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Home My WebLink About00-05773 "Co -,,;. "~ , '~, ''',..<', '-',0, c'. ",,-i;;;,'~,,~ ~~, ~}~:..:.():..);:,,':~!:..::(xe~;::':,!!+::~~:::,!>>:~~::':;~!:'.>;::;!:.c~~'::~!::.rX.::!f)",~::~!:.>~::,~~:"::!~')::e!~::':::<e!~;:X+::!t::~!:..>r:;:!:.:>;~'::~!:e<:::!:.::~$*~~:>:~~::.w~>:::*g~~~a.'i>E~!_r:~<"K;'f:+:*$' ~ I ~ ~ ~ , ~ IN THE COURT OF COMMON PLEAS I ~ ~ ~-;~ ~ ;'.s ~ .,.", ~ ~.~ '",< ;0;.' * ~ !>.~ "'0", ~ ~.~ ~.~ ~ ~ !>.~ ,"', ~ ~.~ ~ ~'" ~.~ ~ ~.~ ~ m ;o;.s ~ ;'.s ~ ~.~ ~ i ~.<! I r-: ~ ~~ ~' ~ >"'. ~~~ I t '~ ~.~ ~ ;.:.:< a ~~ ~ ~~ ;..~ ~ ~ l~ ~.~ ~ . , OF CUMBERLAND COUNTY STATE OF PENNA. n uI<:E.J:,:LXu~'nf:L()(O].E:~S L. u....m n uu u. n u ..uu uu I I I N o. n~.~.~.s..?.?~.n c:.i..\7~.~.n.. ~ Plaintiff Versus n..~<;:Q~ ..,!!,. .A:L!~Umm.'):' L.. Defendant DECREE IN ~ORCE AND NOW,..................... .~~.., ]{St~ it is ordered and decreed that.. .E:~ny. .A~. .Elow.ers. .. .. .. . ... . .. .. . . .. . . . . . . ., plaintiff, and. . .ElC;:9t. .'J:.. ~.l.q~;i.ght;. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ". 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\I\Q ................................................ .........................., ~ ~ ~ ~.~ ~ ;'-;i ~ i ~ !>.<! ~ ~ ~ [! I -~ - ~~~~~~~~~~~~~~~~~~~~ By Attest: Prothonotary ~.~ , i ~: ';'': ~ ~.~ ~.~ J ~ ~.~ ~ !>.~ ~.~ ~ ~ ';~" ~ ;..~ . ~ "';/ ~ ~ i !>.<! i ",.~ '.'. ;o;'"!i ~ ~ ~~~~ ~ ~ ; 8 N ~ >,,', ~.~ ~ ~:2 W ~'i ~ !>i ", ~. ~ ~.~ N ~ ~.~ ~ ~ ~.~ ~ !>.~ J. ',,' ~ ~.~ ~ ~.~ ;..~ ~ ~ '.. ~ '.' ~ ~.~ ~~~ :;.:..::!;: :::-:.;( ::~:.;.',: >:::+;;;::::..:+::.,;: :::.:.;~:. ,:":.::." X";<::'.:+;-,: ::.:..::~::- ,', ~ h ~. , HU'"", " _,_"", "'" "C-,-'", ,,"," "'~ ~,' '~", ,- ~ '" ,- ~. " , ~. - ~. " - -,~ . ,~ , .'~" , " ~ ~' , ' .~I':.'. /~I-;r;-ty) &d. ~ ~ ~ 4 ~-/ /~;;)O-cP 7t~ ~ #~ -7 . , " ,. .~ . --"""r -'-", ~ ",<, '-'>->; ,~"'"'~, ~~~> ,,,,"" "', ''':-''! '-'<C ._~.... ", -<' " "- , :"",""'=..-,, ~, left_>!- KELLY A. FLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-5773 Civil SCOT T. ALBRIGHT, 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: I. Ground for a divorce: irretrievable breakdown under Section 3301 (c) ofthe Divorce Code. 2. Date and manner of service of the Complaint:08/24/00 Certified rrrnil restricted delivery. 3. Complete either paragraph (a) or (b). (a) Date of execution ofthe affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff 12/05/00, by the Defendant 12/05/00. Both Affidavits were filed on 12/08/00. (b) (I) Date of execution of the plaintiff's affidavit required by Section 3301(d) ofthe Divorce Code: (2) Date of service of the plaintiff's affidavit upon the Defendant: 4. Related claim 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, if the decree is to be entered under Section 3301 (d) of the Divorce Code: (b) Date Plaiptiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary 12/08/00. Date Defendant's Waiver of Notice in Section 3301(c) was filed with the Prothonotary 12/08/00. Date: \~ 1\ \DO / '" " -",;;k,'L.\" [In ~w'-~.,,;J , "'.L" Jr,Li "'~~'~',i" ''''''''~:nY'l- ......... ,. ~' - ilIr'.' iJ -,"""'.'~~ (") a S c: t::> :g:: 0 --' uf;JJ fT1 ----'" mfT! CJ "j - .~; Z:c , zr. ~;~;fj ~:;!: w ~&~? ~C' '" ;)?:c: 3': --. ~;~$~ Zo N r--., ,. Pc '-.-0: Z; => :~ =< 0:> ~ _'J ~'4 '" "-'~lfJI:, , . .. r. ... . KELLY A FLOWERS, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 00 - S-11.3 Cu;l~~ CIVIL ACTION - LAW IN DIVORCE SCOT T. ALBRIGHT, Defendant 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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. IFYOUDONOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 , , ~- ~-~ ~ ~ . '!lJ"","""'_' , , , ... KELLY A. FLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. SCOT T. ALBRIGHT, Defendant CIVil. ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, KELLY A. FLOWERS, by and through her counsel, Kollas and Kennedy, and respectfully represents as follows in support of the within Complaint: 1. Plaintiff is Kelly A. Flowers, an adult individual currently residing at 503 Kevin Court, Camp Hill, Cumberland County, PA 17025. PlaintifPs Social Security Number is 211-56-7590. 2. Defendant is Scot T. Albright, an adult individual currently residing at lION. 21" Street, Camp Hill, Cumberland County, P A 17011. Defendant's Social Security Number is 169- 48-9872. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 23, 1996, in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant are both citizens of the United States. """ _Co' IllIliiiiII.. ~ . ~ ~llil'l.',~""h"~' , . , .. COUNT I - DIVORCE PURSUANT TO ~3301(c) OF THE DIVORCE CODE 8. Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. The marriage of the parties is irretrievably broken. WHEREFORE, the Plaintiff prays that Judgment and Decree be entered as follows: (a) As to Count I, that a decree be entered divorcing Plaintiff from the bonds of matrimony with the Defendant pursuant to 23 Pa.C.S. Section 3301 (c). RESPECTFULLY SUBMITTED, Mary Kollas ennedy, Esquire KOLLAS AND KENNEDY I.D. No. 69246 1104 Fernwood Avenue, Suite 104 Camp Hill, Pennsylvania 17011 Telephone: (717) 731-1600 ATTORNEY FOR PLAINTIFF DATE: '6] 11\00 2 j,1 ~, I" ~'~ , ". ~,,","Q,~ ~ VERIFICATION I, KELLY FLOWERS, verifY that the statements made in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904, relating to unsworn falsification to authorities. BY~ -I~ / Kel Flowers DATE: ?/n/ro ~~ ~" . ~ III ~ -- KELLY A. FLOWERS, Plaintiff lilliJ[jj~\l1il" , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-5773 Civil SCOT T. ALBRIGHT, Defendant CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE ~ SENDER: cD [] Complete items 1 and/or 2 for additional services. S Complete items-.a, 4a, and 4b. li~ [J Print your name and address on the reverse of this form so that we can retum this card to you. . ~ Attach this form to the front of the mailpiece, or on the ba. ck if space does not G> permit, :5 ,Write "Return Receipt Requested" on the mailpiece below the article number. c 0 Th~ Return Receipt will show to whom the article ~~~~ered and the date Q delivered, ,1.,:"'" ) 3.ArticleAddressed:: .u 4a2i353be~7 q2q ~ ty\\'. 21.ot I. illb'l.{gH 4b. Service Type 8 110 N. 21 ~ S-tfLtl- ~ 0 Registered ('11'1 V\I 11'\ . 0 Express Mail \J.l.l"-{J HUl, PA \70)\ liLRetumReceiptfor '.' 7. Date of Delivery f) I also wish to receive the follow- ing services (for an extra fee): 1. O"Addressee's Address 2;'~!#ett'Oeliv~ry 5, Received By: (Print Name) 8. Addressee's Add fee is paid) Ii g. ill , . 102595-99-8-0223 Domestic Return Receipt t'" BY: Date: <t! 2Z flOOD ennedy, squire KOLLAS KENNEDY 1104 Fernwood Avenue Suite 102 Camp Hill, PA 17011 (717) 731-1600 Attorney for Plaintiff Ii u .;; ~ a ~ .. 0: c ~ :s I g> 'iij :s ~ .2 :s g. .. c .. F .' - "l~""- " !iGI~~~l!Jj~m'~5O"~"i!&'-""'il<:"'"iIIT"'~ ~ , - .'" ,,~ " - . ~ ~ ~~ 0 c $: -:::',. -rJ (I) mrn .0") Z:n z:C -.....) en ,i.~; t'::;; ~"':- /0 , j;; zO ;>0 , c Z ::,) ~ .Co "'~-~' .~ "1O!lIi- 'ii,' , i i , : i I- I I i I' I I I I I, j , 1 I , , i I , i ~ "'- ;ltU~j':ij'" . " ~ KELLY A. FLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5773 Civil SCOT T. ALBRIGHT, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under 93301 ( c) of the Divorce Code was filed on August 21, 2000, and was served upon the Defendant on August 24, 2000. A Proof of Service was filed on August 29, 2000. 2. The marriage ofthe 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! 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. 94904 relating to unsworn falsification to authorities. DATE: /~-/o~ ~~ 12 ~~(J~ y A. Flowers ,j[g .'~ ~,fW .... "l ., ~ KELLY A FLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5773 Civil SCOT T. ALBRIGHT, Defendant CIVil- ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OR (d) OF THE DIVORCE CODE 1. 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 ifI 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.CS. 94904 relating to unsworn falsification to authorities. DATED: 1J/~06 ~d4./ elly A. Flowers '..... "";.\~ ""~"'''"~~j: ..... <' , . KELLY A. FLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 00-5773 Civil SCOT 1. ALBRIGHT, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301(c) of the Divorce Code was filed on August 21, 2000, and was served upon the Defendant on August 24, 2000. A Proof of Service was filed on August 29,2000. 2. The marriage of the 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 ifI 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:~ ; t:Ii::P ') '~""d1i.1.iH;"'I...'. ~: .. y , KELLY A. FLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5773 Civil SCOT T. ALBRIGHT, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OR (d) OF THE DIVORCE CODE L 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 in 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. 94904 relating to unsworn falsification to authorities. DA1ED~/~ c~--:~ /(7 ScotT~ ) nght .