 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 section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: by first-class mail to defendant's attorney, David Baric, Esq., on June 6, 2001. 3. Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by plaintiff, signed on 10/4/01 and filed with the court on 11/5/01; by defendant, signed on 10/9/01 and filed with the court on 11/5/01. 4. Related claims pending: none. 5. Date plaintiff's waiver of notice was filed with the prothonotary: 11/5/01. Date defendant's waiver of notice was filed with the prothonotary: 11/5/01. ~ // Ste hanie E. Chertok Attorney for Plaintiff a ~ <.: " :c I~" , ;~~ L v, ... ~~ 0" \.J) ~' C' ~" ,.'- ~:; ., rct > ~ c C"' --:-".. ....~. "J C:') IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLYN. ICKES, PLAINTIFF v. No. 3'-1 (Pet -2001 (!\ V~ \ CHRISTIAN L. ICKES, 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, 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 the Cumberland County Courthouse. 1 Courthouse Square, Carlisle, P A 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 MA Y 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 Lawyer Referral Service 2 Liberty Ave. Carlisle, P A 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KIMBERLY N. ICKES, PLAINTIFF v. No. (iI- 3'1(.,V -2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Kimberly Naomi Ickes, who currently resides at 12 Courtney Drive, Shippensburg, Cumberland County, Pennsylvania 17257, since May 24, 2001. 2. Defendant is Christian Lee Ickes, who currently resides at 285 Shed Road, Newville, Cumberland County, Pennsylvania 17241, since fall of 1993. 3. Plaintiff and Defendant have been separated since April 8, 2001. 4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 5. Plaintiff and Defendant were married on October 10, 1998 at Newville Assembly of God in Newville, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiffrequests the court to enter a decree of divorce. DATE:tjl/jo I Ste hanie E. Chertok, Esq. Attorney for Plaintiff ID No. 52651 61 W. Louther St. Carlisle, P A 17013 717-249-1177 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: (f ~5 --0/ I ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY N. ICKES, PLAINTIFF v. No. -2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Stephanie E. Chertok, Esquire, counsel for Kimberly N. Ickes, do hereby t'-- certify that a copy of the Complaint in Divorce, was served this (; day of (T UY/e:... , 2001, by first-class mail, postage prepaid, upon those listed below: David A. Baric, Esquire Attorney for Defendant 17 West South Street Carlisle, PAl 71 03 Ste anie E. Chertok, Esq. Counsel for Plaintiff - c-:> ~?'~ :::~ 9J .~ ~ ~ t9 '2J ~, ~ ~ -=-- ~ -' ----- (") C:~'} C :;-: -0("'; ..' [I) L; '7 zc 0' If) ,'" ~"',,, ~G j.:; C' , ", ~ t:S == :.-:; ~~ ;..~ ~ :< (T\ €J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY N. ICKES, PLAINTIFF v. No. 3468-2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, David A. Baric, Esquire, attorney for the Defendant in the above-captioned divorce action, accepted service of the Complaint in Divorce which was filed June 6, 2001, on behalf of my client, Christian L. Ickes. ~;/J;{ tf ' David A. Baric, Esq. Attorney for Defendant 17 West South Street Carlisle, P A 17013 c c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY N. ICKES, PLAINTIFF v. No. 3468-2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on June 6, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. DATE: I()- L/- 0 ( c:' ',~',: C f7~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY N. ICKES, PLAINTIFF v. No. 3468-2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN 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. section 4904 relating to unsworn falsification to authorities. DATE: 10-18-01 c c -" ',.j '. r~.-..-' ~ -:/ -. f~~;:.. \ :':../ r:; ).:> (.: ~--) (I' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY N. ICKES, PLAINTIFF v. No. 3468-2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LA W IN DIVORCE AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on June 6, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. DATE: 10/9/01 I I a~~.~~ Christian L. Ickes, efendant t. .,~~ ~"".__w'~ , . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLYN. ICKES, PLAINTIFF v. No. 3468-2001 CHRISTIAN L. ICKES, DEFENDANT CIVIL ACTION - LAW IN 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. section 4904 relating to unsworn falsification to authorities. DATE: Oct ;)3 ;)['01 , Ck~dJ' ~~ Christian L. Ickes, efendant o ::;~ d~~:.. ,":.-- ./ '~.I I -,' ~:: ;,- G t-:-:1 ~ o c.. l.!\ ;"> -- ., ~ ~ )-:... ..,..... ..--'