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Home My WebLink About02-2166KEVIN HOWARD LINCOURT, Plaintiff TAMMIE JO LINCOURT, Defendant : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02- ,,~t/~(,,, CIVIL TERM : 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 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 divome 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 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 KEVIN HOWARD LINCOURT, Plaintiff TAMMIE JO LINCOURT, Defendant : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02- ,,,~l&~ CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kevin Howard Lincourt, who currently resides at 540 3rd Street, West Fairview, Cumberland County, Pennsylvania, 17025.. 2. Defendant is Tammie Jo Lincourt, who currently resides at PO Box 1631, Bear, Delaware, 19701. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 18, 1988, in Harrisburg, Dauphin 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. Plaintiffhas 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. Date: By: Paul Bradford (Serf is~quire Attorney for Plainti 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID: 71786 VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. DATE: Kevin Howard Lincourt KEVIN HOWARD LINCOURT, Plaintiff TAMME JO LINCOURT, Defendant : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02- 2166 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : COUNTY OF ) AND NOW, this 28~ day of May, 2002, I Paul Bradford Orr, Esquire, attorney for Kevin Howard Lincourt, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed by the Defendant on May 7, 2002 indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. LAW By: Paul Bradfor~ (~rr, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 I.D. # 71786 · Complete~tems 1, ~, and 3. ~ complete Rem 4 if Reetflcted Deliver/L~ deelred. · p~ your name and acldmes on the revere so that we can return the card to you. · Atta~'th~ card to the baok of the mallPlece, or on the Worn if ~pace permits. A. Rece~d by (~s~e Pr~nt C~mnY) [] Irmumd Ivleil 0 C.O.D. 2. ,cuticle.umber 7~ 7o oao, 4. Restricted Oe~lve~ ~ Fee) r=l Ye~ ps Fomn 3~11, Mamh 2001 Oomeeac nmum neee~ EXHIBIT "A" KEVIN HOWARD IJNCOURT, Plaintiff' TAMMIEJO I,INCOURT, Dcfendaa~t : IN THE COURT OF COMMON PI,EAS OF : CIJMBERI2~ND COUNTY, PENNSYLVANIA : : CIVIl, ACTION - lAW : : NO. 02-2166 CIVIl, TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 3, 2002. 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: Kevin Howard Lincourt, Plaintiff KEVIN HOWARD I.INCOURT, Plaintiff TAMMIEJO I.INCOURT, Dcl'endant : IN THE COURT OF COMMON PI,EAS OF : CUMBERI~kND COUNTY, PENNSYI,VANIA : : CIVIL ACTION - lAW : : NO. 02-'2166 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) OF THE DIVORCE CODE 1. I consent to file cntry ofa linal decree of divorce without notice. 2. I undcrstm~d that I may lose rights concerning alimony, division of property, lawyer's ti:cs tlr expenses if I do not claim flmm before a divoree is granlcd. 3. I understand that I will not be divorced until a divorce dccrec is entered by tile Court and that a copy ot' tim dccrec will be sent to me immediately aftcr it is tiled wifl~ tile Profllonotary. I verity, fltat file statements made in this Mlidavit are true mul correct. I understvmd lhat 13risc statements herein arc made subject to the penalties of 18 Pa. C.S. §4904, relafingto unswom lhlsilication to amhorifics. Kevin Howard Lincourl, Plaintiff KEVIN HOWARD LINCOURT, Plaintiff V. TAMMIE JO LINCOURT, Defendant : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-2166 CIVIL TERM : IN DIVORCE 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 ofpruperty, lawyer,s fees or expenses ifI 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 thc 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. +arrmlie Jo Li,n~ur~cD~e~endant "-' ~ KEVIN HOWARD LINCOURT, Plaintiff TAMMIE JO LINCOURT, Defendant : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-2166 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 3, 2002. 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 f'mal 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. ( t Tammie Jo Linc~",~D~t~-~nt - ~ ~ KEVIN HOWARD LINCOURT, Plaintiff TAMMIE JO I,INCOURT, : IN THE COURT OF COMMON PLF2kS OF CUMBERLAND COUN 1 Y, PENNSYLVANIA CIVIL ACTION - lAW : : NO. 02-2166 CIVIL TERM PRAECIPE TO TRANSMIT RECORlr} TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce Ground for divorce: irretrievable breakdown under Section 330 l(c) of the Divorce Code. Date and manner of service of the complaint: May 7, 2002 by certified mail. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff February 26, 2004; by Defendant February 17, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 26, 2004. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 26, 2004. Date: Resp~y S ¢ By: ~' Paul Bradford Or ~ Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 aire Supreme Court ID # 7 2L 7 8 6 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Kevin Howard Lincourt Plaintiff VERSUS Tammie Jo Lincourt Defendant NO. 02-2166 DECREE IN DIVORCE AND NOW, , 2/~<~/'I , IT IS ORDERED AND DECREED THAT Kevin Howard Lincourt PLAINTIFF, AND Tammie Jo Lincourt , 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;