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Home My WebLink About00-05332 ANNIE A. KROL-KNIGHT, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 5,3:S.;t CIVIL 2000 STEPHEN MARK KNIGHT, DEFENDANT CIVIL ACTION - LAW ACTION FOR 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET fORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator Fourth Floor Cumberland County Courthouse CarlislePA 17013 (717) 240-6200 ';>''''=~'''''''''t ~,~ ANNIE A. KROL-KNIGHT. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. !)fJ. 53 3,,2. CIVIL 2000 STEPHEN MARK KNIGHT, DEFENDANT CIVIL ACTION - LAW ACTION FOR DIVORCE COMPLAINT FOR NO-FAULT DIVORCE UNDER 3301(c) OF THE DIVORCE CODE 1, The Plaintiff is ANNIE A. KROL-KNIGHT, who currently resides at 2 Richland Lane, Apt. 208, Camp Hill, Cumberland County, Pennsylvania, 17011, and has resided in Cumberland County for over six (6) months, 2. The Defendant is STEPHEN MARK KNIGHT, who currently resides at 2 Richland Lane, Apt. 208, Camp Hill, Cumberland County, Pennsylvania, nOll, and has resided in Cumberland County for over six (6) months. 3. The 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 are husband and wife and were lawfully married on June 27, 1987 in Old Town, Maine. 5, No children were born of this marriage. 6. Neither Plaintiff or Defendant was a member of the United States Armed Services.' 7. There have been no prior actions of divorce or for annulment between the parties except this complaint filed for divorce. 8. Plaintiff and Defendant have been advised of the availability of counseling, and of the right "'=1.,;r-"Q", to request that the Court require the parties to participate in counseling, 9. The marriage is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing of this complaint, Plaintiff intends to file an affidavit consenting to a divorce, Plaintiffbelieves that Defendant may also file such an affidavit. WHEREFORE, Plaintiff respectively requests, ifboth parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date offiling ofthis complaint, this Honorable Court enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, GATES & ASSOCIATES, P.C. usan Kay Can ello Esquire Counselfor Pl 'nti PA l.D. # 64998 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717)731-9600 Dated: ~lt\ ,2000 '111~_ r ~ " ~r~~~ '" " VERIFICA nON The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of her knowledge, information, and belief This verification is made subject to the penalties of 18 Pa. C. S A ~4904 relating to unsworn falsification to authorities, DATED: -%'.\\)6 d'l ,2000 jJYvvv-i A-~u-Q "~ Annie A. Krol-Knight ,'<'f"'''''~~ "~_, ~~ i II Ii Ii I' ,1 I 11 II ~ I, Ii ,] ij i1 [1 n Ii , I: I' , I-I ,. r'-i 'i _I 11I1_ _ 110_" :R)(":) :J:\:.~ ~ -.I:J CN ~~ ~- - ~ Or:! Cli' Yr o 8 o \A ~ J~ i ~ ~ &' C" ~; ,1::"'-: ri': Z :::::: 0.:_- '. ~~(:_'. ;~ j-,. ~'-:l o ".::;':lO :.n "r; en ~_~~l c_ .'- -~ ""Iffl_~"","~~~II~~r';f-\\<lli~~-\1!j!"","~C'P~''''''cl'~~'$!ml!'''~Ml!Wl~"~MlIffiI1~\",,~~ ANNIE A. KROL-KNIGHT, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO~TY, PENNSYLVANIA vs. NO. 5332-2000 STEPHEN MARK KNIGHT, DEFENDANT CIVIL ACTION - LAW ACTION FOR DIVORCE AFFIDAVIT OF SERVICE CERTIFIED MAIL COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND Be it known, that on the S -iJ.( day of September, 2000, before me, the subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being dilly sworn according to law, did depose and state as follows: 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania, and I am employed by the law firm of Gates & Associates, P.C., Lemoyne, Pennsylvania. 2. My law firm represents Annie A. Krol-Knight, PlaintifIin the above-captioned matter, 3, On August 4,2000 a true and correct copy of the Complaint for No-Fault Divorce Under 330I(c) of the Divorce Code was deposited for delivery with the U.S. Postal Service in Camp Hill, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7099 3400 0006 0352 3289 and addressed to the Defendant, Stephen Mark Knight, 2 RichIand Lane, Apt. 208, Camp Hill, P A 17011 4. A copy of the return receipt card signed by the Defendant, Stephen Mark Knight, '-. showing a date of service of August 5, 2000 is attached hereto as Exhibit "A". 5, Service by certified mail meets the requirements ofPa.R.C,P. 404(2) and Pa.R.C.P. 403. SWORN TO AND SUBSCRIBED before me, a Notary Public, this .5" i:t! day of September, 2000. &)(lJJW Notary Public Notarial Seal Teri L. Walker, Notary Public Lemoyne Bom, Cumbe~and County My Commission Expires Jan. 20, 2003 Member, PennsylVania AssociatIon 01 Notaries My Commission Expires: " ,. ~~ L " , ',' ',',.' . Complete items', 2. and 3. Also complete aem 4 if Restricted Delivery is desired. . Print your name and acft:tress on the reverse so that we can return the card to YOu,. . Attach this card to the back of the mail piece, X or on the front.if space permits. 1. Article Addressed to: S-re.r\\€.(\ {\xU'/L ~\\\ ~h.T d ~ichlQ\\di La.Qe.. Ii p-t. O'lm tu.\'<'-p ~l \\ ~ I'lDI \ . !.~ 3. Service Type i 'J( Certified Mail [J Express'Mail' ~ : o Registered '6i( Return Receipt tOr Merchandise _,- o Insured Mail 0 C.O.D. ~ 4. Restricted Delivery? (Extra Fee) t( Yes . 2. Article Number (Ccipy from service label) _ ~ " I : I)CRQ 3ltOO t\tiY...o. 63S~ 3.;)~9.' PS Form 3811, July "999' . Domestic ReIum Receipt !,j. '{i\" ;iii 102595~9HA.178& ~. ~" -----.------~ --"--.,--<:_-_--:--.-.....-___r"--;-.~...,~~--.-...,.--...- ---'"._..--~~. ~"."-~,-' UNITED STATES POSTAL SERVICE First-Class Mail t." Postage & Fees. Paid ~ USPS ~:' Perma No. G.'O i i f' I Ii t t , . Sender: Please print your name, address, and ZIP+4 in this box. 'S~c... ^. law Offices of . Gates & Associates, P 1013 Mumma Rd.. Suite ~ Lemoyne, PA 1 ?043 \ \\ 06 111.11111.111....1..1.011.111.1..1.11111.11.,.1.1..1.1..111101 - 1<0 ~..~ " , ~'. ,~.,. . ,'- .;'--<:" .'!"- j, Ii .i , t ! ! i I I , I I I I I _IIPI "mll', ~><< m""~.PlI~lIl!llI a Il.r_~~._ o c :,:~ 2~f~ - ~i~~ ..::;;.. r-'~' ~ ::::":~I~ ~?~ ?.: .::2 l-::-; C::.i c./') {"'l -'''0 I (-;~, lJ 1'.:; :.)1 (T> hJ, "-" ~~ :c> ~T) ::< ".~~~~If\!'F<-"'~!'i~"~Bl!l!!~~~~'I1,,;yW~'fi'11\!~j;-"'i'i'!~""'11lIijl!\