Loading...
HomeMy WebLinkAbout03-1034GRANT M. KEMP, Plaintiff Vo JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 0.5 -/0 3 9e CIVIL TERM : IN DIVORCE 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 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 in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 GRANT M. KEMP, Plaintiff Vo JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. O ~ -/ts 3~ CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Grant M. Kemp, an adult individual whose current mailing address is P.O. Box 128, Roxbury, Franklin County, Pennsylvania. 2. Defendant is Jeanette M. Rowan, an adult individual currently residing at 427 Newville Road, Newburg, Cumberland County, Pennsylvania. Plaintiff is a bonafide 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 September 23, 1989, in Shippensburg, Franklin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Ma~lbt~l(/I~as, Esquire Attorney foEPlaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: GRANT M.(. ~' M~~ntiff GRANT M. KEMP, Plaintiff JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-1034 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Jeannette M. Rowan, acknowledge that on or about March 26, 2003, I received a certified and tree copy of a Complaint in Divorce in the above captioned action, by certified mail, postage prepaid. Date: GRANT M. KEMP, Plaintiff JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW NO. 03-1034 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 7, 2003, and served on March 26, 2003 2. The 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. I 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 THE FOREGOING AFFIDAVIT 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. / · ~__J~ { GRANT M. KEMP, Plaintiff GRANT M. KEMP, Plaintiff JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-1034 CIVIL TERM : 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divome 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 THE FOREGOING AFFIDAVIT 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. / GRANT M. KEMP, Plaintiff JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-1034 CIVILTERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 7, 2003, and served on March 26, 2003 2. The 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. I 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 THE FOREGOING AFFIDAVIT 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: ~ ,.~0/o20'~3 J~E~. ROWAN, Defendant GRANT M. KEMP, Plaintiff JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 03-1034 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora final decree in divorce: without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorc, e 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 irrm'tediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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: NETTE M. ROWAN, Defendant GRANT M. KEMP, Plaintiff JEANETTE M. ROWAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-1034 : 1N DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following infomaation to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: certified mail, restricted delivery on March 26, 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: July 9, 2003 by Defendant: July 30, 2003 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff s affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 16, 2003 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: August 8, 2003 Attorney for Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUI~TY STATE Of GRANT M. KEMP, Plaintiff VERSUS JEANETTE M. ROWANt D~fendant pIENNA. NO. 03-.1034 CIVIL TERM DECREE IN DIVORCE AND NOW,~AI~ DECREED That Grant M. Kemp Jeanette M. Rowan AND IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF 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 EI~TERED; BY Th .F~U. rT: /;,/~' ~ ~/ PROTHONOTARY