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Home My WebLink About00-05435 , . , , , . . , , , , , , , , , , . . , , . , , , , , . , . . , , , . . , , , , , . . . . , , , , , , . . , . . . . , , , _".J_' ,,1- 'E , , L t . , . ,., " . . , , , . ., ,. . . "''''''''''' , , . . "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MICHAEL W. KELLY, Plaintiff NO. 5435 2000 VERSUS PAMELA S. KELLY, Defendant DECREE IN DIVORCE AND NOW, f\J ",\I (> ""7 Lc J Z.l , ZOOD, IT IS ORDERED AND DECREED THAT MICHAEL W. KELLY PAMELA S. KELLY , PLAINTIFF, AND , 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 ENTERED; ATTEST: J. , ,Inl: '" '" "'''' '" '" , . . . . , , , , , , , , , , , , . , , , , , , , , . , , . , , , . . . . . . . . . . . . . . . . , . . . . . ;;II .<.< . <<." "", '<~" ''''<'' 'liT""'" , , , .. ~ /(.,;).;)-aJ W~.~-d 4 ~ Ir'd~~ /1~ ~;t;~ , .. , 1, ~~, ," ,,' _ ,_:ri!l!:-:'~, .,,~'o,~ ~ - ~ " .. __1". - ._, ~".~,,~ .;" ~- ~,"",~~""-~k'"~'>'.l:N1"',,~, ' . MICHAEL W. KELLY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA S. KELLY Defendant : NO. 00-5435 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: August 5, 2000 by U.S. Mail, Certified Mail, Postage pre-paid, return receipt requested signed by the respondent indicating service was effected. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff November 7, 2000; by Defendant November 13, 2000. 4. Related claims pending: November 13,2000. 5. Date Plaintiffs Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: November 16, 2000. Date Defendant' s Waiver of Notice in 9330 I (c) Divorce was filed with the Prothonotary: November 16, 2000. THE LAW OFFICES OF PAUL BRADFORD ORR Date:dv.A5. 2000 By: 4:*~/a Giego . tier, Esq. 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ill No. 73471 ~- ,- :'" j' ., MICHAEL W. KELLY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. KELLY Defendant : CIVIL ACTION - LAW J.OOO- 5Y3S- : NO. 00- CIVIL TERM : IN DIVORCE v. NOTICE 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 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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, P A 17013 Phone: (717) 249-3166 - " ' "-,, " ',." , ,.-' -~. >-'~j J I 1 , I I I I rl j , I I ,I 1,1 I i , .. MICHAEL W. KELLY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : :}! : NO. 00- 5'1 CIVIL TERM : IN DIVORCE PAMELA S. KELLY, Defendant COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michael W. Kelly, who currently resides at 97 Winchester Gardens, Cumberland County, Pennsylvania, all his life. 2. Defendant is Pamela S. Kelly, who currently resides at 2018 Dickinson Avenue, Camp Hill, Cumberland County, Pennsylvania, all her life. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 19,1996, in New Kingston, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. llli -~, , . , 8. Plaintiff requests the Court to enter a Decree in Divorce. THE LAW OFFICES OF PAUL BRADFORD ORR Date: 7/)I~O By~rC1L Greg L utler Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court lD # 73471 tI' . , VERIFICATION 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. S 4904, relating to unsworn falsification to authorities. Date: ;;1- ~=o ~~~ Michael W. Kelly, Plaintiff , y,.-. _ .-:,;.-1 . " . ,~ ' ~.~" , .- . . MICHAEL W. KELLY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW PAMELA S. KELLY : NO. 00-5435 CIVIL TERM : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 4, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. s4904, relating to unsworn falsification to authorities. Date: //-7-d~ - ,- "--\&iM':"' \ i' i: I: I I' ',; !j _n ~'" ~fu....Lj'~r, , . MICHAEL W, KELLY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA S. KELLY Defendant : NO. 00- 5435 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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 a 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 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, !j4904, relating to unswom falsification to authorities. Date: //-7-00 . , " , MICHAEL W. KELLY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW PAMELA S. KELLY : NO. 00-5435 CIVIL TERM : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 4, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. 54904, relating to unsworn falsification to authorities. Date: //j/.3?lJlJlJ t P ..""",~i1,>, i i: ii 'I I, I: ;,-; I, i, i; i'i I' " 'I ,i 'i " I ::1 i'i I, :'1 'I I :1 " 'i " 'I ,I I :1 iJ :1 tI I :1 q 'I Ii 'I . ="-" . _~~o, ' "~~ '_i,,,,-m..__,.I'''d', , " .- MICHAEL W. KELLY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA S. KELLY Defendant : NO, 00- 5435 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entrj of a final decree of divorce without notke. 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 a 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 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. ~4904, relating to unsworn falsification to authorities. Date: 1J/18/J.M() " . 'I " . .. . I .. MICHAEL W. KELLY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. PAMELA S. KELLY. : NO. 00-5435 CML TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : COUNTY OF CUMBERLAND ) AND NOW, this 5th day of August, 2000, I Gregory 1. Cutler, Esquire, attorney for Michael W. Kelley" Plaintiff in the above-captioned action, hereby certifY that I mailed a copy of a Divorce Complaint by U.S. Mail, Certified Mail, Postage prepaid, return receipt requested, in the above-captioned action, upon Pamela S. Kelly, 2018 Dickinson Avenue, Camp Hill, P A 17011. The original return receipt card signed by the Respondent on August 5, 2000 indicating service was effected, is marked Exhibit" A", attached hereto and made a part hereof. Dated: 8' / " 10 0 By ~L~ " , ~ ,..~,. " ,. . , . Complele ~e,l;s 1.2, ""<t3. Afso complete .' ~em 4 W Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. .. AttaCh this card 10 Ihe bacK of Ihe mail piece. ^ or 0111 the 'front if space permits. 1. Article Addressed to: ~-5.~ oI8~~~. f- .J.L:.u.., \ PA Il D II 2., ,M, ,iCla" N" ~mbe,;,',r,I"f.1~,fro,.','.,',.,'''' ,ice,; ,/a!:!eIl,' : Z.~I.'l . I'S I'om';', .{ JUlY j'i!90 x D. Is' eliveI)' address different from item 1? If YES. enter delivery address below: 3. ~",ice Type ~Certified Mail 0 Express Mail ji(.RegJstered ~ Return Receipt for MerchandIse o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 102595-99..M-1789 Domestic Return Receipt Exhibit" A" ~,