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Home My WebLink About00-04953 . ~ .' '~-". ,'~ ~ ",-'.-~ --~."-.-o-- '~'-'-''- ".o-"'~-'~,_:"'"'","'-,-~'~>.L~"",'I",.C-L"_:.'. '-"'_S,~--"""" -Cc_, '- --~ "I I I I I KENNETH KARKER, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00 - "I9:;J (Jo~( ~ TRACY L. KARKER, Defendant : CIVIL ACTION ' LAW : 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. When the ground for the divorce is indignities or irretrievable breakdown of J:IllIUiage, you must request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at 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 "~I_~!" ",,-" - ,- ~ , r_"- KENNETI:I KARKER, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . .-,-- : NO. MJ- <-/95.3 ~ /~ TRACY L. KARKER, Defendant : CIVIL ACTION - LAW : ACTION IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, KENNETI:I KARKER, by and through his attorney, Jarad W. Handelman, Esquire, of the law firm of James, Smith, Durkin & Connelly LLP, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more fully set forth: 1, The Plaintiff, KENNETI:I KARKER, is an adult individual and citizen of the United States of America, currently residing at 202 Market Street, Second Floor, New Cumberland, Cumberland County, Pennsylvania 17070, 2. The Defendant, TRACY L. KARKER, is an adult individual and citizen of the United States of America, currently residing at 30 Byron Nelson Circle, Etters, York County, Pennsylvania 17319. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were man-ied on May 29, 1999 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There were no children born of the marriage -", .- . - ~- ~ ,--~ ~, "m '$(;' 6. Neither Plaintiff nor Defendant is a member of the United States Anned Services, 7. Plaintiff and Defendant have both been advised of the availability of marital counseling and that each may have the right to request that the court require the parties to participate in counseling, 8. Plaintiff avers that there has been no prior action for divorce or annulment of the marriage filed by either party in this or any other jurisdiction. 9. Plaintiff avers that the marriage is irretrievably broken, pursuant to Section 3301(c) of The Pennsylvania Divorce Code Act 206 of 1990. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. Respectfully submitted, ...- JAMES, SMITH, DURKIN & CONNELLY, LLP ~~Q JARAD W. HANDELMAN, ESQUIRE Attorney I.D. #82629 Dated: July 13, 2000 By: P,O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorney for Plaintiff, Kenneth Karker ~-< - ,-. __'''_<''''."~.''"=_~~n''~ ~'ew ~"__~_e~__. "---__" '-,c- :1 VERIFICATION The undersigned, Plaintiff, KENNE1H KARKER, hereby verifies that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best oflus knowledge, infonnation and belief and further states that false statements herein are made suQject to the penalties of 18 Pa,C.S. Section 4904 relating to lUlSworn falsification to authorities. ~~ KENNE1H KARKER - """..,; H105.157 AEV. S.97 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF HEALTH tJo. 'f9 0.3 {l,;d -r ~ VITALRECOADS STATE ALE NUMBER Cumberland DiVORCE [Xl RECORD OF OR ANNULMENT o STATE FILE DATE COUN1Y (CHECK ONE) HUSBAND 1, NAME (First) Kenneth (Middls) 3. RESIDENCE StreBtorR.D. Citr, BarD. or Twp. New Cumberland 6. RACE WHITE IZJ County (Last) Karker State 2. DATE OF BIRTH 4. PLACE OF PA BIRTH 7. USUAL OCCUPATION Laborer (Month) (Day) 11 8 (Stat8 or Foreign Country) (Year) 70 202 Mkt.St. 2nd Floor, 5. NUMBER OF THIS 1 MARRIAGE Cumberland New Jerse BLACK OTl-lER (Specify) o WIFE 8. MAIDEN NAME (First) (Middle) (Last) 9. DATE (MonllJ) (Day) (Year) Tracy L. Hays OF 10 2 66 BIRTH 10. RESIDENCE Slrestor R.D. CIIy, Boro. or Twp. County State 11. PLACE (Slate or Foreign Country) 30 Bvron OF Pennsvlvania Nelson Circle Etters York PA BIRTH 12. NUMBER r RACE '14. USUAL OCCUPATION OF THIS 2 WHITE BLACK OTHER (Specify) MARRIAGE E9 n o Daycare Worker 15. PLACE OF (County) (Slate or Foreign Country) 16. DATE OF (Mon/h) (Day) (Year) nil' Cumberland PA nil' May 29 1999 MARRIAGE MARRIAGE 17A. NUMBER OF 17B. NUMBER OF DEPENDENT rB. PLAINTIFF 19. DECREE GRANTED TO CHILDREN THIS CHilDREN UNDER 18. HUSBAND WIFE OTHER (Specify) HUSBAND WIFE OTHER (Specify) MARRIAGE 0 0 [KJ 0 0 IX] 0 0 20. NUMBER OF HUSBAND WIFE SPLIT CUSTODY OTHER (Specify) 121 lEGAL GROUNDS FOR GHIlDAEN TO 0 0 0 0 0 DIVORCE OR ANNULMENT CUSTODY OF Irretrievable Breakdown 22.. DATE OF DECREE (Mon/h) (Day) (Year) 123. DATE REPORT SENT (Mon/h) (Day) (Year) TO VITAL RECORDS ". - " 24. SIGNATURE OF TRANSCRIBING CLERK MORRIS 8< VEDDER 32 N. DUKE ST. YORK. PA. "-" ,'.,~ .-" . . r . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION: LAW KENNETH KARKER, Plaintiff No. 2000-4953 vs, TRACY L. KARKER, Defendant Action in Divorce NOTICE OF STAY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: You are hereby notified that on August 7, 2000, Tracy L. Karker, the Defendant above-named, filed a second divorce action in the Court of Common Pleas of York County, Pennsylvania captioned as "Tracy L. Karker, Plaintiff v, Kenneth Karker, Defendant" and indexed to Docket No. 2000 SU 03816-02D, York County is the county in which the last family domicile is located and Tracy L. Karker continues to reside in York County at the last family domicile. Under the Pennsylvania Rules of Civil Procedure, Pa,R,C,P. No, 1920,6, if a second action is brought within ninety days after service of the complaint in the first action, the court of the county of the last family domicile and in which one of the parties continues to reside is empowered to make the determination of which action is to proceed. As a result of the filing of the second divorce action, this action is stayed until the Court of Common Pleas of York County determines, based upon the purposes of the Divorce Code, which of the two actions shall be stayed and which shall proceed, Respectfully submitted, MORRIS & VEDDER DATED: September 5, 2000 BY: ~~~ &~,-Ved~, Esquire 32 N. Duke St. PO Box 544 York, PA 17405 (717) 843-9815 Supreme Court No, 32098 Doc. No. Cwv2873-2 I, II MORRIS & VEDDER 32 N. nUKE ST. YORK. PA. " _"w~""<_ "._,'o,-~ c,-'-<" ",.__.",'a' ,',,cj-, .'-,.",," ^"' -j:.,.,--, "c.-",;"~',-.~-.,;:;;'" ""'_'0'_\_ , < , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA1TIA CIVIL DIVISION: LAW KENNETH KARKER, No. 2000-4953 Plaintiff vs, TRACY L. KARKER, Defendant Action in Divorce CERTIFICATE OF SERVICE I, Tabitha K, Stayman, Secretary to Clyde W, Vedder, Esquire, of the law firm of Morris & Vedder, 32 North Duke Street, PO Box 544, City of York, York County, Commonwealth of Pennsylvania, 17405, do hereby certify that on this 5th day of September, 2000, I served a true and correct copy of Notice of Stay, by placing the same in the United States mail, postage prepaid to: Jarad W, Handelman, Esquire 134 Sipe Ave. Hummelstown, PA 17036 MORRIS & VEDDER BY~i~~~: -~~~~~rr:t~j to Clyde W. Vedder, Esquire II . ."~ . ~,. ~' . ... ~, - ~. - !il"! KENNETH KARKER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 00-4953 TRACY L. KARKER, Defendant : CIVIL ACTION - LAW : ACTION IN DIVORCE PRAECIPE TO WITHDRAW CAUSE OF ACTION TO THE PROTHONOTARY: Kindly withdraw the above captioned action filed by Plaintiff and docketed to the above captioned docket number. Respectfully submitted. JAMES, SMITH, DURKIN & CONNELLY LLP Date: September 19, 2000 j lJ-=> . JARAD W. H I.D, No, 82629 P.O, Box 650 Hershey, PA 17033 (717) 533-3280 Attorney for Plaintiff, Kenneth Karker -~ -- ,'", ~,., t_."" - " - ~"'. L_', , '__ -_--_,,',,= ";.-,-..J. ,," 0 ->.>i~<1 CERTIFICATE OF SERVICE I, JARAD W. HANDELMAN, ESQUIRE, do hereby certify that I serveq a true and correct copy of the foregoing Praecipe upon the following below-named individual(s) by depositing the same in the U.S. Mail, postage pre-paid at Hershey, Dauphin County, Pennsylvania this 19th day of September, 2000, SERVED UPON: Morris & Vedder Clyde W, Vedder, Esquire 32 North Duke Street York, PA 17401 ---:s~ JARAD W. HANDELMAN, ESQUIRE JAMES, SMITH, DURKIN & CONNELLY LLP