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Home My WebLink About06-6084TAMMY L. WOLFE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW TIMOTHY D. WOLFE, NO v? _ Defendant IN DIVORCE NOTICE TO DEFEND 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY ATMW4M-AT-U W 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Carol J. Lindsay,- q Attorney Id. 446 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff TAMMY L. WOLFE, Plaintiff V. TIMOTHY D. WOLFE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 04 • G v f- V C4,;a 7.,c.,,.,. IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Tammy L. Wolfe, an adult individual residing at 602 Woodland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. The Defendant is Timothy D. Wolfe, an adult individual residing at 161 South West Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 1, 1997 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the SAIDIS, FLOWER & LINDSAY AT[ORNEtS•AT.IAW 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance SAIDIS, "NMR & LINDSAY errotwexs.,vuw 26 West High Street Carlisle, PA with §3301 of the Pennsylvania Divorce Code. Dated: /0//71 O b Respectfully submitted, SAIDIS, FLOWER INDSAY Carol J. Lin a Esquire Attorney Id. /4643 26 West H ig %-S#eel Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. mmy L. W Date: 10 -AZ"I?kp SAIMS, FLOWER & LINDSAY nnoxrffvsnruw 26 West High Street Carlisle, PA (? n rII3 s- C=D ca n9 t a rJt _AY .... ?? t two C a V TAMMY L. WOLFE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. b1? - (v08?{ TIMOTHY D. WOLFE, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on October 26, 2006, she served a true and correct copy of the Divorce Compliant upon Timothy D. Wolfe, Defendant, by mailing those documents to the his address at 161 South West Street, Carlisle, PA 17013, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Timothy D. Wolfe. Respectfully submitted, SAI Carol J. Lindsay; Eli Attorney Id. 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY ATIDIMM-ATanw 26 West High Street Carlisle, PA Dated: October 30, 2006 ,Y SAIDIS, FLOWER & LINDSAY .,rrostv?s•.vuw 26 West High Street Carlisle, PA ¦ Complete items 1, 2, and 3. Also complete itern.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 K space permits. 1. Article?Addressed to: "Imp+ht? J. Woi Pe- 5aLL-'L-h tj-)0- 6? Sf . caf l'Sle, IJA (-7o)3 A. Signature X."). -- B. R eared by (Printed Name C. Date of Dehery l012,1 o,b D. Is delivery address different from Rem 1? ? Yes ff YES, enter delivery address below: le No 3. Service Type ? Certified Mail ? Express Mail ? Registered ? Return Receipt for Merctombe ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7D04 135? 0003 7284 7504 (transfer from service label) PS Form 3811, February 2ou Domesdc Return Reoeipt 102506-02-WIS40 ""? =? r = ?^-? ? r --? S r?? ? a ? --, ^,r? r? ? w -- ? ? T 4.'J _?? -? TAMMY L. WOLFE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -- LAW NO. 06-6084 TIMOTHY D. WOLFE, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 18, 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. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to f"N the penalties of 18 Pa.C.S. 4904 relating to unsworn fali*ation to authoritAs. Date: I --altn ammy L. W PLAINTIFF'S 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. 1 understand that I may lose rights concerning alimony, division of property, SAIDIS, Lull-ws" 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsifi Date; I -;? ? /)/I 102020 a pia ? ?»+ts TAMMY L. WOLFE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-6084 TIMOTHY D. WOLFE, : Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 18, 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. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: - ry .: Timothy . Wolfe DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE 1. 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, SAIDIS, FLOWER & LENDS" 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. 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: ?- q., 0 7 Timothy DLANolfe JpA 3 Q ZOQ7 _i - 4 x:: fn TAMMY L. WOLFE, Plaintiff V. TIMOTHY D. WOLFE, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant was serviced with the Divorce Complaint on October 26, 2006, via certified mail. Proof of service was filed with the Court on November 2, 2006. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6084 IN DIVORCE By Plaintiff: January 27, 2007 and filed with Prothonotary on January 31, 2007 By Defendant: January 29, 2007 and filed with Prothonotary on January 31, 2007 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated July 6, 2006 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: January 27, 2007 and filed with Prothonotary on January 31, 2007 By Defendant: January 29, 2007 and filed with Prothonotary on January 31, 2007 SAIDIS, FLOWER & LINDSAY SAMIS FLOWER & UNDS" 26 West High Street Carlisle, PA 10 2? Car ire SupremMsMyy, urt ID No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 ._r:. _??i? ` -, t 7 ,. - ?-n y . ?. ?? ? ?? --? t^..% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TAMMY L. WOLFE VERSUS TIMOTHY D. WOLFE No. 06-6084 DECREE IN DIVORCE AND NOW, `l?'??0?'I'?I ?""? IT IS ORDERED AND TAMMY L. WOLFE DECREED THAT , PLAINTIFF, AND TIMOTHY 1). 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; The terms of the Separation and Property Settlement Agreement dated July 6, 2006 are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: ATTEST: J ' PROTHONOTARY .499 rt TAMMY L. WOLFE, Plaintiff v TIMOTHY D. WOLFE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6084 IN CUSTODY STIPULATION OF THE PARTIES This Stipulation is made this L3 day of & f(/,hSt-,"- , 2009, between TAMMY L. WOLFE, of 602 Woodland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as "Mother" and TIMOTHY D. WOLFE, of 161 South West Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Father." RECITALS: R1. The parties were married, but divorced by Decree of Divorce on February 8, 2007. R2. The parties have a child, Chelsea Wolfe, born April 22, 2000. R3. Pursuant to the parties' Property Settlement and Separation Agreement of July 6, 2006, Chelsea is in the joint legal custody of the parties and in the primary physical custody of Mother. R4. Father pays support for Chelsea pursuant to the Court's Order of May 13, TOWER & LINDSAY ,vmw?vs.,vuw 26 West High Street Carlisle, PA 2009 in the amount of $416.34 per month with an additional $21.67 per month for arrears for a total of $438.01 per month. R5. Father resigned his employment with the Carlisle Area School District and anticipates a three month incarceration commencing December 3, 2009. NOW, THEREFORE, in consideration of the mutual promises contained herein and --rLvJ other good and valuable consideration and intending to be legally bound, the parties agree as follows: 1. Father will pay to Mother for the benefit of the parties' child $ 7 3 /1 Z" " /, 2. Mother accepts said payment in full satisfaction for Father's support the payment set ni it in paragra-ph-1-abmm- obligation for l? months from the date of 3. Upon receipt of the payment, Mother will withdraw her Complaint for Support and will not refile a Complaint for Support for f 9? months from the date of this Agreement. Mother will waive any support arrears which may be owed by Father at the time Mother withdraws her claim for child support. 4. In the event that Father fails or refuses to make the payment set out in SAIDIS, FLOWER & LINDSAY ATr 26 West High Street Carlisle, PA paragraph 1 herein, Mother will have no obligation to withdraw her claim for child support. 5. Mother shall have legal and physical custody of Chelsea Wolf, born April 22, 4f 14t G(?'iil ?e? GCS `E- pavtz?e5 elCk Lr?;Y, 2000 6191 f 'in I-K 6. Father has agreed that Mother may petition the Court of Common Pleas of Cumberland County, Pennsylvania without objection from him to change the last name of the child to Chelsea Patton. Father agrees that Mother may present this Agreement to the Court of Common Pleas of Cumberland County, Pennsylvania as evidence of Father's assent to the name change for Chelsea, 7. The terms of this Agreement may be entered as a Custody Order and also as a Support Order. IN WITNESS WHEREOF, the parties hereto set their hands and seals the date above first written. Witness: - v ammy L. fe mothy D olfe COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss On this, the day of Oe>taAtj-/ , 2009, before me, the undersigned officer personally appeared TAMMY L. WOLFE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BARBARA L STEEL, Notary PWM Carlisle Bore, Cumberland County, PA My Commission Expires June 7, 2011 "FLOWER & LINDSAY ?uw 26 West High Street Carlisle, PA COUNTY OF CUMBERLAND (SEAL) itle of Officer ss On this, the 0 day of 001-Att- , 2009, before me, the undersigned officer personally appeared TIMOTHY D. WOLFE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. (SEAL) Title of Officer NMWAL SEAL E. STEE, Notary Public ARA [BARB rlisle Born, Cumberland County, PA y Commission Expires June 7, 2011 T nr? s'I`71a16 l,'C H 17 Ling i 1 I ? 4 V M i' I OCT 5-1 1s 200961 TAMMY L. WOLFE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-6084 TIMOTHY D. WOLFE, Defendant IN CUSTODY ORDER OF COURT NOW, this 19th day of OC.?4y`i' , 2009, upon consideration of the within Stipulation of the Parties, the terms of the Stipulation are hereby made an Order of Court. By the Court, SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA i,?`` 7t Ir 2009 0C ; 20 0' ' 2 t ??+? ?t7"3 t ?fcS r tit t Cfc 1 a4y L . Li teary 't 7 woL-)E,..,,. 11/03/2009 11:06 7172453820 LISAWC SSI PAGE 02/02 IN TM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff' Vs File No. IN DIVORCE Defendant NOTICE TO RIS PRIOR SURNAMM Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by madang "x" prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated ?, ZL hereby elects to resume the prior surname of ::i?2.1-Aor"1 and gives this written notice avowing his / her intention pursu to the provision f 54 P.S. 7 Date: twc Signal ame being resumed COMMONWEALTH OF?ENNSYLVANIA ) COUNTY OF C.u-b I r wA On the 7 day of / OU ? e r__.,, 200 9 before me, the Prothonotary or the notary public, personally appeared the above affiant known. to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto yet my hand hereunto set my hand and official seal. o`z Not Public SEAL ECARLISLE OTHONOTARY,ANOT ARY PUBLIC CUMBERL AND COUNTY COURTHOUSE ' MISSION EXPIRES JANUARY 4, 2010 FILED --CF Fl G"E: OF THE" PR7.,TH",' NTARY 2009 NOV -4 Aid 11: 20 CtyiP;r: , ATY