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Home My WebLink About01-3951 . . ~ 'Z /f/~ ~yt(, ('c?- ~. 'I (J?}1/ ~ ~ ~'rP t:'v?1 ------ ---- - STACY LUBESKIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-3951 Defendant. CIVIL ACTION - LAW IN DIVORCE GARY LUBESKIE, PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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 Complaint: A Complaint in Divorce was filed on June 26, 2001, and served on Defendant on July 5, 2001 via certified mail, return receipt requested. Affidavit of Service has been filed. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) ofthe Divorce Code: Plaintiff - October 30, 2001 and filed on November 14, 2001 Defendant - May 23, 2002 and filed on May 30, 2002 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: nla (2) Date of service of the plaintiffs affidavit upon the defendant: nla 4. Complete the appropriate paragraphs: Document #: 218115.1 (a) Related claims pending: none (b) Claims withdrawn: none (c) Claims settled by agreement of the parties: N/ A (d) State whether any written agreement is to be incorporated into the Divorce Decree. None. 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code: nla (b) Date plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the prothonotary: November 14,2001 Date defendant's Waiver of Notice in S3301(c) Divorce was filed with the prothonotary: May 30, 2002 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ;:Jut()~ ~CZ?~ Karl R. Hildabrand, Esquire LD. No. 30102 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 2181 I 5, I STACY LUBESKIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-3951 GARY LUBESKIE, Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 2-'1 ~f May, 2002 I, Karl R. Hildabrand, Esquire, of Metzger, Wickersham, Knauss & Erb, attorneys for Plaintiff, Stacy Lubeskie, hereby certifY that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Gary Lubeskie 88 Autumn Lane Enola, P A 17025 ~KE~SHAM' KNAUSS & ERB, P.C. B. ~~,~ ~ Karl R. Hildabrand ~ Document #: 218115,1 o N o c: c) C<) :~) .1 ,--~ : ~ ~ ,/ ) c::::' .---', ~ , I =-:t .~'::: ~ ;.;. 'J) -< ,.t) ~ 3 STACY LUBESKIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Of - 29S' / Ci(A. 't~ GARY LUBESKIE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO: Gary Lubeskie 88 Autumn Lane Enola, P A 17025 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 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, One Courthouse Square, Carlisle, Pennsylvania. 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, P A 17013 (800) 990-9108 Document #: 209165,1 STACY LUBESKIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0/- 395'/ ~ I~ v. GARY LUBESKIE, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE I. The Plaintiff is Stacy Lubeskie, an adult individual currently residing at P.O. Box 451, Mechanicsburg, Cumberland County, Pennsylvania, since June, 2001. 2. The Defendant is Gary Lubeskie, an adult individual who currently resides at 88 Autumn Lane, Enola, Cumberland County, Pennsylvania, since 1998. 3. The Defendant has been a bona fide resident in the Commonwealth of Pennsy lvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 23, 1998, In Shamokin, Northumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties. 7. 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. 8. No children were born of the marriage. 9. The marriage is irretrievably broken. Document #: 209165.1 ." 10. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiffrequests that this Court enter a Decree in Divorce, and enter such other orders as are appropriate. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ~/~~~ p? Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 P.O. Box 5300 3211 North Front Street Harrisburg, P A 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: (. - Z 1 ~O' Document #: 209165.1 VERIFICATION I, Stacy N. Lubeskie, hereby 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.A. S4904 relating to unsworn falsification to authorities. ~~~~stjlzRk~L StacyN. Lu skie Date (0 -I~ l) \ Document #: 208888.1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STACY LUBESKIE, v. NO. 01-3951 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE GARY LUBESKIE, AFFIDAVIT OF SERVICE I, Karl R. Hildabrand, Esquire, counsel for Plaintiff, Stacy Lubeskie, hereby certifY that a true and correct copy of the Complaint in Divorce was served upon Defendant, Gary Lubeskie, by certified mail, return receipt requested, on July 5, 2001, at 88 Autumn Lane, Enola, P A, 17025. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is the signed return receipt card for said service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. BY~<(?~~~~ - ~ Karl R. Hildabrand, Esquire Attorney LD. No. 30102 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: ?/l9/o/ ( I Document #: 210614.1 (Xh,blt A .. 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: D. Is d ery address different from item 1? If YES. enter delivery address below: o Agent o Addressee DYes o No Gary Lubeskie 88 Autumn Lane Enola, PA 17025 3. Service Type EX Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C,O.D. 4, Restricted Delivery? (Extra Fee) DYes 2. Article Number (Copy from service labelj 7099 3400 0016 0532 8742 PS Form 3811 , July 1999 Domestic Return Receipt 102595-00,M-0952 ?-1 ~ a ~ ~ ~ c~ ,,'. " STACYLUBESKIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01-3951 GARY LUBESKIE, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 26, 2001, and served upon Defendant on July 5, 2001. An Affidavit of Service was filed on July 23, 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. ~ 4904 relating to unsworn falsification to authorities. Date: /(>/3(\10 I , ~Ptac~~&~~ Stacy Lube . e Document #: 218112.1 C> ..--- "z.. o c:.. --.---....'---.- o c: -".. -u6; 1"1' f'; -:-/ .'\. ~;~I C2C) ,?c .......c ';P c: :z:. :< - -F- tv 1)''- ~ '1:> ) o ~ ..-. ~ o ""'}"l - .,.. N >;.11 U' r STACYLUBESKIE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 01-3951 GARY LUBESKIE, Defendant CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl 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. S 4904 relating to unsworn falsification to authorities. Dated: /0 {50 J G I . JJ/-<-CL Document #: 218114.1 (:) n c <: -0 fi:' n'E' Z...._ Z[~:~ cn~.. ~..:'- kG ~--, zb >c: z =2 C: o < + f\J .. V\ V\ .";) ) a c. . ~--f ...,... a <: .[:- -0 .......;b... r:.~ U1 (J') STACY LUBESKIE, Plaintiff v. GARY LUBESKIE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 01-3951 Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 26,2001, and served upon Defendant on July 5, 2001. An Affidavit of Service was filed on July 23,2001. 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. S 4904 relating to unsworn falsification to authorities. OJ- Document #: 218112.1 o ('.l ~ ~ ~ A ~ ~ :~:; c') I...,;. --.1'1 - .::-~ . ", ....,c...J (::':'.~t ,. ) --'-j .. () STACY LUBESKIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3951 GARY LUBESKIE, Defendant CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER ~ 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a fmal 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. 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. Dated: S- I ~:) / 0 ~ I f Document #: 218114.1 ~ ~ 5 -.....-- _._------~