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MARY M. MEDKEFF-ROSE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 01-3717 CIVIL TERM
BRIAN N. MEDKEFF-ROSE,
DEFENDANT
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 SECTION 3301 (c)
3301 (D1{t) OF THE DIVORCE CODE. (STRIKE OUT INAPPLICABLE SECTION),
2, DATE AND MANNER OF SERVICE OF THE COMPLAINT: AFFIDAVIT OF SERVICE (FILE
6/29/00 )
3, (COMPLETE EITHER PARAGRAPH (A) OR (B)),
(A) DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY
SECTION 3301 (C) OF THE DIVORCE CODE: BY THE PLAINTIFF:
APRIL 15, 2002; BY THE DEFENDANT APRIL 15, 2002.
(B) (1) DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED
BY SECTION 3301 (D) OF THE DIVORCE CODE:
(2) DATE OF SERVICE OF THE PLAINTIFF'S AFFIDAVIT UPON THE
DEFENDANT:
4, RELATED CLAIMS PENDING: NONE
5, COMPLETE EITHER (A) OR (B),
(A) DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO
FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS
ATTACHED:
(B)
DATE PLAINTIFF'S WAIVER OF NOTICE IN 3301 (c) DIVORCE WAS
FILED WITH THE PROTHONOTARY: APRIL 24,2002,
DATE DEFENDANT'S WAIVER OF NOTICE IN.,Z301 (C) DIVORCE WAS FILED
WITH THE PROTHONOTARY: APRIL 15, 2S.o2.
SAIDIS
SHUFF, FLOWER
& LINDSAY
AITORNEYS'AT'LAW
26 W, High Street
Carlisle, P A
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MARY M, MEDKEFF-ROSE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- 3"11--+ CIVIL TERM
BRIAN N. MEDKEFF-ROSE,
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 at the
Cumberland County Courthouse, Carlisle, PA 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
Telephone: (717) 249-3166
fl\div\MEDKEFF-ROSE.com\6-01
MARY M. MEDKEFF-ROSE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ()I~ 3,,//'7 C~ ~-
BRIAN N. MEDKEFF-ROSE,
Defendant
CIVIL ACTION LAW
IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is MARY M. MEDKEFF-ROSE, an
adult individual, who currently resides at 4702-B Charles Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. The Defendant in this action is BRIAN N. MEDKEFF-ROSE, an
adult individual, who currently resides at 340 Charles Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on March 13, 1982, in Delaware, Ohio.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
-1-
6. The Plaintiff avers as the grounds upon which this action lS
based is that the marriage between the parties hereto is
irretrievably broken.
7. The Plaintiff avers that two (2) children have been born of
this marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of di-
vorce.
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 P.C.S. ~4904, relating to unsworn falsification
to authorities.
Date :~l it\ 0 \
, 1'1:\ ViV\ v~.1z
~. MEDKEFF- BE
/
STONE LaFAVER & HEKLETSKI
~
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H B Sr6NE
r);.-/ID #60251
treet, P.O. Box E
and, PA 17070
717-774-7435
for Plaintiff
-2-
SAIDIS
SHUFF, FLOWER
& LINDSAY
AITORNEYSeATeLA W
26 W. High Street
Carlisle, P A
MARY M. MEDKEFF-ROSE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3717 CIVIL TERM
VS.
II BRIAN N. MEDKEFF-ROSE,
DEFENDANT
II
II
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I
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IN DIVORCE
AFFIDAVIT OF CONSENT
1. A COMPLAINT IN DIVORCE UNDER ~3301 (C) OF THE DIVORCE CODE WAS FILED ON
JUNE 1, 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 IN 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 TO
THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA,C.S. 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES.
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26 W. High Street
Carlisle, P A
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MARY M. MEDKEFF-ROSE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3717 CIVIL TERM
VS.
BRIAN N. MEDKEFF-ROSE,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~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 I 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 TO
THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES.
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SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT'LAW
26 W. High Street
Carlisle, P A
MARY M. MEDKEFF-ROSE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3717 CIVIL TERM
VS.
BRIAN N. MEDKEFF-ROSE,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A COMPLAINT IN DIVORCE UNDER ~3301 (C) OF THE DIVORCE CODE WAS FILED ON
JUNE 1, 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 IN 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 TO
THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. 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~M~K~T
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SAIDIS
SHUFF, FLOWER
& LINDSAY
AITORNEYS'AT'LAW
26 W, High Street
Carlisle, P A
MARY M. MEDKEFF-ROSE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3717 CIVIL TERM
VS.
BRIAN N. MEDKEFF-ROSE,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301 ee) 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 I 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 TO
THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES.
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BRIAN N. MEDKEFF-ROS , DEFENDANT
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fl Idivllmailsrv, aff
MARY M. MEDKEFF-ROSE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-3717 CIVIL TERM
BRIAN N. MEDKEFF-ROSE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, Brian N.
Medkeff-Rose, at 340 Charles Road, Mechanicsburg, PA 17050, by United
States Certified Mail, postage prepaid, restricte? delivery, on June
/
22, 2001, as evidenced by the attached Certifi d Mail return
r"-~-" NOTARIAL. SeAL
; I<AYE R. LUCKEY. Notary Public
I New Cumberland Bora. Cumberland Co.
1 ?Irf Commission ~ires March 27, 2005
c________
SWORN TO AND SUBSCRIBED
befo e me this .:?L:,</II day
of , 2001.
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Certified Fee
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Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Postmark
Here
Total Postage & Fees $
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ru
ru Name (Please PrInt Clearly) (To be oompleted by mailer)
ITI Mr. Brian N. Medkeff-Rose
si;;;ei;A;ji.-;.;o:;-o;-jiosoicNO'..-..-.---.-------.-------------- .,-...-..-................,
~ 340 Charles Road
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SHUFF, FLOWER
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ATIORNEYSoAT'LAW
26 W. High Street
Carlisle, P A
II
II
MARY M. MEDKEFF-ROSE,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. 01-3717 CIVIL TERM
vs.
BRIAN N. MEDKEFF-ROSE,
DEFENDANT
: IN DIVORCE
AFFIDAVIT UNDER ~ 3301(0) OF
THE DIVORCE CODE
1 . The Parties to this action separated in October, 1994 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, lawyer's fees or expenses if I do not claim them before a divorce is granted.
VERIFICATION
I, the undersigned, hereby verify that the statements made herein 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.
~ a /7Vd~Z
Brian N, Medkeff-Ros
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fl\div\1,countr,Old\7'1'97
MARY M. MEDKEFF-ROSE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-3717 - CIVIL TERM
BRIAN N. MEDKEFF-ROSE,
Defendant
CIVIL ACTION - IN DIVORCE
COUNTER-AFFIDAVIT
UNDER ~ 3301(d) OF
THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
x
(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 years.
x (ii) The marriage is not irretrievably broken.
2, Check either (a) or (b):
(a) I do not wish to make any claims for economlC 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.
--1--'-
'.
X (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 delay.
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, ~ 4904 relating to unsworn
~J ~~~~
Date
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falsification to authorities.
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.
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