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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: fo - /' ~ c:1 c:Jlt? ~ ~c.c ANDREWS & JOHNSON By: son, Esquire Attorney fo laintiff 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 ~~~ ;J ~ u., ~ ~J "" -... ~ () ~ . ,--") '7' ;[; ... ;--.) W p..,) r"--_) t,::J t 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 ~ .~ "';.', " .. G) (,. ...~". - 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 ~ rJf~NI ~~~ Ie A. Cohlck, Plainttff o ~ ;:,:'~- r;5 = c;;f" o l"i ('J - o 11 -4 ::;::-n plf'.: m :~};~ ".-- ~~~p" '::~\ ~ ...0 -0 ~.. -- - o f'J 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~ . a ~ 0 = S (::::.;> 11 (.;:::i',", <,- c::J rrl ("') \.0 -0 -",~ - ,. c..-::; fv 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 ~ Dale G. Cohick, Defendant ;~~) --.'1 ~ F'T , t::~J .-\ i';i ! 01 f',) (......, C', .---.."" ~....~._~".~- 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 ~ Dale G. Cohick, Defendant r-. : :::1 w ;;1 ! eli ~:';:J f'~'" ) c,.~ ---.-.. 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 By: ~r1 ;:':.~ ~! t.-,'::': ,-Ii -,-1 cr; r:3 ,_ '.J c:; "':+i :f. '" "':+i :+i :f.:f. '" '" l+i 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, Fb~--r 1 c::t' II. .)oA ~ · ~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 :+: :f. :+::+: :f.:+i:+i :+ifF.:f. '" :f. :f. :+i :f.:f. :f. J. ~ :!r? "tJ':'" ~ ai- #' e ~ p?l ...,~w /Jt,;.,..,-J /..~. /;. e .. i . . ~.. .'" 'lI(' ,;.. ,,: ~~ .,,, ~