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HomeMy WebLinkAbout03-2497WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 CLARA A. KINSLOW, Plaintiff Vo WALTER A. KINSLOW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 03-,).. '/q7 CIVIL TERM : 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 at CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA 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. Cumberlm~d County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 aynl~ F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Porafret Street Carlisle, Pennsylvania 17013 CLARA A. KINSLOW, Plaintiff Vo WALTER A. KINSLOW, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ·NO. 03- .~ '/q } CIVIL TERM ·IN DIVORCE COMPLAINT DIVORCE Plaintiff in this Action in Divorce is CLARA A. KINSLOW, an adult individual who may be served with process in this case through the office of her attorney of record, Wayne F. Shade, Esquire, 53 West Pomfret Street, Carlisle, Pennsylvania 17013. 2. Defendant is WALTER A. KINSLOW, an adult individual and citizen of the United States of America who resides at 13 Cooper Circle, Carlisle, Cumberland County, Pennsylvania 17013. o Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. Plaintiff and Defendant were lawfully joined in marriage on May 20, 1983, in Carlisle, Cumberland County, Pennsylvania. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 o The parties have been living separate and apart since on or about April 11, 2003. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. Both parties to this Action in Divorce are legally capable of managing their own concerns. Defendant herein is not a member of the armed forces of the United States of America. 10. There were no children bom of this marriage. 11. 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. -2- WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. Way~a~F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Stre~ Carlisle, Pennsylvania 17013 -3- I verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Dme: May 23, 2003 Clara A. Kinslow WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 CLARA A. KINSLOW, Plaintiff Vo WALTER A. K1NSLOW, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2497 CIVIL TERM : : 1N DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on May 28, 2003, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on May 30, 2003, as evidenced by the retum receipt card attached hereto bearing Certified No. 7099 3400 0018 5044 8691. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: June 2, 2003 Wayne~. Shade Postage Certified Fee Return Receipt Fee (Enc~orsement Required) Restricted Ddivery Fee (Endorsement Required) Total Postage & Fees .60 2,30 1.75 3.50 $ 8.15 L'L*') (ED 0 Mr. Walter A. Kinslow 13 Cooper Circle Carlisle, PA 17013 2. Article Number i~ Form 3811, Aa~u~ 3{~01 x B. Recek~l by ( Pr/rded Name) ,C ,aof I If yES, ~ter delh/~y eddm~ flelow: i'-I No ~P_.etified Mall r'l ~ Mall [] Registered i'1 Rerun1 Receipt for Merchandise [] Insured Mall [] C.O.D. 7099 3400 0018 5044 8691 WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 CLARA A. KINSLOW, Plaintiff WALTER A. K1NSLOW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 03-2497 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER {}330 l(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under {}3301 (c) of the Divorce Code with Notice of Availability of Counseling was filed on May 28, 21)03, and served on May 30, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without notice. 4. I understand thru 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. WAYNE F. SHAD 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 have been advised of the availability of marriage counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I ~articipate in counseling. I understand thru the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, ! do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. 9. 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. Date: Walter A. Kinslow WAYNE F. SHADE Attorney at Law 53 West Porafiet Streel Carlisle, Pennsylvania CLARA A. KINSLOW, Plaintiff WALTER A. KINSLOW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2497 CIVIL TERM : 1N DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF iNTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) A Complaint in Divorce under §330 ! (c) of the Divorce Code with Notice of Availability of Counseling was filed on May 28, 2003, and served on May 30, 2003. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a Final Decree of Divorce without notice. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. WAYNE F. SHADE Attorney at Law 53 West Porafrel Street Carlisle, Pennsylvania I understand thai 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 of my right to counseling and underst~md that I may request that the Court require that my spouse and I participate in counseling. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. 9. 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. Date: September 4, 2003 Clara A. Kinslow WAYNE F. SHADE Attorney ~t Law 53 West Porafret Slreet Carlisle, Pennsylvania 17013 CLARA A. KINSLOW, Plaintiff WALTER A. K1NSLOW, Defendant To the Prothonotary: : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2497 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. The date and manner of service of the Complaint were on May 30, 2003, by first class, United States certified mail, return receipt requested, addressee only. 3. Date of execntion of the Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code by Plaintiff was September 4, 2003, and by Defendant was September 3, 2003. 4. Related claims pending: None. Date: September 8, 201)3 Wayne-F. Shade Attorney for Plaintiff IN THE COURT Of COMiMON PLEAS OFCUMBERLAND COUNTY STATE OF CLARA A. KINSLOW, Plaintiff VERSUS WALTER A. KINSLOW~ PENNA. Defendant NO. 03-2497 CIVIL TERM AND NOW, DECREED THAT AND DECree IN CLARA A. KINSLOW , PLAINTIFF, WALTER A. KINSLOW ,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