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HomeMy WebLinkAbout02-5730Kirk A. Ramsey, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ~_ . Kim L. Rameey, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You ate 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 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 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 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, PA 17013 (717) 249-3166 James A. Miller, Esquire Attorne~/,,6r Plaintiff Christopher J. Keller, Esquire Attorney for Plaintiff Kirk A. Ramsey, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ~::~,~ -- : Kim L. Ramsey, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCF 1. Plaintiff is Kirk A. Ramsey, who currently resides at 21 Clover Lane, Mechanicsburg, Pennsylvania 17055. 2. Defendant is Kim L. Ramsey who presently resides at 4307 Hazlitt Court, Charlotte, North Carolina 28269. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 22, 1988, in Cumberland County, Pennsylvania. parties. There have been no prior actions for divorce or annulment between the 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. COUNT 2 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODF 11. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 12. The parties have been separated since May 5, 2000; a period in excess of two (2) years and the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to: a) enter a decree dissolving the marriage between Defendant; Plaintiff and Respectfully Submitted, Law Office of James A. Miller BY: c"~'J~es A. Miller, Esquire /~ttorney for Plaintiff //2157 Market Street // Camp Hill, PA 17011 ~ (717) 737 6400 BY: Christophe,~/J. Keller, Esquire Attorney for Plaintiff 2157 Market Street Camp Hill, PA 17011 (717) 737 6400 VERIFICATION I verify that the statements made in this Divorce Complaint 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: Kirk A. Ramsey, Plaintiff Vm Klm L. Ramsey, Defendant : IN THE COUR'r OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5730 CIVIL TERM : · CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Christopher J. Keller, Esquire, hereby certify that I have served the Defendant, Klm L. Ramsey, with a certified copy of the divorce complaint on December 17, 2002, by certified mail number 7001 1140 0002 12.74 5302 as evidenced by the attached original United States mail return receipt. 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.A. Section 4904, relating to unsworn falsification to a~uthorities. Christopher J. ,Keller, Esquire ~---~... Attorney for Plaintiff Supreme Court ID 86889 2157 Market Sb'eet Camp Hill, PA 17011 (717) 737 6400 · Complete items 1, 2, and 3. Also complete itshn 4 if Restricted Delivery is desired. · Print your[lame and address on the reverse so that we can return the card to you. · At~ach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Received by (P/e~e Print Clearly) B. Date of Delivery [] Agent [] Addressee 17 1'3 Yes enter daiiw~ry below: [] No Certified Mail [] Express Mail [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Reetri~ed Deliver)? (Extra Fee) ~/Yes 2. A~d¢leNumber 7001 1140 0002 1274 5302 PS Form 381 1, March 2001 Domestic Return Receipt 1025~5-01-M-1424 Kirk A. Ramsay, Plaintiff V. Kim L. Ramsay, Defendant · IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5730 CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) and Section 3301(d) of the Divorce Code was filed on December 2, 2002 and service was obtained upon the defendant by certified mail number 7001 1140 0002 1274 5302 on December 17, 2002 and Affidavit of which was filed with the Prothonotary on January 29, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. 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.A. Section 4904, relating to unsworn falsificat~orities. Date: .~ '1/ ' ~ - KirkA. Ramsay Kirk A. Ramsey, Plaintiff Kim L. Ramsey, Defendant · IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5730 CIVIL TERM · CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDEE SECTION 3301(c) OF THE DIVORCE CODF 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 I 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification of a,~~ Date: ~~, - Ki/~k A-R~msey~ Kirk A. Ramsey, Plaintiff Klm L. Ramsey, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5730 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) and Section 3301 (d) of the Divorce Code was filed on December 2, 2002 and service was obtained upon the defendant by certified mail number 7001 1140 0002 1274 5302 on December 17, 2002 and Affidavit of which was filed with the Prothonotary on January 29, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. Date: Kim L. Ramsey Kirk A. Ramsey, Plaintiff Klm L. Ramsey, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02.5730 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 I 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification of authorities. Kim L. Ramsey Kirk A. Ramsey, Plaintiff V. Klm L. Ramsey, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5730 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORI3 Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground f or divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner service of the Complaint: A complaint in Divorce under Section 3301(c) and Section 3301(d) of the Divorce Code was filed on December 2, 2002 and service was obtained upon the defendant by certified mail number 7001 1140 0002 1274 5302 on December 17, 2002 and Affidavit of which was filed with the Prothonotary on January 29, 2003. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: April 18, 2003 by Defendant: May 16, 2003 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: April 24, 2003 by Defendant: June 4, 2003 4. Related claims pending: There are no related claims pending. Respectfully Submitted, Law Offices ~f James A. Miller By: /~/ Ja~s A Miller, Esquire At~mey for Plaintiff .~/f57 Market Street JCamp Hill, PA 17011 (717) 737-6400 STATE OF Kirk A. Ramsey, IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY '.e~~ PENNA. Plaintiff VERSUS Kim L. Ramsey, Defendant N O. 02-5730 DECREE IN AND NOW, DIVORCE , IT IS ORDERED AND DECREED THAT AND Kirk A. Ramsey Kim L. Ramsey , PLAINTIFF, , 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/a ATTEST: ~~-~-~--*-,,----^~*---.. .. ._ _ . _. ¥¥-~.~- +++++ +++++++ + ++~ PROTHONOTARYi~~~j