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Home My WebLink About00-02921 -'->., L. ~, . , :Ii :Ii :Ii:li :Ii . . . . :Ii :liif.:liif.:Ii"" ... . . :Ii"''''':!:'''':!::!: :Ii IN THE COURT OF COMMON PLEAS . , , . OF CUMBERLAND COUNTY PENNA. . STATE OF . . . . . John E. Killinger, Plaintiff . No. ::lOno 29::>1 _ Civil Tilt""" . . . . VERSUS . . Charl€ltte F. Killinger, Defendant . . . . . . DECREE IN DIVORCE . . . . JU\l fa , 2...o~ IT IS ORDERED AND AND NOW, . . . John E. Killinger DECREED THAT , PLAINTIFF, AND Charlotte F. KillinJler , 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; . . . . . . . . . . . . . . . .. . . . ATTES OTHONOTARY . . :!: :!::f.:Ii:f.:!: :!: :Ii,., :!: :!:,., ,., :f.:!: :!::!::!::f.:Ii:f.~ :!: ""~'~'1,' <'-' . ~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :t::Ii:f.~ . . . . ~ '.,.. \ 'Z . . , ; ~iI!" .' '7~.CJO M ~~ ~ car ~ >7) tpo ./1~ ft1~ cO d?f ,.M~ " .' "___'1'~ , ".'-,' - ",_,q.'7':"" '-',,' -- ~"""' ,',....~" - ,-. """"', , .',t. _', "" ~_ ~ " ".,,,,,, """",', - "'" ,I JOHN E. KILLINGER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000 - 2921 Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Colll't for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S3301(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receipt requested. delivered on: May 18.2000. 3. Date of execution of the affidavit required by S3301(d) of the Divorce Code: By Plaintiff: May 8. 2000. Date of filing and service of the plaintiffs affidavit required by S3301(d) ofthe Divorce Code on respondent: Filed: May 10. 2000. Served on Defendant: Mav 18. 2000. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: June 15.2000. via certified mail. restricted delivery to Charlotte Killinger. (Returned by Charlotte Killinger. with signed Counter-Affidavit). Date: 6 f d 7, 00 Respectfully Submitted: q~~ I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 Attorney for Plaintiff ~" t -lJ~b JOHN E. KILUNGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000 - 2921 Civil Term NOTlC ACTION IN DIVORCE TO: DATE: Charlotte F. Killinger. June 7, 2000. Ff1.:n ;- -om ~X' -.~{J ,;t;=t; ;;.to ~ drn ">$ (4) -< C) C) <- c:: 2: N m o "'" .-; CHARLOTTE F. KILLINGER, Defendant -0 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after June 27. 2000 the Plaintiff can request.~he 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 date above, 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 lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS A TT ACHED TO THIS NOTICE. 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. The filing of your counter-affidavit alone does not protect your economic claims. 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 A venue Carlisle. Pa. 17013 (717) 249-3166 ~~"~ "'ii- , -,. -.~ - JOHN E. KILLINGER, . Plaintiff : IN THE COURT OF COMMON PLEJ,.S : CUMBERLAND COUNTY, PENNSYL V AN'IA vs. : No. 2000 - 2921 Civil Tenn CHARLOTIE F. KILLINGER, Defendant : ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) ofthe DIVORCE CODE 1. Check either (a) or (b): _1:::::..<a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry ofa divorce decree because: (Check (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 maniage is not irretrievably broken. 2. Check either (a) or (b): v"(a) I do no( wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if! do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotal)' in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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. DatelhIH/.&jrY~O &th~~'W, ~~J f Charlotte . 'llinger, Defen t NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. < ~ .~ I~~,. ~llliIIllk~1 ~"'li"",;;',,_; , JOHN E. KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. {t}-;Yl02/ Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION 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, including custody or visitation of your children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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, Pa. 17013 (717) 249-3166 " '.~~ " ".q~;;'1' JOHN E. KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 6t.J_.:2f/.2/ Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is John E. Killinger, an adult individual, who has resided at 610 N. Middleton Road, Carlisle, Cumberland County, Pennsylvania, since May 1999. 2. Defendant is Charlotte F. Killinger, an adult individual, who has resided at 519-C South West Street, Carlisle, Pa., Cumberland County, since March 1,2000. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married in September 1958 in Winchester, Virginia. 5. There have been no prior actions of divorce or for armulment between the parties. 6. 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. 7. Plaintiff and Defendant have three children together, John Killinger Jr., Pamela Killinger, and Jesse Killinger; however, all are over the age of eighteen. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. " ,-, - ~JJ-" , . 1 O. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I veriJy 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. S4904 relating to unsworn , falsification to authorities. ~JZu~~~ 0000 Killinger, Plaintiff Respectfully submitted, Date: ~. 8' . 0 C) aJ~ ane Adams, Esquire J.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ""'~illi~~~f~j,~~:J);.;,;t4;;~;;"_~~~~~" ~, t~ ~ \ ~ \) ~ ~ ~ - ~ ~ ~ ~ (A ~ c",\ 'I~ \~ \i '~ ~ \ ~ ~ "-1IiIHlr~ o 0 ~ 0 -OED ::E: rnrn ;':;;-\1 2:0 --: Z,-- (J)~' ._ -< "/ '-' sF) )> ;: -0 Z\'j :3:: )>8 N z -' ':;;) -< r", -"~,," n~ -n '4 ;F.,., , 'F ""{"J-rn :t;Q nt ':::/0 :C=Fj Q("j ,.....--rn ~ 55 ,.;; . .~-,,' .", - JOHN E. KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. t)tJ ',;;9;;2/ Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated in November 1990, 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 my 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 are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 5'. 8;'00 ~ C :1-f~ 000 E. Killinger, Plaintiff ~ ~ --"" . ',..IIli...........,...""'"'"="_~~~~-~....."'~.._~"'~~~~~II.-. - ,~. , _..,.", 1&l(...1ll. ~......~.......~ ~~ --'-I ~ () 0 0 C 0 2'" .." U~ :::J!: ---I meo :no ;~-n zrn -< ~( .1._ -e,!Ti ~C:5 0 :DO rf:" o~ ~ ,~. -0 :.;-1 -. ,f."::i;j zO ,.". G ' ~O -(') -'C r:-? 'Z-n 01 Z ;g ::;! 0 .e:- ~ , ~~~ -" -.\,1 JOHN E. KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2000 - 2921 Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this May 19,2000, I, Jane Adams, Esquire, hereby certily that on May 18,2000, a true and correct copy of the NOTICE TO DEFEND, COMPLAINT, AND AFFIDAVIT OF SEPARATION, were served, via certified mail, restricted delivery, return receipt requested, addressed to: Charlotte Killinger 519C South West St. Carlisle, Pa. 17013 PLAINTIFF Respectfully Submitted: Od~ ane Adams, Esquire LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF II!III"" "-IbIlll.jj~""~~~~~~~~---~II!lIIilIroIIBl~ .....~ o C.: ...,. ~- "1)cb rnr';- '7::':~Q, ~~" ~2 ~ ~~ o o :; )"~ -" N W - f1{: :s _:-."'- ~ -l ::I: --n 'Tl;':;;;: -G~ :n .L 'JO :~-ri _J...-n Qo t)rn ~ ")'0: :2. ~) r. t:;:) . + t Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this _card to the back of the mailpiece, or on the front if space permits. 1, Article Addressed to: D. Is delivery address d'1 rent fro Item 11 [f YES, enter delivery address below: QI~~ 5/'1c c;o~ weaf? s+: C arO.sle./ PA- /7 D/3 CD Ja.~...+-I-Af? oF- 3. Service Type ~:~j~t:~~-~ o Insured Mall o Express Mail o Return Receipt for Merchandise DC.a.a. 2. ArtIcle Number (Copy from ~e!V{~e_ label) 'c.ted_D.ellveryJ--1E2sJ,raff!!!} ~Yes ;, .,. ';c'334 DII bg-, 102.59S099-M.1789l PS Form 3811, July lQ99 _D-ornestic R~turn, !3eceipt - I, "" ~~ ~::, ~, ~ ~ . JOHN E. KILLINGER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . NO.: 00-2921 . . . CHARLOTTE F. KILLINGER, . ACTION IN DIVORCE . Defendant . . PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Marlin L. Markley, Esquire, in the above-captioned action. Respectfully submitted: 4~~ Date: t /22/ .LO(j() I Marlin L. Markley, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 II ,~ -~o;;' ....1ilm ii.ii"~~ ~ ~_liI~~~_,,"i\,'l"~~~~"""" .!I!l~' "iil*nrllli.ICEu lL_~~~ ~~ ~~, I::") ~- ~~; ~~$~, l;':'v ~~2. 7c~ ');:, -, -'- 'f"'-) \',0 '-:: ,q ~'O . ,,;,",l~'-"'.-'''"'''''''''''''-~~'-" - L~ ~-_.,ru.",- .'" '"' JOHN E. KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000 - 2921 Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE TO: DATE: Charlotte F. KilIinl!er. June 7, 2000. You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after June 27. 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 date above, 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 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 TillS NOTICE. 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. The filing of your counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE TillS 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, Pa. 17013 (717) 249-3166 ,....~j; - - ..- ~=,--~~~, ,~ ~ . -" ~ Ir~J't:f -" . ..---.--.1. 1. '"~~'-;!;~J.!U<_~."",~,,,,,,-,,_,_,,, ",- - "'" '~ JOHN K KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA vs. No. 2000 - 2921 Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 330Hd) ofthe DIVORCE CODE 1. Check either (a) or (b): k,(a) I do not oppose the entry of a divorce decree. _(b) 1 oppose the entry of a divorce decree because: (Check (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, and expenses ifI do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in this counter-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:Y--ph(J'A5 &~() @~~- W, ~:i"/(/ j! Charlotte . illinger, Defend t NOTICE: If you do not wish to oppose the entry ofa divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. ,'" 'f ~. . ,~- , ~. ~~' . .....~';;i;..~iliii.i:wlimh'WllU'.i:ill5l!!1!l 1" ".- ,-=-- " " <. '--'" ~-~. ~ . j ~~~~~ ..i , - " ~' 0 ~ 0 ~w. L. --I c:: *:n z , ';- ~"~ N "T,:,It'D "" ~;)D OL , -0 d'r; :ll: ~..,.; ~O 'f.l dm N ~ eN -< ~ - ~ JOHN E. KILLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2000 - 2921 Civil Term CHARLOTTE F. KILLINGER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE OF INTENT AND COUNTER-AFFIDAVIT i-' AND NOW, this June 26, 2000, I, Jane Adams, Esquire, hereby certify that on June 15,2000, a true and correct copy of the NOTICE OF INTENT and COUNTER- AFFIDAVIT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Charlotte Killinger 519C South West St. Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: e Adams, Esquire LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF :..-- .-'*-> -.- t:'Ic~; ---'> , , Complete items 1, 2; and 3.-A1so complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. ~~ ~/qc- '6(}"V~ ~+-s+. ~/1t 17013 D. Is delivery address different item 1? If YES, enter detivel)' address below: D Agent D Addressee DYes o No 3. Service Type ertified Mail D Express Mail D Registered 0 Return Receipt for Merchandise o Insured Mail D C.O.D. 4. Restricted Delivery? (Extra Fee) Yes PS Form 3811, July 1999 ~ 3 3"\ Q:t ~ Domestic Return Receipt l>'tJ 102595.99.M- 1789