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Home My WebLink About06-5121 o . LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney LD. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, P A 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Kelly Marie Cook KELLY MARIE COOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2006 - .rl ~ f Civil Term TIMOTHY JASON COOK, 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 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 of Cumberland County, One Courthouse Square, 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 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 1-800-990-9108 . KELLY MARIE COOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, 2006 - is 1:2 1 Civil Term TIMOTHY JASON COOK, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is Kelly Marie Cook, an adult individual whose current address IS 4580 Creekview Road, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose social security number is 194-60-1971, 2. The Defendant, Timothy Jason Cook, is an adult individual, whose current address is 4218 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose social security number is 400-31-7756. 3. Plaintiff and Defendant were married on October 13, 2000, III Mechanicsburg, Cumberland County, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. . 9. There is one minor child born to the parties; namely: Ian Garret Cook, born November 18, 1999. 10. Plaintiff avers that the grounds on which this action IS based are: (a) That the marriage is irretrievably broken; and (b) That the parties have lived separate and apart for a period of at least two (2) years, said date of separation being May 2004. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. B iane M. Dils, squire 1400 North Second Street First Floor, Front Harrisburg, P A 17102 (717) 232-9724 J.D. No. 71873 Dato (jlO)O~ .. VERIFICA TION I verify that the statements made in this Complaint in Divorce Under Section 3301(c) of the Divorce Code 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. ,...~ ~~~t~ f/1(H7~C (~ KELLY MA E COOK ''"' / I Date: JjSo/~ (., - . ~ "'69- ~ - l. ~ 0 ...., 0 . C~ C = "T1 ~ ~ :;c:~ "'"' I~; , :r>' ~-n -- r.::: rne ~ - G-) ~ ~ (...:> -0 i11 ~ ~_r)O ~ () .1.... '-::"'1LJ .-,.~ -,-, -", ;:'')::.1 ..-;.;.. ;,,- C-, c.... cj"" 0) -.J ~ ~ U1 'u ~ '< to KELLY MARIE COOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 2006 - .s1 J..! Civil Term TIMOTHY JASON COOK, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served upon you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in May 2004, 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! do not claim them before a divorce is granted. 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. K~~~~i~:t! ~l2i&f (rrL- Date: F' /..:Jo /0 ~ (') c- "}I~ Q1rI,.; ",,='.', .?C .." -,- r <::;:....' )>c :~2_3 ~ " ~ S' CJJ .l:'" '" "'" ~ :x>. ~ W o .." I~;:n :nh; .no 0(1 .::~ -71 ,....,"71 ;;::(') olr) ;:-1 <"" ,J;) -< - RECEIVED II ,/ I.. b ~ ~ q,JJ-O LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, P A 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Kelly Marie Cook KELLY MARIE COOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 2006 - 5121 Civil Term TIMOTHY JASON COOK, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Patrick W. Quinn, Esquire, hereby accept service of the Complaint in Divorce Under Section 330 I (d) of the Divorce Code and Affidavit Under Section 3301 (d) of the Divorce Code on behalf of Timothy Jason Cook, the Defendant, on the _ J:1 ~__ day of ~aptan"'J..",- "O"t:: J~ ~~ lU"'l .t..vvv. nn, Esquire ,LLC 47 West Hi Street Gettysburg, P A 17325 I.D. No.~ DATE: q~ (1.oCo ~ ~ --tJ cr:" \::s; ~",: 1::; \ (() .,' ~,~ S'~ ~ ~ <A --0 ~ ..-0 ~ ~;;; \:.) .~., c' Y ';t: :2. ~ ~e .-o~ ~9.1.- ,,,)\0 ,::'{:. ::;; <1(1 /~\,f\ <3 -z. .:2. <P . . o o ... ... KELL Y MARIE COOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. No. 2006 - 5121 Civil Term TIMOTHY JASON COOK, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE TO: Timothy Jason Cook c/o Patrick W. Quinn, Esquire Wolfe & Rice, LLC 47 West High Street Gettysburg, P A 17325 You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to the Plaintiff s affidavit. Therefore, on or about November 1, 2006, the Plaintiff can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date, or the Court may grant the divorce and you will lose forever the right to ask for economic relief. .. A counter-affidavit which you may file with the Prothonotary of the Court is attached to this notice. 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. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, Pa. 17101 (717) 232-7536 DATED: October 11,2006 KELL Y MARIE COOK , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2006 - 5121 Civil Term TIMOTHY JASON COOK, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I opposed 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. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic 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. . (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. 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. Date: Timothy Jason Cook 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 need not file this counter affidavit. Q ~;7 r--:> = c.::> 0"' ~ ~ I en o -r1 .-{ ;n:c- 'c:. :~5~' ~ -~~ -""'" ~-~Fi\ u --' .,~ ~b =-< co 'I KELL Y MARIE COOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 2006-5121 Civil Term TIMOTHY JASON COOK, Defendant CIVIL ACTION - LAW 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: Irretrievably broken under Section () 3301(c) or (X) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By Acceptance of Service on September 19, 2006. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, N/A; by Defendant, N/A. (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: 8/30/06; Date of service of Plaintiffs affidavit upon Defendant: Acceptance of Service on September 19, 2006. 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: October 11, 2006. 5. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff: N/A; by Defendant: N/A. 6. Related Claims Pending: None Respectfully submitted, B/;~~ 4)L Diane M. Dils, Esquire 1400 N. Second Streetet Harrisburg, P A 17102 (717) 232-9724 I.D. No. 71873 Date: November 3,2006 ......., ('2'::::; c::") cr- ,.-) ~ I 0') --::;1 ---,..,? CJ ~~ .< "'''''''''' "'''''''''''''''' '" '" '" "''''''' "'''' "'''''''''''''''''''~''''''''' "'~~~"''''~''''''''''''~'''''''''''''''''''''''''''''''''''''''''''''''''''''' :Il IN THE COURT OF COMMON PLEAS '" OF CUMBERLAND COUNTY STATE OF KELLY MARIE COOK VERSUS TIMOTHY JASON COOK PENNA. No. 2006-5121 DECREE IN DIVORCE ~ AND NOW, ~()~f.~\\t.l DECREED THAT AND TIMOTHY JASON COOK 2006 , IT IS ORDERED AND KELLY MARIE COOK , PLAI NTI FF, , 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; :Il '" '" NONE BYTH~O~ ~\ ATTEST: . \ PROTHONOTARY '" "'''' "''''''''''''' "''''''''''''''''''' ~"'''''''''' "'~"'~"''''''''''~~''''''''''''''''''''' '" ~ '" '''If. '" !IJ !IJ '" ff. !IJ '" if. if. if. '" if. '" J. ff. if. if. ff. ff. '" '" ff. '" if. if. ff. if. ff. if. if. if. '" '" ff. '" if. ff. '" !IJ ff. if. ff. if. ff. if. ff. '" if. '" '" ,.;T. ~ ,c" ? ~~;t-. IJ(}? -1/ . L"TfV ~.;t /u 0'1J "10' c.t ,/I r6 71' - f{ /"V > wtlti'v r f/ /