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HomeMy WebLinkAbout00-00609 . . . . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '" '" '" '" '" '" '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LYNN}{. KNARR, Plaintiff No. 2000-o0q VERSUS KEITH E. KNARR, Defendant DECREE IN DIVORCE AND NOW, ~~;~ T ,z,o.... , IT IS ORDERED AND DECREED THAT LYNN M. KNARR , PLAINTIFF, AND KEITH E. KNARR , 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. BY:'~~d,J ATIE? {1.~ PROTHONOTARY " " . " - ~ . . . . . . . . . . . . . . . " . . . " . " . . . . " . . " . " . . " " . . . " . " " " " " J. . . " ~ ,~ ,~c . , " i~ ", ,', ."" " ~ '.~ ,'" .. ~ 9.9.aJ &;(.~' /4A~7tF4~ ff.{)o ~~ /~'2 d2:r- ~ . " -"""'~ .~, "1,~'''''' ~,,' -~,- LYNN M. KNARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V AN1A : CIVIL DMSION - LAW v. KEITH E. KNARR, : NO. 2000-609 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: l r I I t L Ground for divorce: irretrievable breakdown under S 3301(c) 33fll(<ij of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint Service was made on February 12, 2000 by certified, restricted delivery, return-receipt requested mail that was signed for by the Defendant 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the Plaintiff: August 15,2000; by the Defendant: August 25, 2000. (b) (I) Date of execution of the Plaintiff's Affidavit required by S 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4, Related claims pending: none 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by S 3301(c) of the Divorce Code: by the Plaintiff: August 15, 2000; by the Defendant: August 25, 2000. Date: 8 -;)q-OD !/L. Thomas S. Die , squire Attorney for Plaintiff , , 2 "'Os: ,..,..,CfI Zrr; Z::r" C0~' ;$~" ~C".J )>0 Zo Pc: Z =< .C C b r- G-"5 w a G ',. -.'~-, 'I'n ;:;:' ,;.j:~ :~:t1; orl1 0-1 55 -< :boo :::0: :.n "-'. ~ ~ i LYNN M. KNARR, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000- 1.,,09 ClVlL TERM KEITH E. KNARR, Defendant : CIVIL ACTION - LAW : 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 annuIment 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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 RIGHI TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ~ c LYNN M, KNARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000- C,O,/ CIVIL TERM KEITH E. KNARR, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Lynn M. Knarr, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Lynn M. Knarr, is an aduIt individual who currently resides at 255 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Keith E. Knarr, is an aduIt individual who currently resides at 1527 Spring Garden Drive, Middletown, Dauphin County, Pennsylvania 17057. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 11, 1997 in Carlisle, Cumberland County, Pennsylvania, 5. There have been no prior actions of divorce or for annuIment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. - 7, The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Lynn M. Knarr, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. S 3301(c) or 330 1 (d) of the Divorce Code. Date: T', J",J rw \ ;)Q?D - omas S. Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ~ " - ~ ,', '.~~ "'<" . LYNN M. KNARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO, 2000- CIVIL TERM KEITH E. KNARR, Defendant : CIVIL ACTION - LAW : IN DIVORCE VERIFICA nON 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. S 4904, relating to unsworn falsification to authorities. ~1ut01l l" >- l- i::: ~~ 2f ("') z l(.}.: "- i-"-~ 3~ ~ 8: G LUQ M ~:~:~" ~",..- O~ ~ H- ~,:(: 0- ''':"J ::3 8 ~ 0 Cf) t~:', ('<;.} ~l~ ........ 0.. CJ~- u3J.. I ~. ;:::'.' C::J ('['-2 l..1] 1 it lLluJ " ~ L.! :'.'.'C;.Ck" "'- 2: ~ ;' C;::J ::-.J c:!.. L) 0 0 \J ........ > , LAW OFFICE OF Thomas S. Diehl 401 East Louther Street, I~uite 103 I Carlisle, Pennsylvania 17013 Telephone (717) 240-(1833 . FAX (717) ]40-9893 > ~ ." "~".'<~"" ", . ... ._ ,e- '< ~,.', -"".";'~;"<' J>c, :;" .... , .. LYNN M. KNARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION - LAW v. KEITH E. KNARR, : NO. 2000-609 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT L A complaint in divorce under ~3301(c) of the Divorce Code was filed on February 2, 2000. 2. The marriage of the 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 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. 9 4909 relating to unsworn falsification to authorities, ~ {] 111 fmrr L M. KNARR, Plaintiff Date:Wff L5;dOn WANER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 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 staternents herein are made subject to the penalties of 18 Pa.C.S. 94909 relating to unsworn foJ,ifiom"" 10 _oriti~. ~ 11_ Date{JD~ I5drro 1Il. ru/~ I L M. KNARR, Plaintiff ,~",,~ ',V, "',;,..... J'~ ,.L,",- " "'Ii "",'" ....... I I . ,I fJ>- ' ,( 0 Cl ,~ C c':J --} -,.\ $.: :0- vcr.: nlrr: (J') Z:::C Zl-- ':':..J, .- (j"),J:> 0 '~,-' -<:2:, .'.-', :<0 ~ ::-:;::'r: )>0 2] Z ~ ~ (j 0 C517' 5>c: ~ ~ U1 ;::,; ::n C) -< I;t; " ' , , _,::_"~~<.,,,,j,>',-;~, ,;,,;_ ,_~~') '_:.:;,,,",:'>>,c,,,-,,, ' "- -, ,'- h .'-^". .~: I, _' ,',<---, ,L "-'''.- , > f .. . LYNN M. KNARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DMSION - LAW v. KEITH E. KNARR, : NO, 2000-609 CIVIL TERM Defendant : IN DNORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under g3301(c) of the Divorce Code was filed on February 2, 2000. 2. The marriage of the 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 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. g 4909 relating to unsworn :&.ti~:ori"" 1t G ~ I TH E. KNARR, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 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 made subject to the penalties of 18 Pa.C.S. g 4909 relating to unsworn falsification to authorities. Date: BPS/ /If) I I ~?L rn E. KN~ Defendant ;;;",;'- -->--,~,,,:- <-' ;',:;';';'\;"=,,,~,;,:,;, ,,"~ ",. '. , I'" .,' " ", """,,,,,,,,,.,.,i.,.,J',,,,,,' ~ , - I o ~ ""rJ ~~ fllQ-,' _f; ~Z 0) \~, rs ~~::. ~CJ ::Be, ~d ~ "" ~ ~l ~ to"- IL) ..""",., '"'-". 4 c::> c.) }~ ,- 6::; >:...J c (J .-;1 ~. ~-- ;~j ::j~~) -...,',,' _'--\_n :,;".-c) (ji-'-'l j;! :n -< -"'<~- -:.;,> ~ t " . LYNN M. KNARR, Plaintiff ~', : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 2000- 609 CIVIL TERM KEITH E. KNARR, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 14th day of Febmary 2000, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Lynn M Knarr, and states that he personally mailed a certified copy of a Complaint in Divorce to the Defendant, Keith E. Knarr, at 1527 Spring Garden Drive, Middletown, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of . said receipt is attached hereto indicating service was made on February 12, 2000, Respectfully submitted, Thomas S, Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, P A 17013 (717) 240-0833 (717) 240-0893 -FAX - y .. ...... ~ , , . Z lbb bb8 57b US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse SenifuITH E. KNARR - S~ 1.40 '" m Retu e ..... Whom& '5. Return c{ Date,& r::i C TOTAL CIO (') E o "- lJ) ll. ""'------ ~ SENDER: " '1ii ~ w ~ .. ~ .. ;; " o " il Q. ~ o Complete items 1 and/or 2 for additional services. Complete Item, 3, 4a, and 4b. AI.lllft& o Print your name and address on the :".... .' :' . 0 ' , : ' this card to you. ,,' '. ". ' '<. DAttac~ this formtothefrontOfthemailPiUIIi...mm. . . ~s not P91rrut., ,'.;, , OWrite "Retum Receipt Requesfed"on th " t' ' mber. o The Return Receipt will show to whom the article was de ivered and I e date delivered. 3. Article Addressed to: 4a. Article Number + ~ I also wish 10 receive the (ollow- ing services (for an extra fee): 1. D Addressee's Address 2,lllIlflesl1Jcted Delivery'" KEITH E. KNARR 1527 SPRING GARDEN DR. Z 166 668 576 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise MIDDLETOWN, PA 17057 ~ertifled o Insured Deoo ) 7. Dfte of Delivery . J.. - }-tJi) 8. Addressee's Address (Only If requested and fee is paid) 102595-99-8-0223 Domestic Return Receipt -L.i___,'""'-_" .. " .~ .. lJ) a ';; " ~ a: " ~ " ';j a: '" " '1ii " ~ .g " o >- .. " .. F ~J 'i. " l'ol', ~1I""""'-JdiI'"_..' ~:lIl>~JilIIii>__"""'''!d'''''''~H:1>''''~!<~' '"" ,.^ . , , .- "., " ,~ - (') 0 ,- c: C:.J -;.'1 ;;: -." -:;:1 1:J C:; r"1 rn r'" " ~;J ~~' ~ ~-n .{:- '0 " !< ,",j ~,~~ )> '''TJ ~ri :2: ~. .' (~") ,-', )> c_, ':,..,) () n~ c: Z _._.~ po =<! (..) :J.'J -< .i ;""':l~;,.' ,I , 'i . , ~ LYNN M. KNARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL DIVISION - LAW KEITH E. KNARR, : NO. 2000-609 CIVIL TERM Defendant : IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, Lynn M, Knarr, having been granted a Final Decree in Divorce on the 7'h day of September, 2000, hereby elects to resume the prior surname of SHERIFF, and gives this written notice pursuant to the provisions of 54 P.S. S 704. rI~JL 1!J. ~ Lynn . Knarr Date: September 15, 2000 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the /S7~ day Of~.:-?, 2000, before me, a Notary Public, personally appeared the above affian own to me (or satisfactorily proven) to be the person whose name is subscribed to the within document and acknowledge that she executed the foregoing for the purposes therein contained, IN WITNESS WHEREOF, 1 have hereunto set my hand and official seal. / cL:~/~~~ ~~ C?7- Notarial Seal Kimberly L. Oieh~Hough, Notary Public Carlisle Bora, Cumbertand County Commission Expires May 5, 2003 ~ ';';;','0 '.' . 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