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HomeMy WebLinkAbout01-4687JASON LEE KNOUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: ; ' ' ROMI SUE. KNOUSE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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 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 of 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 grounds 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. 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 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 BELOWTO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JASON LEE KNOUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROMI SUE. KNOUSE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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 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 of 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 grounds 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. 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 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, PA 17013 Telephone: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JASON LEE KNOUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ROMI SUE. KNOUSE Defendant COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Jason Lee Knouse, and files the within Complaint against the Defendant, averring as follows: Count I - Under Section 3301 (c) and 3301 (d) of the Divorce Code 1. Plaintiff is Jason Lee Knouse, an adult individual who currently resides at 235 North Locust Street Point Road, Apartment 1, Cumberland County, Pennsylvania Plaintiff has lived at said address since September 1, 2000. 2. Defendant is Romi Sue Knouse, an adult individual who currently resides at 3221 Grey Fox Circle, York, York County, Pennsylvania 17401. Defendant has lived at such address since May, 2000. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 19, 1997, in York County, Pennsylvania 17401. 5. The Plaintiff and Defendant are both citizens of the United States of America and are not members of the Armed Forces. 6. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 7. This action is not collusive. 8. Plaintiff has been advised of the availability of counseling and understands that he may have the right to request that the Court require the parties to participate in counseling. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce pursuant to Section 3301(c) or Section 3301(d) of the Pennsylvania Divorce Code of 1980, as amended (the "Divorce Code"). PLAINTIFF: /~on Lee Knouse JASON LEE KNOUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: ':~/- ~/~7 C/~/~ ROMI SUE. KNOUSE Defendant ACCEPTANCE OF SERVlCE I, Romi Sue. Knouse, the Defendant in the above-captioned transaction, do hereby accept service of the Complaint For Divorce. Ro/~'i Sue K~ouse' / ---- Date: I also wish to receive the fo ow- ing services (for ~n extra fee): 1. [] Addressee s Address 2. J~lestricted Delivery ~ 3. Article AG~ea,~ud to: ~-~ / 14a. Article Number 4b. Service Type 13721 ~.~.~'~ ~'0)~ e[~.~} /FiRegistered XCe.ified I' ~ Express Mall ~ Insured ~: 17 Date of Delivo~ ~ . R~iv~ ~ (Pdnt Name) [8. Addre~ee's ~dre~ (~if r~uest~ aod EXHIBIT A JASON LEE KNOUSE, Plaintiff ROMI SUE KNOUSE Defendant IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4687 CIVIL ACTION . LAW IN DIVORCE TO THE PROTHONOTARy: Transmit the record, together With the following information, to the COurt for entry of a divorce decree: Divorce Code. 1. Ground for divorce: Irretrievable breakdown Under § 3301(c) of the 2. Date and manner of service of the Complaint: Acceptance of service was sent to the Plaintiff on AUgust 23, 2001 by United States Mail Certified Restricted Del/very. Service accepted by Plaintiff on AUgust 24, 2001. Acceptance of Service was filed With the Prothonotary October 25, 2001. 3. Date of execution of the Affidavit of Consent and Waiver of Counseling required by § 3301(c) of the Divorce Code: by Plaintiff, December 26, 2001; by Defendant, December 14, 2001. The Plaintiff's Affidavit of Consent and Waiver of Counseling is being filed contemporaneously herewith. The Defendant,s Affidavit of Consent and Waiver of Counseling is being filed contemporaneously herewith. 4. Date of execution of the Waiver of Notice of Intent to Request Entry of a Divorce Decree as required by § 3301(c) of the Divorce Code: by Plaintiff, December 26, 2001, by Defendant, December 14, 2001. The Plaintiff'S*Waiver of Notice is being filed contemporaneously herewith, being filed contemporaneously herewith. DATE.. The Defendant,s Waiver of Notice is JASON LEE KNOUSE, Plaintiff ROMI Sue. KNOUSE Defendant IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTY, PENNSYLVANIA NO. · CIVIL ACTION . LAW · IN DIVORCE ~SEN ~WAIV T AND 1. A Complaint in Divorce Under Sect/on 3301 (c) of the Divorce Code was filed on ~. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed Since the date of filing and service 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· 4. I have been advised of the availability of marriage counseling Understand that I may request that the Court require that my spouse and and I Participate in COUnseling· I further Understand that the Court maintains a list of marriage COUnselors in the Prothonotary,s Off/ce, Which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I Participate in counseling prior to a decree being handed down by the Court. I redly 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:~ ~ JASON LEE KNOUSE, Plaintiff ROMI SUE KNOUSE Defendant IN THE COURT OF' COMMON PLEAs OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O%4687 DA TE..~ CIVIL ACTION . LAW IN DIVORCE ENTRY OF A D INTENTION TO I~VORcE D RE UE 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 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 vet/fy 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 JASON LEE KNOUSE, Plaintiff ROMI SUE KNOUSE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 01-4687 CIVIL TERM CIVIL ACTION _ LAW IN DIVORCE 1. A Complaint in Divorce Under Section 3301('c) of the Divorce Code was filed on August 06, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I Participate in COunseling. I further understand that the Court maintains a list of marriage COunselors in the Prothonotary,s Office, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I participate in counseling Prior to a decree being handed down by the Court. I vedfy 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 falsifi · authon DATE ~~___~ r'~° , 'ties JASON LEE KNOUSE, Plaintiff ROMI SUE KNOUSE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4687 CIVIL ACTION _ LAW IN DIVORCE ~RnOcF.N~O,,T.I_c_E_OF INTENTION TO RE UEST ENTRY OF~ OF TH~ 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 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. ~ 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°//Fli Sue.~:nouse; i~efendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ....... JASON LEE KNOUSE Versus ..... ROMI SUE KNOUSE DECREE IN DIVORCE decreed that .......JAs. o.~ LEE KNOUSF. ordered and nd ................a0az. SOS.z~OUSE ................. . plaintiff, are divorced .......~._ L ._ . ' ......................... , defendant, f-.,,,, ,,,e oona5 ot matrimony. 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; The Court retains jurisdiction of any pending economic either party. ' ....................... ......... ' ........ ;r.a,t.s.e.d..by.,