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HomeMy WebLinkAbout06-7311e ~~ Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstoovn, PA 17011 (717) 731-1461 VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE COURT OF COMMON PLEAS CUl~ERLAND COUNTY, PENNSYLVANIA NO . D(o - 73 /l L'cc~-~ 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ~ '1 NOTICE ~ AVAILABILITY QF TO THE WITHIN~NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty. days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. c THOMAS D. COULD, ESQUIRE PA. I.D. # 36508 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 717-731-1468 VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE .COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA NO. DG - 7~/I IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Virginia K. Dickens who resides at 406 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is William M. Dickens who resides at 406 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant have been bonafide residents of 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 December 8, 1990 in Westchester County, New York. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. There were no children born of this marriage. 1 7, The parties have been living separate apart since December 26, 2006. (. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States and or any of its allies. g. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce.. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION 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. iz 19 06 . ~~~~iu Date : _, Vir inia K. Dickens ~1~ V `1~ b 0 ~~. ~ \ (' v`~ C`:~ c'~- ~,~ t:~, ~, c--, e- C~ r~, ~~ 7y ~. . ~~r~- ,_ .>' r' :-C _.~ VIRGINIA K. DICKENS, PLAINTIFF v. W18LLIAM M. DICKENS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-7311 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by United States Mail on December 29, 2006. As indicated by the Acceptance of Service form, the Complaint was received by the Defendant on January 14, 2007. ~~~_ ~ Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ~~ ~' ~i s- `~~ , '~ ~:% t'x't F C~ ~ '",~ ~~ VIRGINIA K. DICKENS, PLAINTIFF v. • IN THE COURT OF COMMON PLEAS COUNTY, PENNSYLVANIA No. ,2,006 - 73 /~ e~Utc. TF2y- WILLIAM M. DICKENS, IN DIVORCE DEFENDANT ACCEPTANCE OF SERVICE I, William M. Dickens, accept service of the Divorce Complaint in the above captioned matter. Dated: ~ ~ v ,. i;, ~._ y~~~~ ~ ~ William M.~bickens 406 West Keller Street Mechanicsburg, PA 17055 DEFENDANT ~~i -v ~: ~ ~' ~ C~ C~ ~ ~ cn VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE COURT OF COMMON PLEAS CLA~ERLAND COUNTY, PENNSYLVANIA NO. 2006-7311 CIVIL TERM IN DIVORCE AFFIDAVIT QF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on December 29, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42 (e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED : ~^~~%'~ ~~ ,Z 04~ li'-~t f.,l~Gl~ ~~~~ V RGINIA K. DICKENS ~ ~~ ~~. t_ ~ y~ . ~ ~ ~ ~ ( Y y VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE COURT OF CO1rII~lON PLEAS CUi~IDERLAND COUNTY, PENNSYLVANIA NO. 2006-7311 CIVIL TERM IN DIVORCE yPAIVER 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 without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ~~~~211Z /?, oGO47 ~/ ~~C.~.~ ~ ~iC.~~-4-J VIRG NIA K. DICKENS ~~' ~ ~~ ~~~` fi ~a N Q "~ ~ ~. ~H. -t~ ~ ~.~r'x r_~ ~ tt~ VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE COURT OF COMMON PLEAS CtA~d3ERLAND COUNTY, PENNSYLVANIA NO. 2006-7311 CIVIL TERM . IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 29, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42 (e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED : ~ WILLIAM M. DICKENS ~. `C~ ~ ~~ a,,. ~ .. . ry ~: ~ d ~ ~"% -~ ~ G.:> ~~ ~ VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE COURT OF COI~IIrlON PLEAS CL7MBERLAND COUNTY, PENNSYLVANIA NO. 2006-7311 CIVIL TERM 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 without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. I ^.,_r DATED: Ll G ~ ` ILLIAM M. DICKENS ~' c~ c t c!~ ~' .. ~{ ` p ~ N ~ ,p ~- E1• ~ VIRGINIA K. DICKENS, PLAINTIFF v. WI8LLIAM M. DICKENS, DEFENDANT IN THE COURT OF COMMON PLEAS ccn~mERLaND couNTY, PENNSnvANIA NO. 2006-7311 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On January 14, 2007, Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, April 17, 2007; By Defendant, April 17, 2007. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in § 3301 (c) divorce was filed with the Prothonotary on April 20, 2007. Date Defendant's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary on April 20, 2007. Thomas D. Gould, Esquire Attorney For Plaintiff -. . t~r ~ . sa = ~ ~i r:~ r;:r, p .~. ~ ~ n ~ f ~f ~ h^ `` `V V ` v d I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. _ ~~- - . = VIRGINIA K. DICKENS, ~i PLAINTIFF VERSUS WILLIAM M. DICKENS, DEFENDANT (y0, 2006-7311 CIVIL TERM L)ECREE IN DIVORCE J'~ • 3°~'''~ AND NOW, ~ ,~~ IT IS ORDERED AND DECREED THAT VIRGINIA K. DICKENS PLAINTIFF, AND WILLIAM M. DICKENS DEFENDANT, ARE DIVORCED FROM THE BGNDS OF MATRIMONY. THE COURT RETAINS JURCSDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE PROTHONOTARY J~~!/ ~~ e' . 4.. ~ r ~ r VIRGINIA K. DICKENS, PLAINTIFF v. WILLIAM M. DICKENS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 7311 CIVIL TERM IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VIRGINIA ANN DICKENS, being duly sworn according to law, deposes and says that she is the Plaintiff in the above-captioned divorce action in which a final decree from the bonds of matrimony was entered on April 25, 2007 and she hereby elects to resume her prior surname of VIRGINIA ANN KRISTA and, therefore, gives this written notice avowing said intention, in accordance with #704 of the Act of November 15, 1972, P.L. 1063, 54 PA.C.S. Section 704. ~JS~ JIRGINIA ANN DICKENS To be known as G/ ` RGINIA ANN KRISTA Sworn and subscribed to before me this ~ day of ~~1 t; 2007 ~~61r~ .....~~~ NOTARIAL SERI IilAtdNE SHAFFER Notary PubNc 90ROUGHOF CMIP 1~1. CUNBERLMD CC)t>rilY M-t Commission Expires Aug 30, 2008 \. V ~......,~....m~.p...~~- ~ <: ~x;: ~, ~ z~~s~;;N:, ± x~.~ R f`. Q ~' C~ .~ © ,.- ~_ \ ~~ ~` O ~ ~~ ~ ~.1 Q = `l ~~.: OO(~~ L ~ ' „~ ~\ `~.: -a :!may ~~ --~ ,rr; ~ `~ ~-: C,~:r t r j r3-s ..ry - ~ ~l tJ