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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
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Plaiptiff
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VERSUS
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Defendant
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AND NOW,
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DECREED THAT
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AND
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PENNA.
No. 2000-152
DECREE IN
DIVORCE
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, IT IS ORDERED AND
CRAIG I. ADLER
, PLAINTIFF,
KAREN E. ADLER
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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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 ENTERE':D; none.
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ROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CRAIG I. ADLER, )
Plaintiff )
)
v. ) NO. 2000 - 152
)
KAREN E. ADLER, ) CML ACTION - LAW
Defendant ) IN DNORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of a divorce
decree:
1. Ground for divorce: Irretrievable breakdown under ~3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Service accepted by Kathleen C. Daley,
Esquire on behalf of Defendant Karen E. Adler on January 12,2000; Acceptance of
Service filed January 18, 2000.
3. Date of execution of the affidavit of consent required by ~3301(c) of the Divorce
Code: by plaintiff, August 22, 2000; by defendant, August 22, 2000.
4. Related claims pending: All claims resolved by agreement of the parties.
5. Date plaintiff's Waiver of Not ice in ~3301(c) Divorce was filed with the prothonotary:
contemporaneously herewith; date defendant's Waiver of Not ice in ~3301(c) Divorce
was filed with the prothonotary: contemporaneously herewith.
Date:
Donald T. Kissinger, Esquire
HOWETT, KISSINGER & CONL , P.C.
130 Walnut Street
P. O. Box 810
Harrisburg,PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Craig I. Adler
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
) {]; ( ( C-
v. NO. ';;006 - IS;}. t~
)
KAREN E. ADLER, :
Defendant ) 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.
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
Cumberland County Prothonotary's Office, Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013.
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.
PROTHONOTARY'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA 17013-3387
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
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v. NO.
)
KAREN E. ADLER,
Defendant ) IN DIVORCE
.c.QMR!d~I.H'1'
COUNT I
CReauest for a No-Fault Divorce)
Under Section 3301Cc)and Cd) of the Divorce Code
1. Plaintiff is Craig I. Adler, who currently resides at
2838 Buxton Court, Harrisburg, Susquehanna Township, Dauphin
County, Pennsylvania, 17110, and has so resided since October 15,
1999.
2. Defendant is Karen E. Adler.
3. The last known residence and present whereabouts of
the Defendant is 473 Woodcrest Drive, Mechanicsburg, Hampden
Township, Cumberland County, Pennsylvania, 17055.
4. Plaintiff and Defendant have been bona fide residents
in this Commonwealth for at least six months immediately previous
to the filing of the Complaint.
5. Plaintiff's social security number is 184-38-1818.
6. Defendant's social security number is 019-62-9526.
7. Plaintiff herein is not in the military service of the
United States of America nor any of its allies.
To the best of
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Plaintiff's information, knowledge and belief, Defendant herein is
not in the military service of the United States of America nor any
of its allies.
8. The parties married on July 20, 1985, at Harrisburg,
Pennsylvania.
9 .
MINOR CHILDREN:
The following persons are minor
children born of this marriage:
Benjamin E. Adler
AGE SEX DATE OF BIRTH RESIDENCE
6 Male September 30, 1993 2838 Buxton Court
Harrisburg, PA 17110
3 Male December 25, 1996 2838 Buxton Court
Harrisburg, PA 17110
NAME
Joshua R. Adler
10. There have been no prior actions for divorce or
annulment instituted by either of the parties in this or any other
jurisdiction.
11. This action is not collusive as defined by ~3309 of
the Divorce Code.
12. Plaintiff has been advised of the availability of
counseling and of his right to request such counseling.
13. The parties have been living separate and apart since
October 15, 1999.
14. The marriage of the parties is irretrievably broken.
15. After ninety (90) days have elapsed from the date of
the filing of this Complaint, Plaintiff intends to file an
Affidavit consenting to a divorce.
Plaintiff believes that
Defendant will also file such an Affidavit.
16. Should Defendant not file an Affidavit consenting to
a divorce, then Plaintiff will submit an Affidavit at the
appropriate time alleging that the parties have lived separate and
apart for at least two (2) years.
WHEREFORE, if both parties file Affidavits consenting to a
divorce after 90 days have elapsed from the date of the filing of
this Complaint, Plaintiff requests this Honorable Court to enter a
Decree in Divorce pursuant to ~3301(c) of the Divorce Code; or,
should the parties fail to file said Affidavits consenting to a
divorce, Plaintiff requests the entry of a Decree in Divorce
pursuant to ~3301(d) of the Divorce Code.
DATED:
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craig7~Uire
Pro Se for Plaintiff
ADLER & CLARAVAL
125 Locust Street
P. O. Box 11933
Harrisburg, PA 17108
Telephone: (717) 234-3289
Attorney I.D. No. 52970
Y~:R~E~l:;P.1:~QH
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.
J-
Craig~dler
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
)
v. NO. 2000-152
)
KAREN E. ADLER,
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on January 10, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90)days have elapsed from the date of filing and
service of the Complaint.
3. I 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.
I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. 54904 relating to
unsworn falsification to authorities.
Date:
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Craig ~dler
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CRAIG I. ADLER,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
)
v.
NO. 2000-152
)
KAREN E. ADLER,
Defendant
)
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on January 10, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90)days have elapsed from the date of filing and
service of the Complaint.
3. I 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.
I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. 54904 relating to
unsworn falsification to authorities.
Date:
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Karen E/ Adle
Defendant
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CRAIG I. ADLER,
Plaintiff
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v.
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KAREN E. ADLER,
Defendant )
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-152
IN DIVORCE
DEFENDANTS'S WAIVER OF NOTICE OF INTENTION TO
RE9UEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301 (C)OF THE DIVORCE CODE
AND AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the
Divorce Code was filed on January 10, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90)days have elapsed from the date of filing and
service of the Complaint.
3. I consent to the entry of a final Decree in Divorce
without notice of intention to request entry of the decree.
4. 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.
5. I understand that I will not be divorced until a Decree
in Divorce 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.
6. Plaintiff's and Defendant's Waiver of
Di vorce were filed with the Prothonotary as
respective consent documents.
Notice in 330l(c)
a part of their
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. 54904 relating to
unsworn falsification to authorities.
Date:
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
)
v. NO. 2000-152
)
KAREN E. ADLER,
Defendant ) IN DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO
REOUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301 (C)OF THE DIVORCE CODE
AND AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on January 10, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90)days have elapsed from the date of filing and
service of the Complaint.
3. I consent to the entry of a final Decree in Divorce
without notice of intention to request entry of the decree.
4. 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.
5. I understand that I will not be divorced until a Decree
in Divorce 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.
6. Plaintiff's and Defendant's Waiver of
Di vorce were filed with the Prothonotary as
respective consent documents.
Notice in 330l(c)
a part of their
I verify that the statements made in this Affidavit are
true and correct. I understand that false statements herein are
made subj ect to the penal ties of 18 Pa. C. S. 54904 relating to
unsworn falsification to authorities.
Date:
1'2-1 DO
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
)
v. NO. 2000-152
)
KAREN E. ADLER,
Defendant ) IN DIVORCE
WAIVER OF COUNSELLING
I, Karen E. Adler, being duly sworn according to law,
depose and say:
l.
counselling
require that
I have been advised of the
and understand that I may
my spouse and I participate
availability of marriage
request that the Court
in counselling.
2. I understand that the Court maintains a list of
marriage counsellors in the Prothonotary's Office, which list is
available to me upon request.
3. Being so advised, I do not request that the Court
require that my spouse and I participate in counselling prior to a
Divorce Decree being handed down by the Court.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
~~~~
Karen 7iJ. Ad r
Sworn to and subsC~d
befoe:;r~ ~ day
of , 2000.
t
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NOTARIAL SEAL
DEBRA M. SHIMP, No1IIry Public
Harrisburg, Dauphin County. PA
Co",,"lssion Ex ires Au . 23, 2001
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
)
v. NO. 2000-152
)
KAREN E. ADLER,
Defendant ) IN DIVORCE
WAIVER OF COUNSELLING
I, Craig I. Adler, being duly sworn according to law,
depose and say:
1. I have been advised of the availability of marriage
counselling and understand that I may request that the Court
require that my spouse and I participate in counselling.
2. I understand that the Court maintains a list of
marriage counsellors in the Prothonotary's Office, which list is
available to me upon request.
3. Being so advised, I do not request that the Court
require that my spouse and I participate in counselling prior to a
Divorce Decree being handed down by the Court.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Craig I A~er
me this
, 2000.
.
NOTAfllAL SEAL
DEBRA M, SHIMP, Notary Public
HarrI~u'\l' Dauphin County, PA
CommISSIon Ex Ires Au . 23, 2001
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CRAIG I. ADLER, ) IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
) ckoo 15.:&
v. NO. -
)
KAREN E. ADLER, :
Defendant ) IN DIVORCE
ACCEPTANCE OF SERVICE
I hereby accept service on behalf of the Defendant,
Karen E. Adler, being authorized to do so and acknowledge receipt
of a true and correct copy of the complaint. ,
Date:
/-I~-(b
Attorney for Defendant
1029 Scenery Drive
Harrisburg, PA 17109
and
day
me this
, 2000.
i
NOTARIAL SEAL
PATAlClAA, PATTON, Notary Public
Lower Paxton Twp., Dauphin County
Commission Expires June 20, 2002
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