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Home My WebLink About03-0101JENNIFER J. KANN, Plaintiff MICHAEL T. KANN, : Defendant : IN DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03- / OI CIV LACTON_ LAW ~NOTICE TO DE_FEND AND CLAIM RIGHTs ~., You have been sued in court If ,,ou wis · · J ,, to uerena against the claims set forth in the rouow~ng 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 m · ,A j .udgment may also be entered aoain ......c ...... a.y be entered agmnst you by the Court. · . ~, ot 2,,~ ,u, any other clmm or rehefrequested in these papers t~y the Plmnt~ff. You may lose money or property or other rights important to you, including custody or v~s~tation 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days the date on which you receive this notice. Failure to do so will constitute a waiver of your right of request counseling, to IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Telephone (717) 249-3166 F:\FILES/DATAFILE/Gendoc cur\9220-2dcorn C~eated: 01/06/03 08:3358AM Revised: 01/06/03 03:I506 PM JENNIFER j. KANN, Plaintiff V. .' : MICHAEL T. KANN, : Defendant .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- /o / CIVILACTON_ LAW IN DIVORCE Pennsylvania. 5. 6. 7. ._COMPLAINT Plmntlffls Jennifer J. Kann, who currently resides at 922 Rockledge Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Michael T. Kann, who currently resides at 77 Mountain Lane, Newburg, Cumberland County, Pennsylvania. 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 11, 1999, in Newville, There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Date: MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243~3341 January 7,2003 Attorneys for Plaintiff averments, I may be subject to criminal penalties./ / / VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false JENNIFER J. KANN, Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. KANN, Defendant NO. 03-101 IN DIVORCE CIVIL ACTON - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Michael T. Kann at 77 Mountain Lane, Newburg, PA 17240 on January 9, 2003, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Michael T. Kann" and dated January 18, 2003. Ed~vard L. Schorpp, Esquire Sworn to and subsclibed before me this a~'~c~ay of January, 2003. ~iq:ota~ Public - ~ NOTARIAL SEAL TRICIA D. ECKENROAD, Notary Public Carlisle Boro., Cumberland County My Commission Ex[~ires Oct. 23, 2004 · 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. A~ticle Addressed to: [] Agent R. Received by ( C. Date of Delivery I-~-~3 D. Is delivery address different fi'om item 17 [] Yes If YES, enter delivery address below: [] No I 3. Service Type ~Certlfied Mail [] Registered [] Insured Mail [] Express Mail [] Return Receipt for Merchandise [] C.O.D. 4. Restricted Delivery? (Extra Fee) ,~Yes 2. Article Number - (Trensferfromservicelabe/) 7001 2510 0006 5862 9275 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-0835 Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To JENNIFER J. KANN, Plaintiff MICHAEL T. KANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-101 C1VILACTON- LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 7, 2003. 2. The mamage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301 (d) 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, lawyers fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divomed 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 and waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date: t~ - ~,~ Jea~er J.I~, Pla~ff / JENNIFER J. KANN, Plaintiff MICHAEL T. KANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-101 C1VILACTON- LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301 (c) of the Divorce Code was filed on January 7, 2003. I acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on January 18, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ning~4aysltave ' elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concermng ahmony, &ws~on of prop aw_r s fees or expenses if I do not claim them before a divorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301{d) 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, lawyers fees or expenses ifI 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 and waiver 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: ~, ~dg.~ ~~~~ Mich'~el-T I~ann, D/eeliendant JENNIFER J. KANN, Plaintiff MICHAEL T. KANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-101 CIVIL ACTON ~ LAW IN DIVORCE PRAECIPE TO TRANSMIT RECOR I J To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Code. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the complaint: certified mail, restricted delivery on January 18, 2003. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; June 9, 2003; by the Defendant; June 8, 2003. 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, if the decree is to be entered under Section 3301 (d)(1)(i) of the Divorce Code: Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 9, 2003; Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 9, 2003. Date: June 9, 2003 MARTSON DEARDORFF WILLIAMS & OTTO Edward L. Schorpp Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JENNIFER J. KANN Plaintiff VERSUS MICHAEL T. KANN Defendant NO. 03-101 DECREE IN DIVORCE DECREED THAT AND JENNIFER J. KANN MICHAEL T. KANN ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLL-OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. ~T