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Home My WebLink About00-05581 r . . . . . . . . . . . i:-. . . . ~ ~ ~ ~ ~ ~ ~ ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KRISTINA L. KENNEDY, No. 00-5581 CIVIL TERM Plaintiff VERSUS BROOKS T. KENNEDY, Defendant DECREE IN DIVORCE AND NOW, 'D...Cl!-.....,~<'J \3 ,2..00 .:?,IT IS ORDERED AND DECREED THAT Kristina L. Kennedv , PLAINTIFF, AND Brooks T. Kennedy , 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; No claims remain. By THEJ:,J(: A $T: PROTHONOTARY .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . '" '" '" "':Ii ",~'f. . ~ ., , -'~ , ',. "-",','-, ~, ~~.,i~ ~!Jli i - 1 .ll_'--'~~-liIlIi~.I"'l.llli"ll'lii~llJjIll'1iII'" ~- :W~ ).IX' ,]Jtl.JL"'5'"""'^ "_"""_",,",, "'"",,',"" ~<= . "~,,7 , _",'-_>_____,,~" , ~"'~~^'- Ie;;, /.;;? rf/J -00 .~~,~^'. ....,~---~-- ~ .-j "'"-!.......~^"-'.- :.'--' '" . ~. l , . 1 w-~~~a1~. 71~ ~ ~ df'- . '0'" , ~o I . </. .. . 11 KRISTINA L. KENNEDY, Plaintiff. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5581 CIVIL TERM BROOKS T. KENNEDY, Defendant CIVIL ACTION - LAW 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: 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery on August 18, 2000. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff 11/21/00; by Defendant 11/21/00 4. Related claims pending: None. 5. Date plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: 11/28/00 Date defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: 11/30/00 Dated: /0-/'1/ cO ~, Lori Serratelli, Esquire SER T LLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Cc,,~l ~ KRISTINA L. KENNEDY, Plaintiff NO. 00- St'JS1 CIVIL ACTION - LAW BROOKS T. KENNEDY, Defendant 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT WISH TO 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 HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 I-J;"i'_..,~ " .p __ ~"'~~' "' - vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. /J1.J-S5~1 ~ 'rb- CIVIL ACTION - LAW KRISTINA L. KENNEDY, Plaintiff BROOKS T. KENNEDY, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I DIVORCE 1. Plaintiff is Kristina L. Kennedy, who currently resides at 30 Stephen Road, Apt. 5D, Camp Hill, Cumberland County, pennsylvania 17011 since September 1997. Plaintiff's Social Security Number is 205-48-9612. 2. Defendant is Brooks T. Kennedy, who currently resides at 4300 Valley Road, Enola, Cumberland County, Pennsylvania 17025 since June 10, 2000. Defendant's Social Security Number is 210- 52-1469. " ,,- . '- ~ "" - . 3. plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 19, 1997 in Cumberland County, Pennsylvania. 5. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II INDIGNITIES 11. Paragraphs one through ten are hereby incorporated by reference herein. .,-.. -~ 12. The Plaintiff avers as the grounds on which this action is based is that the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 13. This action in divorce is not collusive. WHEREFORE, the plaintiff prays Your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted, /7 /' ! ~~ Lo . S TELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF -'''l~ _. --.. ~ VERIFICATION I verify that the statement made in the foregoing Complaint in Divorce 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. Date: ~~U&+ 1..:J[fj) ~,"1 J _ "111!" _ ~ ~,~ ~ -----~".' -, ~ >~- -_'i;,m.ll~ " " l . KRISTINA L. KENNEDY, Plaintiff vs. BROOKS T. KENNEDY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 00-5581 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Lori K. Serratelli, Esquire, being duly sworn according to law, depose and say that I served the Divorce Complaint in the above captioned matter, by depositing it in the United States mail, Certified Mail, Restricted Delivery, Return Receipt Requested, addressed as follows: Brooks T. Kennedy ABC Fuel Oil Company 25 North Lockwillow Avenue Harrisburg, PA 17112 The return receipt card is attached hereto. Dated: ~ LlSt- .;)1, ;=U-'JCO Sworn and before me of Pluqust IA~ NOTARY PUBLIC \ My Commission Expires: 3 (Z4{D3 Subscribed to this ;?K'~ day , 2000. . Serratelli, Esquire ELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9483 (717) 540-9170 Attorney for Plaintiff Notarial Seal Lisa Conway, Notary Public Susquehanna Twp., Dauphin County My Commission expires Mar. 24, 2003 ~~ \.. . Z 238 582 948 Certified Fee Special Delivery Fee Restricted Delivery Fee on . ~ Return Receipt ShOWIng to ..... Whom & Date Delivered "[ Relurrl ReceiptShowingto Whom. <t: Dale, & Addressee's Address ei o TOTAL POS1age & Fees $ postmark or Date I ' 2";- -- 2./'::> s.~~ S \S.DO ~M.~lffl""" , -""'-"'-"~' " ~ II Corri{,ll!le flams 1, 2, ~nd3. l!6 c()mplel~ item 4 if Restricted Delivery is qesired. . Print your name and address oN the reverse so that we can reti1Fnmrcard to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ''l?:x-ob~''::. '\. ~~V\ " ?I~c... ~~L D'L ~Pf\ ~S ~,~U)\\\o..u 'I< \\o......('~..u<"~ f-A, t,. 2~ Article "Number (COPY, frbm serv:"ice la~",^ ~ a3~ Sg~ <1~ PS Form 381'1: July'1'S99 ' , . . 3. ~ice Type ertified Mail 0 Express Mail Registered ,0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes ,11 ;,1 bbbestit ~tuhi RMeI~t SERVICE OF DIVORCE COMPLAINT ~ " " 102.595-99-M-1789 ~ . .. , KRISTINA L. KENNEDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5581 CIVIL TERM CIVIL ACTION - LAW BROOKS T. KENNEDY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) OF THE DIVORCE CODE (1) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 11, 2000. (2) The marriage of Plaintiff and Defendant broken and ninety (90) days have elapsed filing and service of the Complaint. is irretrievably from the date of (3) I consent to the entry of a final decree of divorce without formal notice of the intention to request entry of a divorce decree. (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. (5) 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. Sec. 4904 relating to unsworn falsification to authorities. I\D\j tfYtCw d " J D (){) DATED ~~ru$ K istina L. Kennedy ~- ~-- , . .. KRISTINA L. KENNEDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-5581 CIVIL TERM CIVIL ACTION - LAW BROOKS T. KENNEDY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) OF THE DIVORCE CODE (1) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 11, 2000. (2) The marriage of Plaintiff and Defendant broken and ninety (90) days have elapsed filing and service of the Complaint. is irretrievably from the date of (3) I consent to the entry of a final decree of divorce without formal notice of the intention to request entry of a divorce decree. (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. (5) 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. Sec. 4904 relating to unsworn falsification to authorities. DATED tfc9-/ / CO I Bd::I--(L~ . .,~:,~ -, ~ "",-- .- ,,;c , ^ ,~, , ,~