HomeMy WebLinkAbout97-00265
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RICK A. MCKEE
Plaint if f
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL AC~I0N - LAW
NO. Q?-.1'S- CIVIL
IN DIVORCE
vs.
SAMANTHA A. MCKEE
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wiah 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 the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL
PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF
DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM
ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE.
IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Court Administrator
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
Telephone: (717) 240-6200
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RICK A. MCKEE
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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vs.
SAMANTHA A. MCKEE
Defendant
CIVIL ACTION - LAW
NO. 91,. ,J~, CIVIL
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(C)
AND 3301(Dl OF THE DIVORCE CODE
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1. Plaintiff is RICH A. MCKEE, an adult individual who
currently resides at 2781 Spring Rd. Carlisle, Pa. 17013.
2. Defendant is SAMANTHA A. MCKEE, an adult individual
who currently resides at 302 Sherwood Drive Carlisle,Pa. 17013.
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3. Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six
months in~ediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August
21, 1993, in Cumberland County, Pa.
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5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability
of counseling and that he may have the right to request that the
court require the parties to participate in counseling.
8. Plaintiff requests the court to enter a decree of
divorce.
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WHEREFORE, the Plaintiff requests the court to enter a
decree of divorce in favor of the Plaintiff and against the
Defendant.
Respectfully submitted.
O'BRIEN, BARIC & SCHERER
BY=-~~
Robert L. O'Brien, Esquire
Attorney for Plaintiff
I.D. If 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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I verify 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. t 4904, relating to
unsworn falsification to authorities.
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RICK A. MCKEE
Date:
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RICK A MCKEE,
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 97-265 CIVIL TERM
SAMANTHA A MCKEE,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT, ACCEPTANCE OF
SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1, A complaint in divorce under Section 3301 (C) of the Divorce Code was
filed on January 16, 1997,
2, Defendant acknowledged receipt and accepted service of the Complaint
on February 2, 1997,
3, The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
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4, I consent to the entry of a final decree in divorce without notice
5, 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,
6, 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,
7, I have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling, I do not request that
the court require counseling,
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,
Section 4904 relating to unsworn falsification to authorities,
Date: 0'2. eYe - \\)
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SAMANTHA A MCKEE