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HomeMy WebLinkAbout01-0034 FX ",,'''''o-''!'''''''I_ ' _, . . .. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . Ronald L. Killian, Plaintiff VERSUS Mari N. Killian, Defendant PENNA. No. 2001-34 CIVIL ICERM DECREE IN DIVORCE . AND NOW, ~\ 4\1\ , "tIJ~, , IT IS ORDERED AND . DECREED THAT Ronald L. Killian , PLAINTIFF, Mari N. Killian . 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; . . . . . . NONE . . . . . . . . . . . . . . " LI''Ir'I''''f> BY TH ATTE5T~~ PROTHONOTARY ft; ft; ft;:!::!: ;t: ;t:~ ft; ft; ft;~ ;t:~;t: ~~ . ... 1 "'I' ,-~. , '" ~ - ',-~" '--, ~~'^ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~, IM'- """ -'-'~d',.:"J",-",'~' -.<11_",,' ,~ ...~i!llfftlI~~_~lii~~.l:ii""'~ liiilmilillIiI ~~ -)l07&;; 0/ 1/-,;;) fp -tJ/ '.lk!'b"jft",Il..tJ:!UUI !n!!II!!!.IlH~,D, .' .,. ..,=.' ",'.... .. ... "'~-"'-<.._:- , ~ ~ .-. . ,,<If- '~1..-: M-~~~ ~4R!J~ 71~ ~;b4~ '-""."'- ~D n 11 , . 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 .~ - ~- 1ll . ~- ---."-' ,,.fJ'IIR~ ~ .~~.,","'''1 ,& ~I'''''"' ''''--' .", <<m,.,,- ~, 'ITI nillifm'l""~'n''iiiil\ , ' c c::: .--' """"_'.....I!I!l'~, ,~"'..!lIQ'~"'J"!'''''"'-'"...,~"~~~~, ~ ~__ '::,'; ("'~ t....) ::) ,,-~ , IfliIJlRllW< " I' 'i 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 -t, " ., 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. " 'I 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 dab.dir/domesticlkillian/com plaint. pld :, < -' I~ - -" __. _ ~ . . ~,." ,,,. ,~~U" , ,"" -J!!, '"_ ^___ , 1! ,. , 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 ,., " _ h~ " . . . . 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 ~ ;j.. !ciL Ronald L. Killian !jj ~"""" ,~~, ._-," , :;>c,,,~ ,~,' '. .... . - ,,,,,,,"",,,, ,"'~"--" ,-.. ~O.< ',.'" ,. ,Fff"_~_~~, ""'-' {, ,---"~ ' ,,- '<-Hl'_"'~,'>-"" '''-'IT!f_''''''' "''"''"'"'''I1'"['1'Iff , -;"'. -," ~ I o~'l o C:) '- ",'~ C:) ~ ,,., '..'. ~C d._ ~ l' ;1' 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 l\\l --~ ",,,,<,,,"., " '" ~~ " ~ ~, ~~~ "'''''"'"'"'.'"-'''''-'"''''>'''~' > .. ... .0. ....... '<', '-1 {i11i:(~i1~";~ri~ffr~t,.,c'[;;Jc,(:' ':"'f: <~:-'nf o c- I=:, ~?[J.f1~~ d~.! -,,< r--~ ":..,- 1,' il ':'/ APR 0 6 2001 " ~ " -' ' >~ l'l'fW" ~ ,. . ~~"",J!!'!l~~ t",- '_"-.-l -:-..71 ,,"-, .., ~, ~ " , 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 , (; 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 ~~~ . 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 m 5 4b, Service Type o Registered o Express Mail o Return Receipt for Merchandise 7. 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