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.IN THE COURT OF COMMON PLEAS
.
OF CUMBERLAND COUNTY
PENNA.
STATE OF
GLENDA JEAN KELLY.
PLAINTIFF
No.
2000 - 2186 CIVIL TERM
CIVIL ACTION - LAW
VERSUS
JOSEPH EDWARD KELLY,
IN DIVORCE
DEFENDANT
DECREE IN
DIVORCE
AND NOW,J Ua'-'~+ 2."3
, 2...Do 0, IT IS ORDERED AND
DECREED THAT
GLENDA JEAN KELLY
, PLAINTIFF,
AND
JOSEPH EDWARD KELLY
, 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
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PROTHONOTARY
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD KELLY,
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:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defeudant, Joseph Edward Kelly, on April 13, 2000, by certified, restricted delivery mail, addressed to him at
2819 Kate Avenue, Apt. C- 3, Bensalem, Pennsylvania 19020, with Return Receipt Number Z 013 345 759.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by plaintiff: August 7,2000; by defendant: July 19,2000.
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and 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 ofIntention to file Praecipe to Transmit Record,
a copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: August 8, 2000.
Date
Prothonotary: July 25, 2000.
defendant's Waiver of Notice in Section 3301(c) Divorce was
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filed with the
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CUMBEIiLAND COUNTY
PENNSYLVPNIA
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- .J.Jf(, CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
NOTICE
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 in 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 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, 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
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AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
'!ifeII,
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- Ol./f~ CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the plaintiff, Glenda Jean Kelly, by her attorney, Marcus A. McKnight, III,
Esquire, and files this complaint in divorce against the defendant, Joseph Edward Kelly, representing
as follows:
I. The plaintiff is Glenda Jean Kelly, an adult individual residing at 139 Cottage Road,
Shippensburg, Cumberland County, Pennsylvania 17257.
2. The defendant is Joseph Edward Kelly, an adult individual residing at 2819 Kate Avenue,
Apartment C-3, Bucks County, Bensalem, Pennsylvania 19020.
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months
prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on October 17, 1981 in Newburg, Pennsylvania.
The parties separated on May 15, 1999.
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5. There have been no prior actions of divorce or for annulment between the parties.
6. There was one child born to this marriage, namely, Michael Joe Kelly, born January 27, 1983,
age seventeen (17) years.
7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which
this action is based that the marriage between the parties is irretrievably broken.
8. The plaintiff avers that she has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
Respectfully submitted,
By:
Marc s A.
Attorney fo Plain.
Glenda Jean Kelly
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 25476
Date: April 10, 2000
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
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GLENDA KE L Y
Date: APRIL 10
,2000
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JOSEPH EDWARD KELLY,
Defendant
2000- .l(8~ CIVIL TERM
IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONTARY:
Kindly allow Glenda Jean Kelly to proceed in forma pauperis.
I, Marcus A. McKnight, III, Esquire, attorney for the party proceeding in forma pauperis,
certify that I believe the party is unable to pay the costs and that 1 am providing free legal
services to the party. The party's affidavit showing inability to pay the costs oflitigation is
attached hereto.
Respectfully submitted,
By:
Date: April 10, 2000
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- .Jli'f., CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am the plaintiff in the above matter and because of my financial condition am unable to
pay the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the
costs oflitigation.
3. I represent that the information below relating to my ability to pay the fees and costs is
true and correct.
(a)
Name:
Address:
Glenda Jean Kelly
139 Cottage Road
Shippensburg, P A 17257
(b) Social Security Number: 178-54-1448
Employment Status: Presently unemployed
Date of last employment: Never been employed
Salary or wages per month: NI A
Type of work: N/A
( c) Other income within the past twelve months:
Business or profession: NI A
Other self-employment: N/A
Interest: N/A
Dividends: N/A
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Social Security benefits: $539.00 per month
Support payments: N/ A
Disability payments: N/ A
Unemployment compensation and
supplemental benefits: N/ A
Workman's Compensation: N/A
Public Assistance: Food Stamps $63.00 per month
Other:
(d) Other contributions to household support: None
(Husband) Name:
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
(e) Property owned: None
Cash: None
Checking account: None
Savings account: None
Certificates of Deposit: None
Real Estate (including home): None
(f) Debts and obligations: None
Mortgage: None
Rent: $109.00 per loan
Loans: N/A
Monthly Expenses: Utilities $150.00 per month
(g) Persons dependent upon your support: None
Name:
Children, if any:
Name: Age:
4. I understand that I have a continuing obligation to inform the court of improvement in my
financial circumstances which would permit me to pay the costs incurred herein.
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5. 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. 4904, relating to unsworn
falsification to authorities.
Date: APRIL 10, 2000
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GLENDA JEAN KELLY,
. Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April
10, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: 1/-7
.2000
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GLENDA JEAN KEL . ~
Plaintiff
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
l. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on April
10, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing ofthe complaint.
3. I consent to the entry of a final decree in divorce.
4. 1 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
not" M I ~ .2000
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SEPH D ARD KELLY
Defendant
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
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! 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 inunediately 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: ~ - '7
.2000
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GLENDA JEAN Y
Plaintiff
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD RELL Y,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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! 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: flu! jJ I~ .2000
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SEP E WARD KELLY
Defendant
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, 1 do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: q~ 7
,2000
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GLENDAJE LLY ~
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-2186 CML TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
I. 1 have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors 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 counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: fl~~ I ~
.2000
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OSEPH DWARD KELL Y \
Defendant
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GLENDA JEAN KELLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
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: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTION - LAW
2000-2186 CIVIL TERM
JOSEPH EDWARD KELLY,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant,
Joseph Edward Kelly, on April 13, 2000, by certified, restricted delivery mail, addressed to him
at 2819 Kate Avenue, Apt. C-3, Bensalem, Pennsylvania 19020, with Return Receipt Number Z
013 345 759.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to
unsworn falsification to authorities.
, ESQUIRE
Date: August 8, 2000
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Z QB 345 75"1 ..w"
US Postal Service ,J';""
Receipt f,or Certifi~,' Mail' .
No Insurance Cove/t.io Provided.
Do not use for International Mail See revefSe
Sentto '
MR JOSEPBEDWAIID KELLY
Street & Number
2.819 DATE AVE APT 3-C
Post 0Ifice, SIa\il, & Z1P'Qodii
BENSALEMPA 1902.0
Postage $, 17
Certified Fee
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~ Return Receipt ShoWing to
:: ,Whom & Date Delivered
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!TOTAL Poslage & Fees
C') Postmark or Date
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If 4/10/00
KELLY GLENDA
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.. ,.;;;pleie iie';;. r,e,and 3:')\' 'If(s,,i'plilte' ,
"-,m 4 if; R'e,str:icted'Delivery is,t1l3$ired.
.' flriot your nama"aL1d address on the reverse
_ _~ we c~return the eard:to you.
. Ailtach this~ to the bacK 01 the mailpiece, X
QT on lhe lro6f,ii space permits.
1. Miele Address' to:
.. JOSEPHf...' "WARD KELLY
.19 KATE,' ',:!lENUKAPT 3-C
~ ," 1902.0
3. Service Ty ~c9
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o Registered
CJ Insured Mail
2. Article Num~~ (Co~y f~,!, service Ja~~Q
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PS Form 3811 , July r_
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