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Home My WebLink About06-6990 WENDY A. DICKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. O~ - roqqO Civil Term FRANK S. DICKINSON, Defendant : ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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 St. Carlisle, Pa. 17013 (717) 249-3166 WENDY A. DICKINSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. () (,.. t 'f 96 Civil Term FRANK S. DICKINSON, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Wendy A. Dickinson, a competent adult individual, who has resided at 1111 Pheasant Drive N., Carlisle, Cumberland County, Pa. 17013, since 1986. 2. Defendant is Frank S. Dickinson, a competent adult individual, who resides at 140 Park Place, Shippensburg, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 8, 1979 in Poland, Ohio. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. . . <# ~ ... 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. ~4904 relating to unsworn falsification to authorities. ~ We~ Dickinson, Plaintiff Respectfully submitted, Date: 13/S /, Adams, Esquire No. 79465 4 outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~~~ ~Yc} tv ~ ........... ~ ~ ~ ~ ~ (") C <-.:- "1:' 5~,: rrIr.-; Z ~:~ 1:1:5. -<~ r~r' :~c' :);~~::~; 52: =< r-.:t = c:::l 0"' c::::J rr1 c-> I C1'> o ." ~ n1:Il -oM; :n9 06 :;:1-, . --- ....n ~:;;:("5 om --i )....... ~ -0 3 Ul &" WENDY A. DICKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 6990 Civil Term FRANK S. DICKINSON, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this December 15,2006, I, Jane Adams, Esquire, hereby certify that on December 13,2006, a certified true copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT was served, via certified mail, return receipt requested, addressed to: Frank Dickinson 140 Park Place East Shippensburg,Pa.17257 DEFENDANT . Complete ltemsJ, 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 mallplece, or on the front If space permits. , 1. Article Addressed to: E'RA71K ~ICr<PISON 14"0 PA."RX PT..'\C"S ~A.ST S~IPPENS9URS P~ 17257 3. ServIce 'JYpe C CertIfIed Mall 0 ElCprees Mall C Registered 0 Return Receipt for Merchandise C Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service I8beI) PS Form 3811, February 2004 7004 1350 0003 7147 1670 Domestic Return Receipt 1 Q25l15-()2..M-1540 Adams, Esquire 1. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF o ~. ~ c:> cr o \'"1 <:'J - coof, >";'1')' --,'U' -~~-,. ~ :1.-n fi1e -:9\C~~ -:~~-\ ~?\ ,,-; ,..-'4;", '") ",,::",;:' E5\;I" )=?' ~ ~? <J' v,) WENDY A. DICKINSON, Plaintiff vs. FRANKS. DICKINSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 6990 Civil Term ACTION IN DIVORCE STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff, Wendy A. Dickinson, intends to proceed with the above-captioned matter. Respectfully Submitted, Date: ~ "I V~ a e Adams, Esquire 17 W. South St. C rlisle, Pa. 17013. 17) 245-8508 ATTOP.NEY FOR PLAINTIFF F~l.EC7-~s~rl~ 4F 7H~ !'~~}~-?~~~~'ARY 10T~9 SAP - 4 P~ I ~ ~ 5 P~N~aYi.:Y~iG'~ WENDY A. DICKINSON, Plaintiff vs. FRANK S. DICKINSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 6990 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce Decree: Code1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce . 2. Date and Manner of the service of the Complaint: via first class mail, certified, restricted delivery, return receipt signed by Defendant on December 13, 2006. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: January 14. 2011 By Defendant: January 14. 2011 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: January 20. 2011 6. Date Plaintiffs Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: January 20. 2011 Cn e-i >M1 ote U-CD CE > = j C -- ,- - Respectfully submitted, J ne 7s, mEsquire . D. N465 17 W. uth South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF WENDY A. DICKINSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. FRANK S. DICKINSON, NO. 06 - 6990 Civil Term. DIVORCE DECREE AND NOW, it is ordered and decreed that WENDY A. DICKINSON, plaintiff, and FRANK S. DICKINSON, bonds of matrimony. , defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None; the marriage settlement agreement entered by the parties shall be incorporated but not merged into this Decree. By the Court, Owf. 0 rrwkd -k cry AElams No *e 1. mou W * deft