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HomeMy WebLinkAbout06-5317 ,. , RONALD E. SNOOK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : Civil Action Law : No. 06 - 5""3 i 7 Civil Term DEBORAH A. SNOOK, Defendant : 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 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's Office, Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania. 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 Lawyer Referral Service 32 S. Bedford Street Carlisle,PA 17013 (717) 249-3166 .," '" RONALD E. SNOOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. Civil Action Law No. 06 ...~3 rJ Civil Term DEBORAH A. SNOOK, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Ronald E. Snook, an adult individual who is sui juris and resides at 34 Creekside Drive, Enola, Cumberland County, Pennsylvania, since August 2006. 2. Defendant isDeborah A. Snook, an adult individual who is sui juris and resides at 205 Mt. Hebran Road, Mt. Wolf, York County, Pennsylvania since April 2001. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 28, 2001 at Mt. Wolf, York County, Pennsylvania. . 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Both parties are not members of the Armed Services of the United States or any of its allies. 8. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Allen D. Smith, Es . Attorney for Plaintiff I.D. No. 17029 51 S. Front Street Steelton, PA 17113 717-939-1891 .. 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. Section 4904, relating to unsworn falsification to authorities. ~~r~ Plaintiff Date:cy,~b>' (") '" ~ r,:.~ C:~ c> ~ C"::> c:;r. -n ~ 0 - U) :t:JJ ~ ""-C:) r~"1 ~ -0 n'r=- ~ -0 rr~ Cl(\ ~ ~ N \;~~ ,.:., -- .....,..., v -.S -........\ :J;~ -.... ;, ~l; ~.~ ~ -c:.. ~ ~,) ~ ::--1 '" N :S ~ + :..-< ~ -. RONALD E. SNOOK, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION v. : NO.06-5317 DEBORAH A. SNOOK, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Allen D. Smith, Esq., the undersigned, do hereby certify that I served a true and correct copy ofthe Complaint in the above captioned Divorce upon the Defendant, Deborah A. Snook, by placing the same in the U.S. Mail, postage prepaid, restricted delivery, addressed to P. O. Box 159, Mt. Wolf, PA 17347. The Defendant received the Complaint on September 19,2006, as is indicated by the postal receipt No. 7099322000669048791, attached hereto and marked exhibit "A". (1-/ ,ft~i I { ~fl/ Allen D. Smith, Esq. P. O. Box 7592 Steelton, P A 17113 Telephone (717) 939-1891 Date: Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. rticle Addressed to: eborah A. Snook . O. Box 159 ~t. Wolf, PA 17347 ~. ,.f 3. Service Type ~ Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (Copy from service label) 7099 3220 0006 6904 8791 PS Form 3811, July 1999 Domestic Return Receipt 102S9S-00-M-09S2 EXHIBIT "A" RONALD E. SNOOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. Civil Action Law No. 06-5317 Civil Ternl DEBORAH A. SNOOK, Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on September 12,2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. J. I consent to the entry of a final decree of divorce after service of notice of intention to request cntry of the decree. I veri fy that the statements made in this affidavit are true and correct. r understand that false statements herein are made subject to the penalties of 18 PaC.S. Section 4904 relating to unsworn fa Isi fication to authorities. Oate: j1l:. t4 1-..... " I =~f~ Plai nti ff --------- - ----- ---- (') c: -- I"'--' c::> = c"f"'\ o .1 -l :C-n rn= 1lt~J \:.~:S c:' o r-tj C) (j1 t""~ (.;, : "-~) :l< .., ' ;::;r1"'\ ~j ::0 -< - RONALD E. SNOOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. Civil Action Law No. 06-5317 Civil Term DEBORAH A. SNOOK, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on September 12,2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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 PaC.s. Section 4904 relating to unsworn falsification to authorities. r- -'"] 4 6 Date: ./~ / . Z C:P - \ o \~;. t-') c;; cO> cr.... o C"f~t kC'~) -- <5' q; 9-41 \;~ ~: ':\"-\'~:j t~:~\:o~ ;-":~-\:. ~ ~ ~,~ :Z -0 ~ . ~_.... -- o ~n RONALD E. SNOOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. Civil Action Law No. 06-5317 Civil Term DEBORAH A. SNOOK, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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! 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 PaCS Section 4904 relating to unsworn falsification to authorities. Date: VJt.. (4 t- i).,15 . '/..-.-J.d ( ~ Plaintiff ".._w_' Q ~-;~ r-.;) ~~ c....... o -n ::;:l '...-n ~j0Jl ~i~ ;f~ -:~, rl'l ~ c'O :< o !T] C-) U'j -0 _.".'~ --",,;.0. o ('J~ --------- ----- RONALD E. SNOOK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. Civil Action Law No. 06-5317 Civil Term DEBORAH A. SNOOK, Defendant IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DNORCE DECREE UNDER SECTION 330l(c) OF THE DNORCE 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! 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 PaCS Section 4904 relating to unsworn falsification to authorities. -J ) 4- 1.:>'-' 6 Date~_l .. tic I ........:> c-::> C:;,:J c-, C7 r"'(' ~ (........) c: -0 C) en IN THE COURT OF COMMON PLEAS RONALD E. SNOOK, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION DEBORAH A. SNOOK, Defendant NO. 06-5317 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. Ground for divorce: Irretrievable breakdown under 93301 (c) 38m~t)Cof the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: September 19, 2006 Certified Mail Return Receipt 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff December 14, 2006 ; by defendant December 14, 2006 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: No claims pending 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: (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: December 15 2006 Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: December 15. 2006 (717) 939-1891 ~fO'c1P~ Allen D. Smith, Esq. ;",0 o - 0- en U- o r-' uJ o ...p c..? ~ (;--.1 --------- --.-------------.------- IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF RONALD E. SNOOK, Plaintiff VERSUS DEBORAH A. SNOOK. Defendant AND NOW, DECREED THAT AND No. 06-5317 DECREE IN DIVORCE DECEMBER '4 , --2.Q.Q.6._, IT I S ORDER ED AN 0 RONALD E. SNOOK , PLAI NTI FF, DEBORAH A. SNOOK , 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; \lJo t\.Q ~~~~~~~~~~~~~~~~~~~~ By THE ATTEST: J. {l~PRO~ONOTARY ~2'. ? d'J r'?J11V;!7Vyt /J?1w'Y ,p:r 'l' 71 -r ,I-, 7~ ~J'.~ /tf}'V'k &-tV IV;; ~AJ' J(' c/ ?r} . J c ' ('/ .. .