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Home My WebLink About98-01889f ?, ?M t?ItIKt 1 ;Is 'a (711) 743-4190 FM (117) 24).)518 KRISTEN K. McGEE, Plaintiff V. CHRISTOPHER M. McGEE, Defendant ..-.... ? pig IN THE 'COURT OF COMMON PLEAS OF : CUMBERLAND COUN'TY,PENNSYLVANIA CIVIL ACTION -- LAW NU. 7n 1m%l/l.8V11, rr:Km : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE I. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that 1 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. 1 understand that 1 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 unswom falsification to authorities, Date:_ 1ggS r:???QQl_ () Kristen K. McGee, Plaintiff I , f I t,! 1 1 L 1" ?~ I Ir 1? ? 1 Y t ? 1. i ? l (1 V+ 1 1 tl 6.. I 1 5f I 1 t .f " ? 1 jrr 1 ,?f r f f ?..? t +S5J 1 k 1 ° ? '? ns.v 1 ? r.i? 1 r I i?"i,? a l ?f ? 1 f ? ? I I 1 OW C I A Ca. I I? i 5 .I ' Ir Il 1: I f. 1 5 , 1 tAw Waca 01 agoWhie M: Verne ?ttt14? M?1M111 ? (717)241.9190 # FAX(717)I/IdSU KRISTEN K. McGEE, : IN'rHE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : CIVIL ACTION - LAW' ) CHRISTOPHER M. McGEE, : NO. 98-1889 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONS . ' I, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 6, 1998. 2. Tl:e marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3, 1 consent to the entry of a 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. Date; -Ja? Kristen K. McGee, Plaintiff 3a1Ssk{ t3 i 1 e . e gold iA Vunoubain w• .Ap, to1a mMV1 °.?-klYt owkf Z4im Ri t t l ?'?e ? y.t 4r J S ?e k r ? , I i. r,t I 1t R ' i 1 t '' I 1 R, 1 I 1 h Y' I VVV Ir , 1 , i ?I i • I t i' ,I I r 1 I . I r . . ,?N' KRISTEN K. McGEE, Plaintiff vs. CHRISTOPHER M. MCCEE, Defendant s IN Tim COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ; CIVIL ACTION - LAW NO. 9&1889 CIVIL TERM s s IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa.R.C.P. 1920100Xii1 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND 1, Jacqueline M, Verney, Esquire, being duly swom according to law, deposes and says that she is the attorney for plaintiff, Kristen K, McGee, and that she did serve a true and correct copy of the divorce Complaint that was filed in the above matter, by U,S, mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the defendant, Christopher M, McGee, on April 10, 1998, The receipt form is attached hereto as EXHIBIT "A'". eq cline M. Vomey, E 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Sworn to and subscribed before me this; _ day of M I 1 1998, a wl El Nof6y Public NOTA" L L LD 9E PINAMCNT I, Notary Publlo e Borough, Cumberland County mmss-or, Expires Nov. 20, 2000 I '. epphgNe Nima I widow 2 br admww sansm, I also 'Meh to recelw the a ft" s, Me, and eb. following eeNfoas (for an WYMO eerd p rwfre and wldreaa on dw 3ewxee of this roan a nel we can mri m Iwo extra fee)' 4! eMUmaiMhtI 4 loan w the IMM w me 1114110m, or an the back If wave does not 1.13 Addressee's Address eN'INe'NMum soap aeeueeNd'on the ndlplaa below ea ankle numb.. 2. M-Aestrlded Delivery aft Plum qc Cpl WIN Naw to wham Me arMda woe eWwnd W ft dab ' dalmo. CorwuN Pbebnaebr for Ise. Addressed to: 4. Amide Number //r II / g 56 .? ldsco ?lva..v, n.eftoT (??,Q l (/? (Pu• q 0 Express Mall 0 Insured ? Rehm ReayN for Merdlendes 0 CAD 7. Date o livery Yr?-5v' R eve W By: (Mf Norm) 8. rewash Address req- and f" It pall) P PS Ram 84911DscsmWrIM IOY69507-130179 omea o Return evept KRISTEN K. McGEE, : IN THE COURT' OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 98-iSytI CIVIL TERM CHRISTOPHER M. McGEE, Defendant ; IN DIVORCE NOTICE TO DEFEND AND CLAIM RliiHTS You have been sued in Court. 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 will proceed without you and a decree in divorce or annulment may 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 or 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL. PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, Pennsylvania 17013 (717) 249-3166 KRISTEN K. MCGEE, Plaintiff V. CHRISTOPHER M. MCGEE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION _ LAW NO. 98. / F'1'1 CIVIL, IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Kristen K. McGee, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following; 1. Plaintiff is Kristen K. McGee, an adult individual, whose permanent address 30 Hamilton Road, Boiling Springs, Cumberland County, Pennsylvania 17007, 2, Defendant is Christopher m. McGee, an adult individual, currently residing at 503 Broadway, Pella, Iowa 50219. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on June 10, 1994 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6, Plaintiff is presently enlisted in the United States Air Force. 7. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling, Having been so advised Plaintiff does not desire the Court to order counseling. 8. This marriage is irretrievably broken, WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce, VERIFICATION verify that the statements made in the within Complaint are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Sec, 4904 relating to unworn falsification to authorities. Dated: 28 March 1998 Q r?> Kristen K. McGee i i i i S rJ V ORIGINA' SEP 14 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBRA E. RALPH Plaintiff No. 95-1889 Civil Term V. : CIVIL ACTION - DIVORCE DAVID E. RALPH Defendant RULE Re: Plaintiff's Petition to Bifurcate Divorce Proceedings AND NOW, to wit, this L?day of , 2009, upon consideration of the within Plaintiff's Petition to Bifurcate Divorce Proceedings, a Rule is entered upon the Respondent, David E. Ralph, to show cause why the divorce proceedings should not be bifurcated and a Decree in Divorce under Section 3301(d) of the Divorce Code entered. RULE RETURNABLE at a hearing to be held on the J? day of 2009, at S- 00 o'clock P M. in Courtroom Cumberland County Courthouse, Carlisle, Pennsylvania. The parties are directed to appear at that date, time and place and give testimony on their respective positions as to why the relief requested in the within Petition for Bifurcation should not be granted. DISTRIBUTION TO: ? Attorney for Plaintiff: Diane G. Radcliff, Esquire, 3448 Trindle Rd., Camp Hill, PA 17011 Attorney for Defendant: Kelly A. Sparvieri, Esquire, 210 Grandview Avenue, Suite 102, Camp Hill, PA 17011 0.0 Ql?sF 's m"a E L?--L l? FILED- L;r rNCE OF THE ;?C17:'ONO?ARY 2009 SEP 15 PHI 3: 27 C=Jf??? . ?Iz,f; ;, `,,fir, 'i'LV 34I