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HomeMy WebLinkAbout95-05310 ~ J J , ,,-. :-~ - ( ,. I ! I j I . , ~- .:+:. .:.:. .:.:. .:c. .:c- .:.:. .:c. .:c. .:co .)Co .*- .:.:. .:<<. .:.:. .:.:. .:.:. .:.:. .:.:- .:<<. .:+:. :-";C':"~^:'."":C-,~,:*, .:c. .:c. *:-<ec"f! " - --- ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF * PENNA. ~ $ 8 8 8 8 8 .. ELEANORE R~ PI a<EN , N().~3JP...qvit,........., Il) 95 ,'. ~ Of " Plainti ff ~\ Vl'l"SlIS ,', ~ RlOiARD L. PICKEN, i ',' ~fendant .;, ~ ;.:, ~ i ',' DECREE IN DIVORCE AND NOW, ... ocrQk.r.. .'1\......,. 19 ".., it is ordered and ,;, ~ ~) v) ~ " ~ 8 8 " " decreed that ...,..',.." .E,LE,~RE ,R., PIO\EN , , . . , , . , , , , . . , , . . " plaintiff, and.."...,.,..",....., ,RlOjAI.W,t.,.I'HJ,<E~.,..,',.,....,.,". defendant, are divorced from the bonds of matrimony_ 8 8 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; ~ ,;, " 8 8 8 M " ~ 8 8 8 - ~ .. '->>:. ,,.:' ':.:' ....................,............. . nv ~he .ci1L~ tl~,ir, Au...t. O.:-.J< ' c' ~ ..,',. /_ ,--!J,' I.t .,.~_... (' ~~#", ,'c' 7!."~ '>'l.,~O{' ~ -~d~ A;;;: ,/ ! Plr~nolar)' , ~ .~~~-*~..**..~.~.*.~.~*~.*.~..~.*..~,~,-~~.*~.- 8 . 8 ,'. ~ 8 . 8 8 8 8 Of ., 8 8 . " ., I, S 8 . 8 I l~ ~ ,-, S . ~ .? ~ 8 ,~ 1M ! . ':8 ~ i~ ,1" ':~ ,;, " '" ~ ~ ~ ~ II'3!Y't /[ 3''/1 (,:,,:1 tf}!:/ /J..:;~W;i ?zd: $t~,..~~ , . ,/' 1Ic<'~e:t' /:1?..tt ~ t'~ ... * 0\ is t.n 16 .. :'i sa I:> ..... ,,) ~, :c;: ':I~ Cl N ';~ c: .":1 Q. CN UJ I- ~m f!: u .rJa. c:; ~. ~~ ~ "" a C1'\ i i I [ t , I , f' . . .. . . , ELEANORE R. PICKEN, Plaintiff v. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 15-- S' 3/0 (J, the ,Jf.~1r-- RICHARD L. PICKEN, Defendant COMPLAINT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If YOll 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, Cumberland County Courthouse, 1 Courthouse Square, CarliSle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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. COURT ADMINISTRATOR Cumberland County Court House 4th Floor 1 Courthouse Square Carlisle, PA 1701)-3387 (717) 240-6200 Respectfully submitted, & FRIEDMAN By: R1C . Frledman, Esqu re 60 N. Second st., 5th FIr. P. O. Box 984 HarriSburg, PA 17108 (717) 236-8000 . , ELEANORE R. PICKEN, . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . NO. . . . RICHARD L. PICKEN, . COMPLAINT IN DIVORCE . Defendant COMPLAINT UNDER SECTION 3301(0) AND SECTION 3301(4) OF THE DIVORCE CODE 1. Plaintiff is Eleanore R. Picken, who currently resides at 257 Roxbury Rd., Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Richard L. Picken, who currently resides at 257 Roxbury Rd., Newville, Cumberland county, Pennsylvania 17241. 3. The parties have resided in Pennsylvania continuously for at least six (6) months prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 12, 1986, in Allentown, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff acknowledges notification of the availability of counseling as prescribed in the Pennsylvania Rules of Court. 7. The marriage is irretrievably broken. 8. Neither Plaintiff nor Defendant is in the military service of the United states. 9. The parties separated on December 31, 1994. , WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. I verify that the statements made in this Complaint are true and correct. I understand that any false statements herein are made subject to the penalties of 18 PA.C.S. 54904, relating to unsworn falsification to authorities. ~~,~ Eleanore R. Plcken rledman, Esqu re y for Plaintiff Second st., 5th Floor 17108 RSF/bp:Di. vorce-Picken. Di. v , . f}e4.~()r f (J;c K.(" 1\ ,,;, H /1 I, ,. .~ 1 L (~ tl!.,\ I(t~ (A.,JIA"l\..... , "q!r- (I 31CJ C~~~ AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTy : ss: OF DAUPHIN . . Personally appeared before me, a Notary PUblic, in and for said Commonwealth and County, Richard S. Friedman, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Richard L. Picken, by Certified Mail, Restricted Delivery, on October 7, 1995, as evidenced by the attached Certified Mail card. man, Esqu re Sworn and sUbscri~to before ~ day of , 1996. NOTARIAl SfAL BARBARA E. PAlMER, Notary Public Harrisburg, Dauphin County My Commission EJpires May 11. 1997 ;:-. '~. '. -... .,' ..; " .", Ii, ~ t, I " ~~..". DOMESTIC IIn"IWf , 'Q - " "'~', """c;"'..;o,:"., ..' "'''''' , . ELEANORE R. PICKEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. : NO. 95-5310 Civil Term RICHARD L. PICKEN, . COMPLAINT IN DIVORCE . Defendant . . WAIVER OP NOTICI OP INTENTION TO RBQUBST ENTRY OP DIVORCB DICRI. UNDBR SICTION 3301(CI OF THB DIVORCI CODB 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 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. 4. 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 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: (')d, 1'7 I 9~ , ~~~ Eleanore R. P cken, Plaintiff Divorce\Picken.Wai ., . ''00 . . ELEANORE R. PICKEN, : IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . NO. 95-5310 civil Term . : RICHARD L. PICKEN, . COMPLAINT IN DIVORCE . Defendant . . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on October 5, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 Pa. C.S. S 4904 relating to unsworn falsification to authorities. DATED: /"!Y< " 1)>0'