HomeMy WebLinkAbout01-0034 FX
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
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Ronald L. Killian,
Plaintiff
VERSUS
Mari N. Killian,
Defendant
PENNA.
No. 2001-34 CIVIL
ICERM
DECREE IN
DIVORCE
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AND NOW,
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DECREED THAT
Ronald L. Killian
, PLAINTIFF,
Mari N. Killian
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AND
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, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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;
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NONE
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LI''Ir'I''''f>
BY TH
ATTE5T~~
PROTHONOTARY
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RONALD L. KILLIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001-34 CIVIL TERM
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MARl N. KILLIAN,
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: Service upon the Defendant via certified
mail, restricted delivery on January S, 2001.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required under Section 3301(c) of the
divorce code: by the plaintiff April I? _ 200 I
by the defendant April 9. 2001
(b) (I)
the divorce code
Date of execution of the plaintiffs affidavit required by Section 3301(d) of
N/A
(2)
Date of service of the plaintiffs affidavit upon the defendant
N/A
4.
Related claims 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: AorillS. 200 I
(b) Date plaintiff s waiver of notice in Section 3301 (c) divorce was filed with the
Prothonotary: AorilIS. 2001
Date defendant's waiver of notice in Section 3301(c) div. rce was filed with
the Prothonotary: A rillS 2001
.
David A. Baric, Esquire
Attorney for Plaintiff, Ronald L. Killian
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RONALD L. KILLIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.2001- 31
CIVIL TERM
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MARl N. KILLIAN,
NOTICE TO DEFEND AND CLAIM RlGHTS
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 rnarriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RlGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY 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
4 Liberty Avenue
Carlisle, Peunsylvania 17013
(717) 249-3166
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001- 3'1
CIVIL TERM
RONALD L. KILLIAN,
Plaintiff
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MARl N. KILLIAN,
COMPLAINT UNDER SECTIONS 3301(c)
AND 330Hd) OF THE DIVORCE CODE
1. Plaintiff is Ronald L. Killian, an adult individual who currently resides at 1240
Holly Pike, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Mari N. Killian, an adult individual who currently resides at 1240
Holly Pike, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on April 14, 1979 in Cumberland
County, Peunsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of counseling and that he may
have the right to request that the court require the parties to participate in Counseling.
8. Plaintiff requests the court to enter a decree of divorce.
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WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the
Plaintiff and against the Defendant.
Respectfully submitted,
1i;;;CHE
David A. Baric, Esquire
I.D.# 44853
17 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff,
Ronald L. Killian
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VERlFlCATION
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.
P..h- .1 h1L
Ronald L. Killian
Date: 1/] I:> O() I
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RONALD L. KILLIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2001-34 CIVIL TERM
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MARIN. KILLIAN,
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on
January 3, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a fmal decree in divorce without notice.
4. 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.
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 .
6. I have been advised of the availability of marriage counseling and understand that
I may request that the court require counseling. I do not request that the court require counseling.
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. Section 4904 relating to
unsworn falsification to authorities.
Date:
04-/IK/OI
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Ronald L. Killian
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RONALD L. KILLIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2001-34 CIVIL TERM
Defendant
CIVIL ACTION-LAW
IN DIVORCE
MARl N. KILLIAN,
DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF
SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on
January 3, 2001.
2.
8, 2001.
Defendant acknowledges receipt and accepts service of the Complaint on January
3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of the filing of the Complaint.
4, I consent to the entry of a final decree in divorce without notice.
5. 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.
6. 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 .
7. I have been advised of the availability of marriage counseling and understand that
I may request that the court require counseling. I do not request that the court require counseling.
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. Section 4904 relating to
unsworn falsification to authorities.
Date:
t./jC/I01
0;d1J)r:Jkc~
Mari N. Killian
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RONALD L. KILLIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001-34 CIVIL TERM
MARIN. KILLIAN,
CIVIL ACTION-LAW
IN DIVORCE
Defendant
CERTIFICATE OF SERVICE
I, David A. Baric, Esquire, attorney for the Plaintiff in the above-captioned divorce
action, do hereby certify that I served a certified copy of the Complaint in Divorce to the
Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card.
O'BRlEN, BARIC & ~RER
By~L//!(A,
David A. Baric, Esquire
DATE:
till? /01
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I~Wllillto reelliV_1I1e follow-
if1WSll,,",,!!S(for an, elllra tee):
[J CO!1)plet8'ltems 1 and/or 2 far additional services. ,
CottJple1e !terns 3, 4a, and 4b. . " .
[J Print your name aI1Cl address on the reverse of thiS form so that we can return thiS
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CI Attach this form 10 ihe fronl of the mailpiece, ,or on the bac\( if spaae does not
PSnlm.
o Write "Return Receipt Requested" on the,mailpiece below the article !lumber.
CI The Return Receipt will show to whom the article was-"'delivered <?,:Id the date
delivered.
. 1.~ .~ddressee'5 Addres~
2. '!'Restricted Delivery
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4b, Service Type
o Registered
o Express Mail
o Return Receipt for Merchandise
7. Date 0
)(\ Certified
@nsured
DeCO
10259'5..99-8-0223 Domestic Retum Receipt
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