The URL can be used to link to this page

Home My WebLink About00-02640 1,.-- '~,',', " <.",,_' "'c" , ". ,~ -."'" . " - .' J , :;:~t::+~!~: ::~~.(::~~::C(~;::~!>>::<';::~5~::::~"::~:"::~_;::,:;:~:c,,:::::~::+>:;: :1~::.;::~:~.!;:::)"::~;::~~~"::~;::::<C!;::,:K.::~;::X.~!r::~~::c!:":::~"";:::::!::C!:;;-'Z:!"1~1~~g~>>,.g~::.::.~{::~..~!r:;:!3"~Jt<~:~ Q ~~ :.: ~ ~ I ! IN THE COURT OF COMMON PLEAS ~ ~ ~ ~.~ ~ ~.S ~ t':: ~ ~.~ ",<>" . !'.~ N ~ ~ ~.~ ~ 8 ~ ~.'~ ~ ~~~ ~ U t."s , ~~ ~ ~ .,.", ~ !'.~ I i ~~t ~~ ~ ~ ~~~ k~ I 1:~ ~~ ~ ~.S ~ ~ ~~ "'./ . ~.~ >",' ~ A :'.'~ M t.,< ~.~ ~ OF CUMBERLAND COUNTY \l W ~ ~ ~.s ~ ~~~ ~ ~~s ~ a ~.~ ~1 a ~.~ ~.~ ~ ~ i ~.~ ~ i ~.~ ~ ~.~ ~.~ ~ i ~.~ ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~.~ ;:~ ~'S ~ ~ "',, ~.~ ;,~ ~ i ~ M .. ~ $ .......-....-- ~ J. ~.~ .... ____uu Prothonotary ~ - . .. " ., .~. .~. .~. '~'. .'~'. .'~'. .'~'. ,~,,'. ;...:. .z. .It:> 'It:. .It:. ~. <.:.' ':c. .:c. <c. .:c. .It:. .:c. .:.:> .It:. .:.:. .:.:. .:~,~., ',~.' ',v,' '.v.' '.v.', '.v. .v. .v. .v. -.; STATE OF PENNA. ..Km.aj;:J.U,EXn.~...J!1QHLER........__....n.___....n..__..... I II No. __2.640__________, __2.00.0.__.. .........!"L.~;!:~'rlf;l)':... ...n_. Versus nJDHN..C...MOHLER,...JR~... J)Ef~N[)A.N.T___n.... DECREE IN DIVORCE AND NOW, ....,.,..,.. ,r,t:l~,c.to.../,....., 20Q1. , '. it is ordered and decreed that.. , , . . !<.I.I'1I}I):R[,E;:(. f\-,., ,I'i\OHLER. ... . . , . ,. , . , . .. , . ", plaintiff, and, .. .. ,. JOllIi. c... .MOHLER,. JR., . . , ". .. , . , .. , , .. . .. ., , . .., 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; . .N.Ql':l~.,.....,....,..,..,.,....".,....",...,.....,..".,."...,.,.,....., ~ , .J-2.t:J1 ..5-0/0/, .. ~. ",- ,n',"'"C-_'_' ~ r - . to' " u-~~~'4~~ ~ /U-~~.~- '. ., ",.- ,~,_n--flltIJ ~, "'~.~.~.-.. .....-,.,...-- , '-jft-;; .. -, PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM 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 ( d ) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on JOHN C. MOHLER, JR. by personal service on Januarv 6. 2001 3. Date of execution of the plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: September 7. 2000 Date of service of plaintiff's affidavit on defendant: Januarv 6. 2001. 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, if the divorce is to be entered under Section 3301 (d)(1 )(i) of the Divorce Code: Januarv 8. 2001. US Mail . Date: 011 ;;l'~ ) 0 ( ~~ Peter J. Russo d&;Iiiil!lll!!ltlMiJt~,L"ijlll~\!l>,~'f,lii;""""L~"'I<<1H,';U""~";;""""H!JP.i$.'"lil'~~W;~~lfl!d.j:Wt<jJ;&i!!lli;1."*i1t\~~",,"j;:;~~Ii\I!il@i~Ii!!~/jjjj&i!l!f!~~_li~~ll <, -to'_ ~~,~ . , __~ <0 - , ~ - ~ " ',I - 0 CJ C ~~>, -" "0 ~. l-q rn ;__--:J .. Z f'.) - .", :z: .. d (n G.:.l -< '--" C? ~ c-; ?~: 5> '"Ti l~' ..-' ,.j C~ :Z () --,- ;-n s> \.0 "----...,, C ~ Z -< :':.11 5J .~ -< , ~ ~ ~ j ~"j , ' " "-e;;. PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 KIMBERLEY A. MOHLER Plaintiff Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OIF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM 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 ( d ) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on JOHN C. MOHLER, JR. by personal service on Januarv 6. 2001 3. Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: Seotember 7.2000 Date of service of plaintiff's affidavit on defendant: Januarv 6. 2001. 4. Related claims pending: None 5. to transmit record, Divorce Code: Date and manner of service of the notice of intention to file praecipe if the divorce is to be entered under Section 3301(d)(1)(i) of the Date:---1h1.lo, c~~ Peter J. Russo "" .,.,,~~l:J, _~~IIilifIi!~Hl u-..-~liIWIJiIlI[.a ~ "~-1Il!IiiiIilIlII~~1!'~<~ ~~-~....~~ .tic r " 8 0 ~ -o~ i; '-1 ~5.l :1: z r---q,:n b5~ N ,..... '~om -<2 N ~'56 ~C'J ~8 > 5t:a X ~~ >c S1 ~ of;"" :i>! f\) :i) ..... "'" ,~,~ ~~, ~..", ~,~, ".~'''.'. ,-- ~~ '. ," 'M,,~ ~, ... . ~ ~ ." . '-, " KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000.2(, lID CIVIL TERM IN DIVORCE JOHN C. MOHLER, JR. Defendant 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 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 Court House, 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 , - . - ~, J-Ii;':_" , . ,- ~ ,,' PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 KIMBERLEY A. MOHLER Plaintiff Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW v. JOHN C. MOHLER, JR. Defendant NO. 2000 ..;n 'fo CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 Ie) AND 3301 (d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through her attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 27 Spring Street, Shippensburg, Cumberland County, Pennsylvania and is a citizen of the United States. 2, Defendant is an adult individual residing at 11371 Mountain Road, Orrstown, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 39 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pennsylvania for 38 years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on April 24, 1988 in Cumberland County, Pennsylvania. 6, There are no children of the parties under the age of eighteen (18). . -" "~ ! , " -. COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder, 8. There has been no prior action for divorce by either party against the other, 9, Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10, Plaintiff avers that the marriage between the parties is irretrievably broken. 11 , Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, KIMBERLEY A. MOHLER, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. Date: '-j la 't (CJ--c.r?/V ~;~ Peter J. Russo 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ~u , PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff KIMBERLEY A. MOHLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000- IN DIVORCE CIVIL TERM VERIFICATION I, KIMBERLEY A. MOHLER, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: ~~...', "- ~"""\) a 0 .~-"C~~~ , KIMBERLEY A. MOHLER _1.~ll!i!iiillI~~;1i~i\hf~~~liil~~:.j.~~,~~~",jMU;:"",~,o.,;,h'~>M_J<i.'''i#td~;jjj1:>!i! "I'~' r~ -- -...r~W .....~ UJ 'I' " -( -..I~ - '''"''_~1.C ,,,__ci!!!lj iI"";'-ilIiI:iIIluJa..ll ...J" "~~ c ~~~ ~;:' _e-"""'_, f~'-;' ,~"c ~-' '-- .....:" ~~8 2~ --I -< L~~ '-~ ,I , C) ,:" - 'r'- ~..,..~ G .. .! ~:.:' -< ,""I ~ ;f::> 1f ... ~ "!. "'1 ....... c "\ " v :-" <:J 2: ~ f; r "~,- '., ','-" PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 KIMBERLEY A. MOHLER Plaintiff Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM ACKNOWLEDGMENT OF SERVICE OF COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) AND 3301 (d) OF THE DIVORCE CODE AND NOW, COMES, Defendant. JOHN C. MOHLER, JR., and does hereby acknowledge that on the date indicated below he did receive a verified copy of a Complaint in Divorce filed against him in the above captioned case. ;drc~M~*.j . DATED: lie !ZOO I t / _r-~"'iIIIi!fIl1IIlI8ifMl1iM1~~~~lI'l """,=~'"" .~,," ~ ~"" , ~.~ ~-","", Iii "lillf lilllliltillii ~~'"~ .. ..' C) 0 ~ ~ c.... :!! -oro $; ~.gj rn~ m2i N .O~ N :0 ~O Q. ~ ::J:rH ~Q a'- 'Z:("' :i>g CP. om ~ l"" 3S N "< ~ ~~ " , . ..~ " - KIMBERLEY A. MOHLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant CIVIL TERM NO. 2000 - 2640 IN DIVORCE NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: JOHN C. MOHLER, JR. Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to plaintiff's affidavit. Therefore, on or after MAY 26,2000, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: 5'/~ooo <.:! ~ Peter J. Russo 61 West Louther Street Carlisle, PA 17013 -,.' " 'Ii \. 'Ii \, ~ \; , \, 'ji \ , , ~ .~~-, I, ~:- '-" ~ .- KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 - IN DIVORCE CIVIL TERM COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree, (b) I oppose the entry of a divorce decree because (Check either (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years, (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim for economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa,C,S, 34904 relating to unsworn falsification to authorities. Date: JOHN C. MOHLER, JR. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. _11Ill~r1J~>:wjdl;;l'.I~",~ili"~I~~illili~~""'-I~MlllilJ""."~--,,:,,;,,,",,-,j<6~A~:t1d;<-l-"'J-jl~':ll!iilili:~,!lliI'J('~'fI'lliilllililllllr!IiJum~~~.l>l1l~~ -- llfmJUlIlIL lrl -.<,"",', ,J,_"__ ._ - ~~~.~" .~""'""-~- ~ n !;; rg& z['" :z-I:.? Ci5 ):,.. j:$~ """-., "S ZC) <-0 Pc: :? ~ Ul ,,- Cl o 5?E --<: I <.n " :J: ~ ~ :;i ~~2::n i!J ::::1 -, ~~ 15f'ri ;g ~ ~. 1lIlIIililit:, I , i I "~~ . " - , ' ~ - , . ltJIliiJ'.' " '''l :,"4. KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: JOHN C. MOHLER, JR. Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to plaintiff's affidavit. Therefore, on or after OCTOBER 4, 2000, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: Seotember 13. 2000 Respectfully submitted, GR-\ L-- Peter J. Russo 61 West Louther Street Carlisle, PA 17013 _iHu_...J....J~I........~ilIl~~lil/l!~~~llIlili; N,. ,","'~__" """ ,. . ~-"" "' " I~'''' ", ",,-, ~.~~ .- i~1 .J...... ~ C' ~; ~?~" I~ c Z -f -< - ,.. 1', ".. t:/J ,q ~.-V (.,,-, ~.'J . , . ~ " ~ ., ,; " .~ ""-"- - .'''\j I I i I KIMBERLEY A. MOHLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 - IN DIVORCE CIVIL TERM COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check either (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim for economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: JOHN C. MOHLER, JR. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. .i__~.J "IIIlIi__~iIIii~--' r ,I~t~" .,,",~ ~ "'~.~~,"~" ,,,," ~_~w~"M1A ,~, ~ ,i-""''-'''''''>':-''-'';i., 'rJ C) ~;: ~f~'; 7-.:,C" (J;: '. r;: <:: ;i:~-:: >c: 7: ^'~ -~ ,.. .'" ::/') ,Tt . ',-' c,,': .' ':.r_' '...~I OJ-" ~ --;.. . ,I . -. KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check either (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ~ I do not wish to make any claims for economic relief. I understand that I );7ay lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim for economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Date: 1/6/200/ , I QLC.~ ~< ~N C. MOHLER, JR. 'I NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. __.....~J~_~~Iii_Uil!IWl '~:i/!IHI~d~iliillIllo::w;j1l "' .~, .. -rillilllll'-' "" .1l "., ~ .'~~.~ "' .= - i; 0 0 0 ~ -n t.- ...J: 2~ ,.. ::;:.." z n1r== :z;:O N -at? ~~ N :0 ~O '< ,.. ::r:=fj ~() :::r; o~ :;;;g CO 5' .. ~ ~ ~ N "iI,,:! "',' '" KIMBERLEY A. MOHLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM PROOF OF SERVICE OF NOTICE OF INTENT TO ENTER DIVORCE DECREE AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, KIMBERLEY A. MOHLER, and certifies that on Seotember 13. 2000 he did serve the Defendant, JOHN C. MOHLER, JR. with the attached Notice of Intent to Enter Divorce Decree consistent with the attached certificate of service. C~~'d~ Peter J. Russo 61 West Louther Street Carlisle, PA 17013 Date: Seotember 13. 2000 iiliiiflln~:~~'iIii-.i':l'"_~Mi!liIblf,i\!~~~''''''' - "'~.illlm~t;!ili~~..J;.t'I]:r~" ->",~" ."". - ~, ~. "IIlll1 .~_..." I" \:"2 ~," ~~F: zf--- co: -<:>- ~:~.': ~(~.: ~"C= 7.: =< .~",. b ,. '.. ,- E~ ~~ '1J ~'1 ''':;) c: 7} ::..') {51 - ,. II KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 - IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, KIMBERLEY A. MOHLER, and certifies that on September 13.2000 he did serve the Defendant, JOHN C. MOHLER, JR. at 11371 Mountain Road, Orrstown, PA 17244, with, the attached Notice of Intent to Enter Divorce Decree via first class mail and certified. Respectfully submitted, ~4L-- Peter J. Russo 61 West Louther Street Carlisle, PA 17013 Date:~ ~_~__.. "-'-'''M1l~;~~~a' - 1TI'-(>~~~'"i, ~ ~;_.~_. ;,~<. ",,' (") ~ -Dn~ Q)f."i' , ..::......,1 ::2::T S?~:~,. ~~~ :'''1 -, (::) '""' 'f) ,-, '..' c.~ -on C.) (,. >-' ',l,' , ., '.-j J .r< :b -< " - I ~ ~ ,;, - 1:..> ,- KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS (20) AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTSWILL BE ADMITTED. AFFIDAVIT UNDER SECTION 33011dl OF THE DIVORCE CODE 1. The parties to this action separated in June 1988 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.e.S. 94904 relating to unsworn falsification to authorities. Date:~~"\..,\ pO \, _iM_Wl~li'f~l.:.liltii__~.~,~_L"'- ''UiF<~_~W~ -'. . 1><l~L. (") C~ ~~~ Z::,r ZC. ~(~ ~;C:; .('={'''; :PC: ?~ -< C:~::.: o .'f) :"T1 -0 (~_: -~0 c;-? '0.."__ # -""'"~ " 'I I I ! ., ~Q .-<. ~ . ~:'-i . . . KIMBERLEY A. MOHLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM PROOF OF SERVICE OF PLAINTIFF'SAFFIDAVIT UPON DEFENDANT AND NOW, COMES, Pe r J. Russo, Attorney for Plaintiff, KIMBERLEY A. MOHLER, and certifies that on he did serve the Defendant, JOHN e. MOHLER, J . with a time stamped copy of the Affidavit of Plaintiff Under Section 3301(d) of the Divorce eode by placing same in an envelope, return receipt requested and addressed to JOHN e. MOHLER, JR. at 11371 Mountain Road, Orrstown, PA 17244, and deposited same with the United States Postal Service for delivery. Respectfully submitted, @Q Peter J. Russo 61 West louther Street earlisle, PA 17013 Date:~ _iliillftlliil.~;..iI._~HiI!IimI~~w~ -<,~,. "-ilI-~-'K-"'- ~ 1liIlilI- (") ~~: cn _':.~ ~;~~- ~-"--' 2~,---' .~,,,,,:, >'~-:: '- z :;! ~- -~, -: -, c' o UJ P'"l '''0 c.'-:. c..,.) .c:- , 1-- I' - . KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: JOHN C. MOHLER, JR. Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to plaintiff's affidavit. Therefore,. on or after JANUARY 26, 2001, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your .signature notarized or verified or a counter-affidavit by the above date, the court can~nter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTEFi-AfFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONeE. IF YOU DO NOT HAVE A LAWYER OR eANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFleE SET FORTH BELOW TO FIND OUT WHERE YOU eAN GET LEGAL HELP. eumberland eounty Lawyers Referral Service eumberland eounty Bar Association 2 Liberty Avenue earlisle, PA 17013 (717) 249-3166 ~ Peter J. Russo Date: \ 1 'is I () I --, ,,, ~ ," KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 IN DIVORCE CIVIL TERM COUNTER-AFFIDAVIT UNDER SECTION 3301ld) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check either (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim for economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.e.S. 94904 relating to unsworn falsification to authorities. Date: JOHN e. MOHLER, JR. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. 1- , . .iii ~ . . KIMBERLEY A. MOHLER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW JOHN C. MOHLER, JR. Defendant NO. 2000 - 2640 - IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, KIMBERLEY A. MOHLER, and certifies that on Januarv 8. 2001 he did serve the Defendant, JOHN e. MOHLER, JR. at 11371 Mountain Road, Orrstown, PA 17244, with the attached Notice of Intent to Enter Divorce Decree via first class mail and certified. ~~ Peter J. Russo Date: \ llJ I ~ I ~_~Il.1;,ji~~ililii~lOUiIiltill'1<1fi1ll>iJ~~*1ih->ffll',\$Mr~~;'~l,*,1i4f!1l!Jiil,_Mil.-~ w. _~ ,,""'. ~. -- .~" !IIltIJI' ~,"_ _,~.JL... ~ ,~~ 'lllIIIlIi-'- ~: " '. 0) c::: C s: '. ....J f';' ,-,-" rn '::;:) ?i ~ c ':-] CO i'-' ;:.S: . ' '- :::'::::: ,'-', 2: \,i :f;: C'l G:) . I", ~ l..-=: 7-: ::? :;! :"" 5:J -< . ~ L~- '~.~,-- ,.. -,.' - , - ~ff:~ ATTORNEY AT LAW Suite 200 . 5010 East Trindle Road Mechanicsburg, PA 17050 PHONE: (717) 591-1755 FAX: (717) 591-1756 Offices in Carlisle, PA Wednesday, February 21,2001 Cumberland County Prothonotary One Courthouse Square earlisle, PA 17013 RE: MOHLER v. MOHLER 2000-2640 Dear Prothonotary: Enclosed, please find a Notice of Intent to Request Entry of Divorce Decree for the above mentioned case. I, unfortunately missed having this document filed with the Prothonotary. Please accept this document, as it was mailed to the Defendant on January 8, 2001. Very truly yours, ~ki&.l)1Ih1fir Melissa M. Meha Paralegal Please Reply To: MECHANICSBURG OFFICE