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Home My WebLink About03-1446Kenneth E Reppert Jr. : IN THE COURT OF COMMON PLEAS OF 50 Cacoosing Avenue : Cumberland County, PENNSYLVANIA Sinking Spring,Pa.19608 . (610) 927-9527 V. TERM Kelly A Reppert 112 North York Street NO. o: R- 1qq(- ,,U,L l ?Y1 Mechanicsburgh,Pa.17055 (717) 795-0667 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 or relief requested 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 at 1 Courthouse Square Carlisle,Pa.17013 (717) 240-6195 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 2 Liberty Ave. Carlisle,Pa.17013 (717) 249-3166 (800) 990-9108 Bar Association Forms 20 Kenneth E R'eppert Jr. :IN THE COURT OF COMMON PLEAS OF 50 Cacoosing Avenue :Cumberland County, PENNSYLVANIA Sinking Spring,Pa.19608 . j (610) 927-9527 V. (_ TERM Kelly A Reppert 112 North York Street Mechanicsburg,Pa.17055 NO. D,? - I y y G (717) 795-0776 COMPLAINT IN DIVORCE COUNTI REQUEST FOR DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Kenneth , who currently resides at 50 Cacoosing Ave. Sinking Spring, County of Berks, Commonwealth of Pennsylvania. 2. Defendant is Kelly , who currently resides at 112 N.York St. Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania. 3. Kenneth has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) month immediately preceding the filing of this Complaint. 4. The parties were married on the 8th day of Nov. . 1993, at Cumberland County Commonwealth of Pennsylvania . Attached hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage. Forms 23 5. Neither plaintiff not defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or for annulment between the parties except parties- 7. The defendant has been advised of the availability of counseling and the right to request that the Court require the parties to participate in Counseling. 8. The marriage of the parties is irretrievably broken. 9. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed from the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the I Divorce Code dissolving the marriage between Plaintiff and Defendant. I Forms 24 I COUNT R REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(13) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 are incorporated herein and made a part hereof by reference as though fully set forth. 11. Plaintiff and Defendant have reached an agreement on issues including None WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between Plaintiff and Defendant into the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. Plaintiff I verify that the statements made in this Complaint 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 unworn falsification to authorities. Plaintiff Date: 03 Forms 25 EXHIBIT "A" COPY OF MARRIAGE LICENSE Commonwealth of Pennsylvania SS: County of Cumberland I I, DONNA M. OTTO Is', DEPUTY , Clerk of the Orphans' Court in and for the County of Cumberland, Commonwealth of Pennsylvania, DO HEREBY CERTIFY That on the 8th day of NOVEMBER A.D. 1993, a Marriage License was issued for the marriage of KENNETH EUGENE REPPERT JR. Age 29 and KELLY ANN McGOVERN Age 25 Also that on the 8th day of NOVEMBER A.D. 1993, Duplicate Certificate signed by RONALD E. KLAIR DISTRICT JUSTICE was received and filed certifying to the solemnization of said marriage at MECHANICSBURG PA on the 8th day of NOVEMBER, 1993. Witness my hand and seal this 25th day of MARCH A.D. 2003 ?( Clerk of Orphans Court. COUNSELING NOTICE The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds; Section 3301 (a) (6) - Indignities Kenneth E Reppert Jr. : IN THE COURT OF COMMON PLEAS OF 50 Cacoosing Avenue : Cumberland County, PENNSYLVANIA Sinking Spring,Pa.19608 . (610) 927-9527 V. TERM Kelly A Reppert 112 North York Street Mechanicsburg,Pa.17055 = NO. (717) 795-0776 year Section 3301 (c) - Irretrievable breakdown- Mutual Consent Section 3301 (d) - Irretrievable breakdown -Two/Three separation A list of qualified professionals is available for inspection in Cumberland County Prothonotary!s Office 1 Courthouse Square Carlisle,Pa.17013 (717) 240-6195 Fonms26 1 .0 Kenneth E Reppert Jr. IN THE COURT OF COMMON PLEAS OF 50 Cacoosing Avenue ; Cumberland County, PENNSYLVANIA Sinking Spring,Pa.19608 . (610) 927-9527 V. Kelly A Reppert 112 North York Street Mechanicsburg,Pa.17055 (717) 795-0776 . TERM NO. AFFIDAVIT OF NON-MILITARY SERVICE E Re pp e r t Jr. , being duly sworn according to Law, deposes and says that he/she knows by his/her own personal knowledge and therefore avers that defen- dant,Kelly A Reppert 34 is years of age; that he/she is employed by UNKNOWN and that he /she is not in the military service of the United States or its allies, or otherwise within the provision of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. Plaintiff Kenneth Sworn to and subscribed before me this day of Mc?f1 , 20 03 Notary Public Notarial Seal Silver Spring Omer, No g Twp., Cumb?ry Public my Commiselon Expir e ty Member Pennsyivania Associat . 1 N s Forms 27 O Y v V Z (J _ (p { Kenneth E Reppert Jr. ; IN THE COURT OF COMMON PLEAS OF 50 Cacoosing Avenue Cumberland County, PENNSYLVANIA Sinking Spring,Pa.19608 (610) 927-9527 V. Kelly A Reppert NO. 112 North York Street Mechanicsburg,Pa.17055 (717) 795-0776 TERM 03 - 114gL &,LC 2a_'v- . ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce filed in the above-captioned matter. 20Q? ?CIG_j J:1 *end l& 2 North York Street Mechanicsburgh,Pa.17055 Forms 28 Kenneth E Reppert Jr. 50 Cacoosing Avenue Sinking Spring,Pa.19608 (610) 927-9527 V. Kelly A Reppert 112 North York Street Mechanicsburgh,Pa.17055 (717) 795-0776 : IN THE COURT OF COMMON PLEAS OF : Cumberland County, PENNSYLVANIA TERM NO. AFFIDAVIT AS TO SIGNATURE Kenneth E Reppert Jr. , being duly sworn according to law, deposes and says that he/she is the Plaintiff in the above-captioned divorce action; that he/she is familiar with the signature of the Defendant; and that the signature on the return receipt attached hereto as Exhibit "A" is the signature of the Defendant. Sworn and subscribed before me this &5 day of N\tk ?h 20 b'?) Notary Public Zla2 ? Plaintiff 50 Cacoosing Avenue Sinking Spring,Pa.19608 Shannon Cramer No4lary Public silver Spring Twp., Cumberland County My Commission Expires Oct. 11, 2004 Ifl-I '1111.1-1 csnr arinn of Notaries Forms 29 + M co -r Curtis R. Long Prothonotary (Office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 03 - /'1141 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573