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HomeMy WebLinkAbout07-1915HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - LAW DOUGLAS R. KUTZ : NUMBER 2007- 1915- CIVIL TERM Defendant : 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 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 the Cumberland County Courthouse, One South Hanover Street, 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE PA 17013 1-800-990-9108 (717) 249 - 3166 Sally J. finder, squire Attorney for Plaintiff 9974 Molly Pitcher Highway Shippensburg PA 17257 HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA VS : CIVIL ACTION - LAW DOUGLAS R. KUTZ :NUMBER 2007- /9/5" CIVIL TERM Defendant : IN DIVORCE Defendant : IN DIVORCE COMPLAINT COMES, NOW, the Plaintiff, HEATHER R. KUTZ, by and through his counsel, Sally J. Winder, Esquire, and represents as follows: 1. Plaintiff is HEATHER R. KUTZ, who currently resides at, and whose mailing address is 2215 Ritner Highway, Carlisle, West Pennsboro Township, Cumberland County, Pennsylvania, 17015, since December, 1998. 2. Defendant is DOUGLAS R. KUTZ, whose currently resides at 145 South Side Drive, Newville, and whose mailing address is P.O. Box 462, Carlisle, Cumberland County, Pennsylvania, since February, 2007. 3. Both Plaintiff and Defendant have been bona fide residents 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 October 26, 1984, at New Cumberland, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff avers that he has been advised of the availability of counseling sessions for both parties upon request of either party or by order of court, and that a list of qualified professionals who provide such counseling service is available at the Domestic Relations Office upon request. By the filing of this Complaint, the Plaintiff acknowledges having been advised by his attorney of record of the availability of counseling sessions and a list of qualified professionals. Plaintiff further avers that he has been advised that the choice of a qualified professional shall be at the option of the Plaintiff and Defendant and need not be selected from the list available upon request and further, that arrangements for and the payment of the services of the qualified professional shall be the responsibility of the parties and will not be included in the docket costs of this proceeding. 8. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court enter an order divorcing the parties from the bonds of matrimony. Respectfully submitted, Sally . Winder, Esquire Attorney for Plaintiff 9974 Molly Pitcher Highway Shippensburg, PA 17257 VERIFICATION 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. Section 4904, relating to unsworn falsification to authorities. Date: 412,- 1 9 Z.oO -1 HEATHER R. KUTZ W r-? rn + v \ ?? ? ? HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - /LAW DOUGLAS R. KUTZ :NUMBER 2007- 146' CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Douglas R. Kutz, do acknowledge that I have received a true and correct copy of the Complaint in Divorce and Notice to Defend and Claim Rights, under the Divorce Code in the above-captioned divorce and accept the service thereof on April _U_ , 2007. I verify that the statements made in this Acceptance of Service 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 unworn falsification to authorities. Date: Douglas R. Kutz ?'-? ? ` j ? ?? ? y ?.. ?, C.? HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - LAW DOUGLAS R. KUTZ : NUMBER 2007-1915 CIVIL TERM Defendant : IN DIVORCE Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 9, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unworn falsification to authorities. Date: -1-1(0-0-7 464-? cei4A HEATHER R. KUTZ C`: ? ;? C? ? -?? _ ....., ?? ? ? ? ? { ? ? ?..?/ .' F ' HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - LAW DOUGLAS R. KUTZ : NUMBER 2007-1915 CIVIL TERM Defendant : IN DIVORCE Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) 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 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. Date: 7- It* - 0'1 AWAAIc KA? HEATHER R. KUTZ ` " .?° ,..; i' ?'? "' '?'7'? C ;,? 3 E"J 1, _ ? - ? ' ?;:; J.. ^ - < ? A ¢ HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - LAW DOUGLAS R. KUTZ : NUMBER 2007- 1915 CIVIL TERM Defendant : IN DIVORCE Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 9, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unworn falsification to authorities. Date: -7-16-07 ` u):3 - b - - P- ;Z? DOUGLAS R. KUTZ ?-- ? _.? -?7 a ' i~`'"J ?ry ?? " ?" 1 L P `.... ?...? Y`ai • ? ?? -. ? .? '•y HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - LAW DOUGLAS R. KUTZ : NUMBER 2007- 1915 CIVIL TERM Defendant : IN DIVORCE Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) 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 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. Date: 7 (0'07 (2 12 DOUGLAS R. KUTZ n r D L7 HEATHER R. KUTZ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs : CIVIL ACTION - LAW DOUGLAS R. KUTZ : NUMBER 2007-1915 CIVIL TERM Defendant : IN DIVORCE Defendant 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 S3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: U. S. Mail, mailed on April 9, 2007. Complaint accepted for service per the attached and filed Acceptance of Service verified by the Defendant as being served on April 11, 2007. 3. Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff 7/16/07; by Defendant 7/16 /07. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: 07/ ab /07. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: 07/ OLD /07. ally nder, squire 9974 M 1 Pitcher Highway, Shippensburg PA 17257 (717) 532 - 9476 Attorney for Plaintiff -?? n ?.? ? ? ?. ? ?? '.. ` --? i . c .- .- e y ? ` ';, :?: ?.:}: , .? k J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FSTATE OF PENNA. u A'1'r l? ? 11. XUT Z t LAI14TIFF NO. 2007 - jj T VERSUS ;SOU GLAS R . KU`' Z DEFENDANT DECREE IN DIVORCE AND NOW, JULY 2 L IT IS ORDERED AND DECREED THAT HEATHER R. KUTZ , PLAINTIFF, AND DOUGLAS R. KUTZ 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 E A 7k *- )??? e--f P L -L ?Q. Jz Z. HEATHER R. KUTZ, Plaintiff vs. DOUGLAS R. KUTZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2007 - 1915 Civil Term ACTION IN DIVORCE NOTICE TO RESUME PRIOR SURNAME To the Prothonotary: Notice is hereby given that the Plaintiff in the above matter: _ prior to the entry of a Final Decree in divorce. OR X after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of CLOUSE avowing her intention pursuant to the provisions of 54 P.S. §704. Date: loq Heather R. Kutz Prior Name Heatherklouse Signature of Name being resumed. COMMONWEALT OF PENLV? ) ):ss qzv? UNT?MB AA4 C On this, the day of 2009 before me, the undersigned officer, personally appeared ea er R. Kutz/ lou rsonally known to me, (or satisfactorily proven) to be the person whose name is subscribed to a thi instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereuntrrfttmy hand and NOTARIAL L SE L • NO P ibIIC JANE ADAMS Notary Public co mission expires: CARLISLE BORO., CUMBERLAND COUNTY My Commission Expires Ssp 6, 2012 OF THE P. C)TI-'ONOTARY 2004 JUL 22 PM I : G 3 f I -#// o #? P?#t ?31s St0s .;t 43e e'vv3 na4eall., ,],?