HomeMy WebLinkAbout06-3595
.
JULIE A. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Defendant
: CIVIL ACTION - LAW
~NO.((.,- 3vQS
: IN DIVORCE
CIVIL TERM
v.
DALE G. COHICK,
NOTICE
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 Court House, High and Hanover Streets, Carlisle.
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
32 South Bedford Street
Carlisle, P A 17013
Phone: (717) 249-3166
.
.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JULIE A. COHICK,
Defendant
: CIVIL ACTION - LAW
~ NO. 0(, .3595'
: IN DIVORCE
CIVIL TERM
v.
DALE G. COHICK,
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
I. Plaintiff is Julie A. Cohick, who currently resides at 427 Steelstown Road, Newville,
Cumberland County, Pennsylvania, 17241 since July 2005.
2. Defendant is Dale G. Cohick, who currently resides at 80 Potato Road, Apt. 9, Carlisle,
Cumberland County, Pennsylvania, 17013 since August 2004.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least
six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on May 9, 1981, at Newburg, Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in this
or any other jurisdiction.
6. The marriage is irretrievably broken.
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. Plaintiff requests the Court to enter 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. ~ 4904, relating to unsworn
falsification to authorities.
Date:
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ANDREWS & JOHNSON
By:
son, Esquire
Attorney fo laintiff
78 W. Pomfret Street
Carlisle, P A 17013
(717) 243-0123
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roUE A. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CNIL ACTION - LAW
DALE G. COHICK,
Defendant
: NO. 06-3595
: IN DIVORCE
CIVIL TERM
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYL VANIA )
COUNTY OF CUMBERLAND )
AND NOW, this 11 th day of July 2006, I, Ronald E. Johnson, Esquire, attorney for Julie A. Cohick,
Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in
Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter,
upon the Defendant at his residence at 80 Potato Road, Apt. B, Carlisle, P A 17013, by depositing the same in
the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the
return receipt card signed by the Defendant on July 6, 2006, indicating service was effected, is marked
Exhibit "A", attached hereto and made a part hereof.
ANDREWS & JOHNSON
By:
Sworn and subscribed to before me this
1_'1-H1 day of July 200
NOTARIAL SEAL
SHELLY SEXTON, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires April 26, 2007
t
. Complete Items 1, 2.snd 3. Also complete
item 4 If Restricted Delivery is desired.
. Print yOUr name and ack:\resSon the reverse
so that we can retum the card to you.
. Attach this card to the back of the mailpiece.
or on the front if space permits.
1. Arti~ Addressed to:
Dr,le G. Cohick
80 Potato Road
Apt B
Carlisle, P~ 17013
2. Article Number
(T'ransfer from service label)
PS Form 3811. February 2004
3. Service Type
'1lf. Certified Mall 0 Express Mail
o Registered JI5..fletum Receipt for Merchandise
o Insured Mall 0 C.O.D.
4. Restricted Delivery? (Extra Fee) Yes
7005 2570 0000 3796 3554
Domestic Return Receipt
102595-02-M-1540
Exhibit A
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Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
JULIE A. COHICK,
v.
: CIVIL ACTION - LA W
Defendant
: NO. 06-3595
: IN DIVORCE
CIVIL TERM
DALE G. COHICK,
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 23,
2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing 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: / /-dtJ--c:ltftf ~
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Ie A. Cohlck, Plainttff
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JULIE A. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
DALE G. COHICK,
Defendant
: NO. 06-3595
: IN DIVORCE
CIVIL TERM
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER fi 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. 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: / I ~~c}t)J~
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JULIE A. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
DALE G. COHICK,
Defendant
: NO. 06-3595
: IN DIVORCE
CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 23,
2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing 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.
Date: f/ t '1107
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Dale G. Cohick, Defendant
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JULIE A. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
DALE G. COHICK,
Defendant
: NO. 06-3595
: IN DIVORCE
CIVIL TERM
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. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn
falsification to authorities.
Date: ~l 07
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Dale G. Cohick, Defendant
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JULIE A. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LA W
DALE G. COHICK,
Defendant
: NO. 06-3595
: IN DIVORCE
CIVIL TERM
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.
2
receipt.
3.
Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code.
Date and manner of service of the complaint: Julv 6, 2006 bv Restricted, certified mail, return
Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce
Code: by the Plaintiff November 20, 2006; by Defendant January 19. 2007.
4. Related claims pending: None.
5. Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary:
Ft!#/l/cJ'Y r
J8tHitU, J 1, 2007.
Date Defendant's Waiver of Notice In S3301(c) Divorce was filed with the
Prothonotary: ~~:f~~.
ANDREWS & JOHNSON
Date: January 31, 2007
Ronald E. Johnso, q.
78 West Pomfret eet
Carlisle, PA 17013
(717) 243-0123
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IN THE COURT OF COMMON PLEAS
OFCUM8ERLANDCOUNTY
JULIE A. COHICK
PENNA.
STATE OF
Plaintiff
06-3595
No.
VERSUS
DALE G. COHICK
Defendant
DECREE IN
DIVORCE
AND NOW,
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~o7, IT IS ORDERED AND
Julie A. Cohick
DECREED THAT
, P LA I NT IFF,
Dale G. Cohick
AND
, DEFENDANT,
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
B
PROTHONOTARY
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