HomeMy WebLinkAbout97-00448
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF 1~ PENNA.
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David Koontz,
Plaintiff
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....Shari Koontz
Defendant
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DECREE IN
DIVORCE
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AND NOW, 0.. . , ..1,"'!H.. , ~ 0.. 0 .. 0 .., " 19.. 9,7.., it is ordered and
decreed that 0 ,Oallid ,~QQnt:l; 000' 0 , , 0 0 , 0 0 0 0 0 , , '000000000' 0000000. plaintiff,
and, Shari. Koontz, , , , . , . , '0' 0 0' 0 . . , . . , O' , O' 000' , . , . , , 0 , . 0 0 . 00, defendant,
are divorced from the bonds of matrimony,
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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; None
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IN THE COCRT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David Koontz,
Plaintiff
No. 97-448
CIVIL ACTION - LAW
, '
VS.
IN DIVORCE
Shari Koontz,
Defendant
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
3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Service
was made by Certified Mail Return Receipt Requested on January
31, 1997 and was accepted February 3, 1997. An affidavit of
service was filed on February 5, 1997.
3. Date of execution of the affidavit of consent required
by section 3301(c) of the Divorce code; by the plaintiff 5/23/97;
by Defendant 5/20/97.
4. Related claims pending: None.
5. Date
file praecipe
the decree is
Divorce Code:
and manner of service of the notice of intention to
to transmit record, a copy of which is attached, if
to be entered under section 3301(d) (1) (i) of the
No notice was required in this case.
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H. Anthony dams,
Attorney for Pla'
128 E. King Street
Shippensburg, PA 17257
(717)-532-3270
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David Koontz,
Plaintiff
VS.
NO. q',. "i 'I f {!(.i.J -r.,t.I~
CIVIL ACTION - LAW
IN DIVORCE
Shari Koontz,
DEFENDANT
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1.
Plaintiff is David Koontz, who currently resides at 3 North
Morris Street, Shippensburg, Cumberland County, Pennsylvania,
since September 17, 1990.
2.
Defendant is Shari Koontz, who currently resides at 332
Meadow Drive, Shippensburg, Franklin County, Pennsylvania, April
1996.
3.
Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately
previous to the filing of this complaint.
4.
The Plaintiff and Defendant were married on September 17,
1982, in Shippensburg, Cumberland County, Pennsylvania.
5.
There have been no prior actions of divorce or for annulment
between the parties.
6.
The marriage is irretrievably broken.
7.
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.
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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. Section 4904 relating to
unsworn falsification to authorities.
Date: dlh-)
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David Koontz
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
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David Koontz,
plaintiff
NO. 97-448
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: CIVIL ACTION - LAW
VS.
: IN DIVORCE
Shari Koontz,
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under section 3301(c) of the
Divorce Code was filed on January 27, 1997.
2. The marriage is plaintiff and Defendant is irletrievably
broken and ninety days have elapsed from the date of filing of
the complaint.
3. I consent to the entry of the final decree of divorce
after service of notice of intention to request entry of the
decree.
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.
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Date: ~ Cfl r-1.) \&
~avld Koontz
plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David Koontz,
plaintiff
NO. 97-448
CIVIL ACTION - LAW
VS.
IN DIVORCE
Shari Koontz,
Defendant
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 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: Slo?/B-l
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plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David Koontz,
Plaintiff
VS.
NO. 97-448
CIVIL ACTION - LAW
Shari Koontz,
Defendant
IN DIVORCE
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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 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,
r.
Date: 5 'y{)-Cj I
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David Koontz,
PLAINTIFF
NO. 97-448
CIVIL ACTION - LAW
VS.
IN DIVORCE
Sherri Koontz,
DEFENDANT
AFFIDAVIT OF SERVICE
H. Anthony Adams, Esquire, being duly sworn according to law
deposes and states that a complaint in divorce was mailed to
Sherri Koontz of 332 Meadow Drive, Shippensburg, Franklin County,
Pennsylvania, certified mail, return receipt requested on January
31, 1997 and was accepted on delivery by Sherri Koontz on
February 3, 1997 as shown by the attached receipt.
H. Anthony Adams
Attorney for Pla nti
128 E. King street
Shippensburg, PA 17257
532-3270
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S~lorn to and subscribed this
5 h day of February,. 1997.
NOTARIAL SEAL
DAWN MARIE SHOOP. NOTARY PU8L1C
Bhlpperltburv, Cumbtrllnd County. PA
My Commlallon Explr.. Flbrulry 5. 2000