HomeMy WebLinkAbout01-0486 FX
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
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STATE OF
JILL ANN KULIG,
.
,
Plaintiff
No. 01-486
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VERSUS
DANIEL K. KULIG,
.
Defendant
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DECREE IN
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DIVORCE
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, IT IS ORDERED AND
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AND NOW'~ 3
JILL ANN KULIG
DECREED THAT
, PLAI NTI FF,
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AND
DANIEL K. KULIG
, 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;
None.
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PROTHONOTARY
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JILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
DANIEL K. KULIG,
Defendant
CIVIL ACTION - LAW
NO. 01-486
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.
Irretrievable breakdown under ~
2. Date and manner of service of the Complaint: February
2, 2001, by United States Certified Mail, Restricted Delivery.
3. Date of execution of the Affidavit of Consent
by ~ 3301(c) of the Divorce Code: By Plaintiff ~;l'
by Defendant ~;I;l7 ' 2003. '
required
, 2003;
,"
4. Related claims pending: NONE.
5. Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce
filed with the Prothonotary: ~, 2003.
Date Defendant's Waiver of Notice in ~ 3301 (c)
Divorce filed with the Prothonotary: ~' 2003.
~espectfully submitted,
DISSINGER AND DISSINGER
Date: Cf5II;>/IJ~
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Mary~ Etter Dissin~L
Attorney for Defendant
28 N. 32nd Street
Camp Hill, PA 17011
717-975-2840
cc: Samuel L. Andes, Esquire
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JILL ANN KULIG,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.c>/_ 4'&t, CiUl' \
IN DIVORCE
DANIEL K. KULIG,
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
'I. foregoing 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 in divorce or annulment may be entered against you by
II the court. A judgment may also be entered against you for any other claim or relief requested in
I 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
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, PA 17013
Telephone: (717) 249-3166
II
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JILL ANN KULIG,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. ol.A.f~
DANIEL K. KULIG,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302 (d) of the Divorce Code, you may request that the court require you and your
i spouse to attend marriage counseling prior to a divorce being handed down by the court. A list
i i of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver
:: of your right to request counseling.
II
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\
JILL ANN KULIG,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 0 PI '9'(.0 C;;J. -r .u.--
DANIEL K. KULIG,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, JILL ANN KULIG, by her attorney, Samuel L.
Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is JILL ANN KULIG, an adult individual who currently resides at 35
Nathan Drive in Enola, Cumberland County, Pennsylvania.
2. The Defendant is DANIEL K. KULIG, an adult individual who currently resides at 905
Maplewood Lane in Enola, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residence of 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 24 December 1996 in Middletown,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
COUNT I-IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the
Divorce Code of Pennsylvania.
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COUNT II EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names of
each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the
Defendant, to equitably divide the property, both real and personal, owned by the parties hereto
as martial property.
I verify that the statements made in this Complaint are true and correct. I understand that
any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn
falsification to authorities).
Date:
II ~/o I
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L ANN KULIG
~
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
II
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JILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
DANIEL K. KULIG,
Defendant
CIVIL ACTION - LAW
NO. 01-486
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Daniel K. Kulig, was served with the Complaint in
Divorce in the above captioned case on February 2, 2001, by
personal service and I accepted the Complaint in Divorce.
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
On this Id'i::b day of ----.mO I'c.h
, 2003, before me
a Notary Public, personally appeared
9AI\J.tI,'l.. j.<. KWrc" known
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subscribed to the
to me to be the person whose name is
within instrument, and acknowledged that she executed the
same for the purposes therein contained.
In witness whereof, I hereunto set my hand and seal.
~#AA (), ~
Notary Public
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JILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
DANIEL K. KULIG,
Defendant
CIVIL ACTION - LAW
NO. 01-486
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(C) OF THE DIVORCE CODE
1. A Complaint in divorce under Section 3301(d) of the
Divorce Code was filed on January 24, 2001 and served on
February 02, 2001.
2. The parties to this action separated January 23, 2001 and
have continued to live separate and apart for a period of at
least two (2) years.
3. The marriage of Plaintiff and Defendant is irretrievably
broken.
4. I understand that I may lose rights concerning alimony,
alimony pendente lite, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
5. I consent to the entry of a final Decree in Divorce
without notice.
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.
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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.
DATED:
J/ /J.-'ll '0
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JILL ANN KULIG, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 01-486
DANIEL K. KULIG, )
Defendant I IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
24 January 2001 and was served upon the Defendant on or about 2 February 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
ISection 4904 relating to unsworn falsification to authorities.
i DATE
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. L ANN KULIG
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c: -, ",.'\JOTARY
G3~1f\Y IJ-AH 1:01
CUM8EHU'('iO COUNTY
F'ENNSYlVANIA
JILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 01-486
DANIEL K. KULIG,
Defendant
IN DIVORCE
WAiVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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. Section 4904
relating to unsworn falsification to authorities.
I Dated:
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03~'),~Y 1.1 Ail I: 02
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JILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
,
,
I
i DANIEL K. KULIG,
Defendant
vs.
CIVIL ACTION - LAW
NO. 01-486
IN DIVORCE
PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION COUNT
To the prothonotary:
Please withdraw the request for equitable distribution made
by the Plaintiff. Thank you.
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JILL ANN KULIG,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
DANIEL K. KULIG,
Defendant
CIVIL ACTION - LAW
NO. 01-486
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(C) OF THE DIVORCE CODE
1. A Complaint in divorce under Section 3301 (d) of the
Divorce Code was filed on January 24, 2001 and served on
February 02, 2001.
2. The parties to this action separated January 23, 2001 and
have continued to live separate and apart for a period of at
least two (2) years.
3. The marriage of Plaintiff and Defendant is irretrievably
broken.
4. I understand that I may lose rights concerning alimony,
alimony pendente lite, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
5. I consent to the entry of a final Decree in Divorce
without notice.
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.
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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.
DATED:
/-/"9/,1
Daf!!-i!~~'ndant
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