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Home My WebLink About97-05933 ~ ~ ( [ ~ ~ . ~ ~.. "~ ( ~ t ~ :" .. ..~ .. ~ .., .., t; . t"- ~, ~ if All,. ..,o.",A:,." ' . . . , "-"'~- '- -:~--r;~~1~I!i'h~, ;; "-0 -.' ~-".....,...- '_c, ~,.,-,- ;~l<b-"", ...""....'-.--"".i~:.,.....,,._~......,..__~ (, *.*.~_.~.*~"~,~*,~..~'~"~'~ . ------~._~-~......~.-.-....-~---~~--~-....~~.-~ -,~,,-~_.~,.~ '-'" ,~--- !!I ~ ~o ~i . ! Mi 0' !ill ~I !iI! : I !!II ~ ~ ~ -:.;0 .:<<0 .:<<. :. ';0,:0 o;oc...:';' .:c. o;oe. ,:Co o;c. _ 'lW 11 . . oW -'-i' ~* * . . 8 8 8 8 8 8 it 8 8 8 ~ r, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~t PENNA. ROGER L. KUMLER. JR" [\;0. 97-5933..,., 19 Plaintiff ~o ,;, ., \'l'l':-illi TAMMY L. KUMLER. ,;, ., Defendant ~ ~ ~ ~I ~l ~ -:0 8 ~ ~ ~ 8 ~ ~ ~ ~ ~ ~ M " ~ ~ * ~ ~ - - - - , . - ' : ',.,' - . ," . ;. .,., ..,:.,.. 0' ,>..:. .-. ..,<<. .>>e. .:.e;. ... .::.:. .::.t:. ':'.' '..~' ,:.;. ..... ..... ..... ..... ....' a DECREE IN 8 D I V 0 R C E t ;.' V9; fA. : AND NOW, ~ o..~ . 0 0 . . . ..00 ""0 ~PQQ it is ordered and 1~ decreed that..... 0 0' .~QG!,Ro 01,.'0 .1\l!~I!.ER.. JR..o 0 0 0..0000000'. 0 0, plaintiff, l!I 8 and 0.00.0.0'.0000.000 TM1MYo L.. ol<UHLER. 0 0.....0000.00... o. 0, defendant, ~ are divorced from the bonds of matrimony. . 8 . 8 . . . . . . . 8 * . ._-- . ,:.;.:.;, ':.;, -:.:' ':.;. -:.:- ':.;, -:.:- .:+:. .:.:. .x. .... .. .. 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; ,..................... ...... .... .... .... ...... .... ...., "..........,.......... ...... ..... .... .......,. RJ. Prolhonotary ,r . ~ ,. 3~.CO M.~~-d- 4~ .3'dOl'~ ~~ /~; Z Jf &4 Ii .. ROGER Lo KUMLER, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO, 97.5933 CIVIL TERM TAMMY L. KUMLER, Defendant : CIVIL ACTION. LA W : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of Divorce Decree: I. Ground for Divorce: Irretrievable breakdown under ~3301(c) of the Divorce Code. 2. Date and Manner of Service of Complaint: Service was accepted by Daryl J. Gerber, attorney for the Defendant on the 3'" day of November, 1997, pursuant to an Acceptance of Service filed November 20, 1997, 3. Date of execution of the Affidavit of Consent required by 93301(c) of the Divorce Code: by Plaintiff on January 18, 2000 ; by Defendant on January 18, 2000. 4, Related Claims Pendin\l: All other claims have been withdrawn by either party, 5. Date Plaintiff's Waiver of Notice in 63301(c) Divorce was filed with the prothonotary: Dated January 18, 2000 and filed herewith, Date Defendant's Waiver of Notice in 9330l(c) Divorce was filed with the prothonotary: Dated January 18, 2000 and filed herewith. Date: 1-.1 \-0 0 Plaintiff's Social Security No, 203-54-0038 XlrALJV...ft( 0 t-J .1lIJLfU.. ) Jenrlifer L. (ehman. Esquire Attorney for Defendant's Social Security No, 198-56-7360 , " " "I 1:; ,,~ 1'-' , .. ~_~i - ~~)~ '-) :;~.. ....::: ')~ "- -, .f'n '",.:. .J::.... ,<z 'ha )0_ , t:" :3 .:..::J '-' i'l p , . J Vo IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. '17 - 5"9 33 f!iv.J T IMrV ROOER l. KUMLER, JR, Plaintiff TAMMY Lo KUMLER, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Courto 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 Courto A judgment may also be entered against you for any other claim or relief r~quested in these papers by the Plaintiff. You may lose money or property or other rights important to YOUo When the ground for 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. 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 THEMo 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 HELPo Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 97- 5"933 6:uJ I~ ROGER L. KUMLER, JR., Plaintiff TAMMY L. KUMLER, Defendant : CIVIL ACTION - LA W : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301ld) OF THE DIVORCE CODE I. Plaintiff is ROGER L. KUMLER, JR., currently residing at 242 Susquehanna A venue, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is TAMMY L. KUMLER, who is residing at 42 Stephen Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 9, 1991 in New Cumberland, Cumberland County, Pennsylvania, " 5. Plaintiff avers that there is one child of the parties under the age of 18. Namely Roger Kumler, III, born December 14, 1992, 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Anned Forces. 8, The Plaintiff and Defendant are both citizens of the United States. 9, Plaintiff has been advised of tile availability of marriage counseling and that he may have the right to request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. COUNT I . DIVORCE 10, Paragraphs 1 . 9 are herein incorporated by reference, 1 \. The Plaintiff avers that the grounds on which the action is based are as follows: (a) That the marriage is irretrievably broken. (b) The parties are currently living separate and apart; at the appropriate time, Plaintiff will file an affidavit alleging that the parties have lived separate and apart for at least two years and that the marriage is irretrievably broken. WHEREFORE, PlaintilTrequests the Court to enter a Decree of Divorce. Respectfully submilled, d JE NIFER L. LEHMAN, ESQUIRE Attorney 1.0. #52784 Suite 207 3540 North Progress A venue Harrisburg, P A 17010 (717) 671-1200 , Date: 10 d<J.-<i7 ti VERIFICATION I verilY that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pao CoS, ~ 4904 relating to unsworn falsification to authorities. ~.L~~ R GER L. KUMLE~ JRo Date: Infl~Jcl7 I I u '-' ~ ('1\ - "0 t><> ~ ~I.r, '" ~ ~ ~ ~~ ~ ~ ol4= il , . v. ; IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 97.5933. CIVIL TERM ROGER L, KUMLER, JR.. Plaintiff TAMMY L. KUMLER, Defendant : CIVIL ACTION. L.\ W ; IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce filed on October 27, 1997 in the above action, I certify that I have been authorized by the Defendant to accept service. By;C-y \L\N,\ ~ r1 ~ Daryl J. Gtber squire 46 East Main Street Palmrya, PA 17078 Dated: II /j I '17 .. >- C") :- cr, N t-- ~ 7 lLl~) i~ ~~_1 c:," '-' , Hi "= , ( g,r ! .. , .. I'":) " C'v ".' w', u. -'. -'. :.-}2 G:~.t C::O .'. ..~ ll. ,.... :s 0 C11 U II ! i I i I i I ..... "I ~ (T !r.. i,;~; .. ...) - 6~ ;S :,~ .- ,., ". ""-:1 ."5- .... ':n "oJ ":c,~ ~j(a ..: "a... '. ;.:." ::5 I~-_) U /0 ~ '>- <:'1 is li". ,. ::1<r .- I }-;') . ", ,..1 :"l~ ...::: :",-;:j .-;,... ~ S'~ (~ -~ :(IJ in. c-:' .,; c.) C,) v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 97-5933 - CIVIL TERM ROGER L. KUMLER, JR" Plaintiff TAMMY L, KUMLER, Defendant : CIVIL ACTION - LA W : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(~\ OF THE DIVORCE CODE I. 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! 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. 94904 relating to unsworn falsificAtion to authorities. Date:-1::j 8-00 ~a.ryy\J~i~0l,/\' 1ri4.'tlti&1 AMMY L. K LER DEFENDANT ~ " ,- "I f=; Lr. ~ '. ~'3..,... -- - I)y :r: ' .} :'f~ ''''=: _-!i'.;i I ,-. -- N ',~ -.., I ~ .. , :'!{Q .... lCl. '- (::> .:..:) c::> (J o;:/!. \j -- ""t: '>- - aJ ',- ~ Lo -'l , ; -- 0 (- , , t'" ~...' , 0 '"'1 0- ) -- ..1: X; , ,.; g ... U, i..< ~ .. -~ I ()' ^. /,: (':1 . . 8 L;" ,,, L'-!\ :.. , 1- i f ~: " "',, (-) ;.;::- ''"-- L'- '1': .~ .J r- ._) () 0' u CJ 0: 5 ~ III ~ aI <( 0: .J III ~ ~ i C) Ul c ~ III ! . dl c . .. :I · w . I- Z ~ ~ 0 0: c Z ~ w C . <( .. . 0: <( . 3 a1 ~ VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROGER L. KUMLER, JR. PLAINTIFF TAMMY L, KUMLER DEFENDANT NO. 97-5933 CIVIL TERM TO: Roger L. Kumler, Jr., Plaintiff Date of Notice: November 3, 1997 NOTICE TO PLEAD YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. c9~ nl~ Daryl J. r et, Esquire 46 E. Main Street Palmyra, PA 17078 Attorney 1.0. No. 21372 Attorney for Defendant " ROGER L. KUMLER, JR. PLAINTIFF VS. TAMMY L, KUMLER DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-5933 CIVIL TERM ANSWER TO COMPLAINT IN DIVORCE AND NEW MATTER 1. Admitted. 2. Admitted 3 . Admitted 4. Admitted 5 . Admitted. 6 . Admitted. 7. Admitted, 8 . Admitted. 9. Admitted. 10. No response required. 11. Admitted, NEW 'MATTER COUNT I - EOUITABLE DISTRIBUTION 12. Paragraph a (1) through (11) and the answers thereto are incorporated herein by reference thereto. 13. plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the Court. WHEREFORE, :>efendant requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties. COUNT II - ALIMONY PENDENTE LITE. COUNSEL rEES AND COSTS 13. Paragraphs (1) through (12) are incorporated herein by reference thereto, 14. Defendant has retained an attorney to represent her in this action and has agreed to pay him a reasonable fee. 15. Defendant is not financially able either to meet the expenses and costs of this action or the fees to which her attorney will be entitled in this case. 16, Defendant has insufficient income and assets to provide for her needs, 17. The costs and expenses incurred in this litigation have become and will become onerous in the future, making it difficult for the Defendant to maintain and support herself, as well as her children, during tha pendency of this action. WHEREFORE, Defendant requests your Honorable Court grant alimony pendente lite, counsel fees and expenses. COUNT III- PERMANENT ALIMONY 18. Paragraphs (1 ) through (17) are incorporated herein by reference thereto, 19. Defendant has insufficient income and assets to provide for her needs. 20. Plaintiff is well able to provide for Defendant's needs, but has refused or otherwise failed to provide for same on a voluntary basis. WHEREFORE, Defendant requests your Honorable Court to award Defendant permanent alimony. Daryl J. Attorney for efendant 46 E. Main Street Palmyra, PA 17078 I.D. No, 21372 717/838-5411 VERIPICATION I verify that the statements made in the foregoing Answer to Complaint and New Matter 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. ~1I'i'^'W1~'1<1~ Tammy L, Kumler Date: \ \- \\- ~ 1 ">- en -- IT. .;l to,; f:, (-~ : .~ ..r ,- t...,l.... - 00 ~: .. l~ -_' l r-- ",,( , .. (~ C' J-- 0' r:? . .; '-' '" - . :'L-, -, b .'hD u-':. ,_,!LJ- \:: 7- -~ \S r- :;) t:r U VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION . LA W ROGER L. KUMLER, JR, PLAINTIFF T AMY L. KUMLER DEFENDANT : NO. 97.5933 CIVIL TERM TO THE PROTHONOTARY: PLEASE WITHDRAW ALL ADDITIONAL COUNTS FILED AS NEW MATTER IN THE ABOVE CAPTIONED MATTER. "-~ Daryl J. Gerb r, quire 46 E. Main Street Palmyra, PA 17078 717.838.5411 1.0. No. 21372 Attorney for Defendant , Date: February 16,2000 .