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Home My WebLink About02-2830LESLIE FICKINGER plaintiff VS. JOHN E. FICKINGER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : CIVIL ACTION - LAW 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, Room 101, Dauphin County Courthouse, Front and Market Streets, Harrisburg, 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. CUV~ERLAND(XYJNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-- 249- 3166 LE SLW__~2~/31~G JOHN E. FICKINGER Defendnnt : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA s 2oo : CIVIL ACTION - LAW COMPLAINT IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Thc Plaintiff is Leslie Fickingcr, who currently resides at 1340 Sugar Maple Court, New Cumberland, Cumberland, Pennsylvania, since May 25, 1999). 2. The Defendant is John Fickin4~er, who currently resides at 18 Wildflower Drive, Wilkes-Barre, Luzerne, Pcrmsylvania, since March 15,1993. 3. Leslie Fickingcr, the Plaintiff has been a bona fide resident in thc Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Thc Plaintiff and Defendant were married on July 14, 1962 at Harrisburg, Pennsylvania, Dauphin County. 5. There were three children bom of this marriage, namely John Edward, Jeffrey Edward bom April 5, 1963 and Thomas Anthony bom March 19, 1964. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have lived separate and apart for more than two years. 8. The marriage is irretrievably broken. 9. The Plaintiff has 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. 10. The Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. Attorney for Plaintiff Telephone (717)232-9398 Attorney ID#36514 LESLIE FICKINGER plaintiff VS. JOHN E. FICKINGER Defe~dnn~ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must a Counteraffidavit within 20 days after the Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on March 15, 1993 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 fights concerning alimony, division of property, lawyers fees or expenses if I do not claim before a divorce is granted. I verify that the statements made in this Affidavit are tree 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 I verify that the statements made in the foregoing complaint are true and correct and that the parties hereto have lived separately and apart for a period of at least two years, and 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 LESLIE FICKINGER Plaintiff JOHN E. FICKINGER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO: 02-2830 CIVIL CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW on this 8th of July, 2002 comes Anthony DiSanto, Esquire, who certifies that he was, at all times material hereto, over the age of 18 years, and that he did serve upon the Defendant John E. Fickinger at 18 Wildflower Dr., Wilkes-Barre, PA 18702 a copy of the Notice to Defend & Claim of Rights and a copy of the Complaint in Divorce by Certified Mail, Restricted Deliver and said mail was signed for by the Defendant on June 22, 2002 as evidenced by the certified mail receipt and return receipt attached hereto on page two of this certificate of service, immediately above my signature. Re'mm Rec~pt Fee ,~.~ TotalPo~tage&Fe~ $ ~7~-~ ................. Harrisburg, PA 17101 (717) 232-9398 LESLIE IN TI~ COURT OF CO~O1N pI.,~.,AS CUMBERLAND COUNTY, p~q'NsYLVANIA NO, 02.2830 CIVIL ACTION-LAW ~q DIVORCE TO: ~0HN F. F]CKINOER, DEFENDANT ....... '-.. ~:vorc~ You have failed to answer the final ~cr~ in oworce. . U do ~ot file ~th the Pmth~omw or,se ~0~ ~ An~er ~th y~ . If~o - , ~ ...... :~ or a Co~d~wt by ~he a~ve da% ~e ~ ' 'r~ ~Ol1~12 rengi, yuu mua; ~ ~ , A Co~AF~AVIT' ~CH YOU ~Y ~LB ~ T~ PRo~ONOT~Y OF ~ CO~T Ig ATTAC~ ~ ~S NO~CE. YOU SHOED TAKE ~S PAPER TO YO~ LA~ AT ONCE. YOUDO N~ ~ A LAiR OR CABOT AFFO~ O~, ~ TOOR TE~'IO~ ~IE O~ICE SET FOR~ BELOW TO F~ OUT ~ YOU CAN OET LEG~ ~LP. CumberN~d CounZy B~ Associ~ion .. 2 Li~ Avenue C~lisle, PA ] 701M (t00) 990-9108 or (71D ~9-318~ 7001 1940 0001 2180 7926 _ LESLI~ FICK~GER JOHN E. FICK[~GEK D~fend~ut IN ~ COUKT OF COMMONPLI~A5 CUMBEP~AND COUNTY, p'gNNSYLVANIA No. 02-2830 Civil Action - L~w ~ DIVOP, CE ~ QOUNTEK-~DA~T 1. Cheek either _X_ (a) [ do not oppose the entrT ~f a d~,or~ decree. ~) I oppose ~e en~ ~ a divo~e deo~ beesu~ (Ch~k 0), (h~ or bo~): (9 ~e ps~i~ to ~ts a~on h~t n~ lived ~e sad apa~ for s pe~ of at l~st thr~ yeS~. ' . (~ The ma~iage is not ~eirl~bl~ bro~. Cheek eitbcr (a) OR (b): ~) I ~sh to ~m ~eo~mie ~li~ whie~ may include ~w~r's fees or e~e~cs or ~ ~pa~mt rigbt~ I ve~ tkat the mteme~ ~ ~ th~ co~r-a~ ire t~e nut co~. I underg~d that ~l~ ita~en~ he~ are ~e ~bJeet 4~4 ~l~tng ~ to Da~:~ Si~ed: ,,, -- 3ahn NOTTCR: I~you do not wish to oppose the entry of a divoree decree ~md you do net wish to LESLIE FICKINGER, Plaintiff VS. JOHN E. FICKINGER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2830 CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Separated for 2 years - Section 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: June 22, 2002 by Certified Mail Restricted Delivery. 3. (Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: n/a by Defrndant: n/a (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: June 1, 2002. (2) Date of service of the Plaintiffs Affidavit upon the Defendant: June 22, 2002. 4. Related claims pending: None 5. (a) Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: August 19, 2002. (b) Date of Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: N/A. Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: N/A. A~~squire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of .~. PENNA. LESLIE FICKINGER Plaintiff VERSUS JOHN E. FICKINGER Defendant N O. 02-2830 AND NOW, DECREED THAT Decree IN DIVORCE LESLIE FICKINGER , it IS ORDERED AND , PLAINTIFF, AND JOHN E. FICKINGER ,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