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Home My WebLink About06-4443r HAROLD S. IRMIIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17015 (717) 242$090 ATTORNEY FOR PLAINTIFF JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. I CIVIL ACTION - LAW :NO. 2006 - .? CIVIL TERM PAMELA R. MOCK, Defendant : IN DIVORCE 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 in 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2006 - gY-13 CIVIL TERM PAMELA R. MOCK, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is JOHN B. MOCK, an adult individual residing AT 116 North Hanover Street, Apartment 4, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is PAMELA R. MOCK, an adult individual residing at 56 Southeast First Avenue, Apartment No. 206, Ocala, Florida 34478. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on October 18, 1998, in Beaver County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. /x.LG4?iJ 7? ZG61. ? l?Gli? C JOHN B. MOCK, Plaintiff HAROLD S. IRWIN, II Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2006 - `/VY? CIVIL TERM PAMELA R. MOCK, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. JOH14 B. MOCK, Plaintiff ?\??1??\) -?.. r... ` c'+'?1 1`1 '` ??! .? C? ..a :?, r; ._a fn ?? t,.; c=< C: i JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2006 - 4443 CIVIL TERM PAMELA R. MOCK, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on August 8, 2006, by certified mail addressed to the defendant at 56 SE 1St Avenue, Apartment 206, Ocala, Florida 34478, Certified Mail No. 7005 0390 0003 2637 2717. 3. A copy of the sender's and return receipts are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. November 13, 2006 Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 Y? Track/Confirm - Intranet Item Inquiry Item Number: 7005 0390 0003 2637 2717 This item was delivered on 08/08/2006 at 16:45 Signature: ` ?7? ??%?--?? atrel,a Hbc L Address: ? VW 4 4 r- I 11-10"I - IT IAIL- - - (Domestic Only; Provided) ru For delivery information visit our website at w ww.usps.com, r- m FI CIAL US ru '3(o? $ C3 Certified Fee . Q ? Retum Receipt Fee (EndorsementRequired) Postmark Here O p^ Restricted DeliveryFee (Endorsement Required) 3 5 0 M t:3 Total Postage & Fees V1 0 0 --- ' Iti Sheet, AptWo.; -'---- - or PO Alo.5? 5 4 -- .. ?. - ----- . -- - ---------------- ---- 04, State. Zt ----- ----- ----- EXHIBIT "A" r) r-la 71 --- -77 Li ?? . L Uq CC) JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW PAMELA R. MOCK , : NO. 2006 - 4443 CIVIL TERM Defendant : CIVIL ACTION - LAW AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about Auaust 3. 2006. Service of the complaint was made by certified mail, return receipt requested, on August 8, 2006 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. November, 2006 /41"F114 5. MOCK WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 1 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. 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. November >L, 2006 ?? c?_ = _ -,- ro; -?: - -. ,. =-< . ? .? JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW PAMELA R. MOCK, : NO. 2006 - 4443 CIVIL TERM Defendant : CIVIL ACTION - LAW AFFIDAVIT OF CONSENT A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 3, 2006. Service of the complaint was made by certified mail, return receipt requested, on August 8, 2006 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. November 4-1 , 2006 PAMELA R. /MOCK WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0 OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. /oZyu & 4 November c?/, 2006 PAMELA R. M0 6K CD -n U < - ,Ln HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006 - 4443 CIVIL TERM PAMELA R. MOCK, 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) of the Divorce Code. 2. Date and manner of service of the complaint: On or August 8, 2006 defendant was served with a copy of the divorce complaint by U.S. Mail (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: November 25, 2006 By the defendant: November 21, 2006 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 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: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: November 29, 2006 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: November 29, 200 November 29, 2006 ' HAROLD S. IRWIN, III Attorney for Plaintiff C7?'a• ?. ?? „?. ??,,?? t .... ?? Y r ??. ? ,s-? j C„ ?? ??. ?'' ??. ?y ..G IN THE COURT OF COMMON PLEAS JOHN B. MOCK OF CUMBERLAND COUNTY STATE OF PENNA. No. 2006 - 4443 CIVIL TERM plaintiff VERSUS PAMELA R. MOCK Defendant DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT AND PAMELA R. MOCK JOHN B. MOCK , PLAINTIFF, , 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 PROTHONOTARY lp? - JOHN B. MOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW -NO. 2006 - 4443 PAMELA R. MOCK, : Defendant : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR SURNAME Notice is hereby given that the DEFENDANT in the above matter: prior to the entry of a Final Decree in Divorce, or x after the entry of a Final Decree in Divorce, dated NOVEMBER 29, 2006, hereby elects to resume the prior surname of PAMELA R. ZELJAK and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. Section 704. 4'?' 1 6 ? (SEAL) Signature -PAMELA R. MOCK SEAL) -1,11A f -Z' Signature of Ns(no-d-o" a mod PAMELA R. ZELJAK STATE OF FLORIDA : :SS: COUNTY OF On the day of sft"2008, before me, a notary public, personally appeared the above 7_e affiant, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In witness whereof, I have hereunto set me hand and official s y JASON M MU AN Notary PWk State of Roft No ry P COMMWW DD415830 My oomm. woes June 28, 2005 '0 r? F r CO rs e