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HomeMy WebLinkAbout99-028879W4 1 i 7 :'? ' , ?,??i ? ?iti? ???'(! ?? 1 !. l ?n ,. J? ' '.:':.F ??? • ^? J G Oo a ?i 't :P`• :? A ?,_..:A ". .m 0:_tt .?-.{?•. O ?i ?i •:?• :?:•- {?• <?• L6:• {O• W.,*1': ? 0. .':1;•,.O.:i.O ,?, .0 "..0+: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF °+ PENNA. e X, SUZETTE.. E... JENKIN$.............................. I,I N O - ...99.-2887. ...CI n 19 99 Versus ....... .MATTHE ... .................... j DECREE IN DIVORCE AND NOW, Z.. , , • . • • , 200J.. .., it is ordered and . • E.• JENKINS• . • . • • • • • • . • • • . • • • plaintiff, decreed that . . . . . . . . . SUZETTE. ...... and ............. MATTHKW .U.. J.rWZN$ ....................... defendant, are divorced from the bonds of matrimony. e d The court retains jurisdiction of the following claims which have I been raised of record in this action for which a final order has not yet been entered; ? r ............ None ........................................................ By Th Cnyrt Attest: r a a I'rnthonolnry 00 i '3rr? s> .;K:.y:w? a: a:• •:a t?c? •:?: •w: ?:?:.,?> :?: s;• •:?:• :?: :?: :?: t?: :?> <?: a> n::o> c?: :e:• ts; c?: ;?j.. ?. ? ` ' SUZETTE E. JENKINS; IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION MATTHEW H. JENKINS, Defendant NO. 99-2887 CIVILTERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under §3301(c) .. aa?t?t9)(i<frdl>tCmcNlV>gtr?4aDtfrte. (Strike out inapplicable section). 2. Dale and manner of service of the complaint: Serve upon the Defendant by Certified Mail+ Re +rn Receipt Requp ted on May 22 1999 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: byplaintiff January 10+ 2001 ; by defendant January 1.5, 2001 (b) (1) Dale of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Related claims pending: 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecfpe to transmit record, a copy of which is attached: (b) Dale of plaintiff's Waiver of Notice In §3301 (c) Divorce was filed with the Prothonotary: January 22, 2001 Date defendant's Waiver of Notice In §3301 (c) Divorce was filed with the Prothonotary: January 22, 2001 JOHN J. KR4FSI6, JR Attorney at Law 2921 N. Fran Street Harrisburg. PA 17110 Atlo n •y for Plnlnfl m C?j r- U„C? to F r'l ?` aJ C%j !)CL cl ;? u SUZETTE E. JENKINS, Plaintiff VS. MATTHEW H. JENKINS, Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.'99-?IAP7 Cj+YEAR 1999 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 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 child or children. When the grounds for divorce is indignities or irretrievably breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone: 717-240-6200 n J. I fsig, J U E re ttorney or Plain • f 2921 North Front Street Harrisburg, Pennsylvania 17110 Telephone: 717-236-2109 Attorney's I.D. #06840 SUZETTE E. JENKINS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - 1,AW NO. 9I `MFA1t 1999 MATTHEW H. JENKINS, Defendant IN DIVORCE: COMPLAINT AND NOW, comes the above mentioned Plaintiff', by her lawful counsel, John J. Krafsig, jr., .Enquiro, who pursuant to to the provisions of 23 Pa. C.S.A. 43301(c), requetst.s the grant- ing of divorce, upon which the following is a st:ateuvant: 1. The Plaintiff is an adult: individual, who currently resides at 11 Louis Lane, 1':nola, Cumberland County, Pennsylvania 17025; and has resided there the pant four (4) years prior to the filing of this Complaint. 2. The Defendant ie an adult: individual, who currently resides 601 Fifth Street, New Cumberland, Cumberland County, Pennsylvania 17070; and han resided there since on or about April 7, 1999, after proviouiily residing at 11 Louis Lane, Enola, Pennsylvania 17025 for approximately four (4) years prior thereto. 3. The Plaintiff and Defendant had been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Com- plaint. 4. The Plaintiff and Defendant were married on May 24, 1997 at Enola, Cumberland County, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties, of record. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counsel- ing is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The Plaintiff requests the Court to enter a Decree of Divorce, pursuant to 23 Pa. C.S.A. §3301(c). Respectfully submitted, J J. Kr sig, Jr. E i e torney f r Plainti 2921 North Front Street Harrisburg, Pennsylvania 17110 Telephone: 717-236-2109 Attorney's I.D. #06840 May j '0_, 1999 - 2 - J VERIFICATION AND NOW, to wit, this 14 V4 day of May, 1999, I, Suzette E. Jenkins, the within Plaintiff, do hereby certify and state the facts as set forth in the foregoing Complaint, are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. , S?iz tte E. Je kins, Plaintiff ra ?'n n f 7 u l ?J' (1? 'Lb 19 ? V Lj \ t b t ? U !ll ll? . .. SUZETTE E. JENKINS, Plaintiff VS. MATTHEW H. JENKINS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. YEAR 1999 IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, John J. Krafsig, Jr., Esquire, attorney of record for the above mentioned Plaintiff, who, being duly sworn according to law, does depose and say that he deposited in the United States Mails, at Camp Hill, Pennsylvania, on May 17, 1999, addressed to the said Defendant, Matthew H. Jenkins, by Certified Mail, Return Receipt Requested, a true and correct copy of the Complaint in Divorce filed to the above mentioned term and number, with Notice to plead within 20 days from date of service. The said Complaint and Notice were duly delivered by the United States Post Office to the said Defendant on May 22, 1999, as will more fully appear from the attached Return Receipt Card, Certified No. P 463 787 512, bearing the signature of the said Defendant, as the individual that the same was addressed to and that said Return Receipt Card being attached hereto and made a part hereof, establishing that legal service of process in accordance with the Rules of Civil procedure has been complied with. inL52, r., uire ttorn for P1 ti 2921 North Front Street Harrisburg, Pennsylvania 17110 Telephone: 717-236-2109 Attorney's I.D. #06840 Sworn to and subscribed to this _day of May, 1999 Notaryl<Pu 1 My commission expires: NOTARIAL St:At 4 SAfdDfiA L 5''Ii^FR, E{3fflS?ill1? [! '' ' P 463 787 512 v a 0 c C a a V e a us Postal Service Receipt for Certified Mail No Insurance Coverage Provided. M.. 1.- fn. lelnrnolinnnl 6Aail Loan mi nma) to w H. Jenkins ei`th Street 4 P Code ate, a, ZI $ Conified Fee Special Delivery Fee Residdod Delivery Fee Return Receipt shoeing to Whom&Dal Delivered ' Rehm Slgwuq to tNren, Adtess Date, AW s ?? '? TOT k,? d7Pa j q Pas r0ale 70 '+"..,eati:. iMWpnnw,tNr.^.,.trt^'Ply fe. . ..r,.?,..'9•."RT'w'?C.y.t^.' y,;.v.,.,^. :+Ir+wo+5.,,.,., i «,.,.^t`!•.: m?rnN::..?mri+e^.1 stN g ' y DER: :Complete hems 1 and'or 2 for additional services. I also wish to receive the :complete hems 3,4a, and 4b. following services (for an ePdm your name and eddrese on the reverse of this form so that we can return this extra fee): xrd to you. Attach this form to the front of the maliplecs, or on the back h space does not 1. ? Addressee's Address 1 eW e1RebrmRa IpfRquaned'onthe mellpiembelow the article number, 2.0 Restricted Delivery :Tie Return Receipt will show, to whom the Hide was dethroned and iM date dellvared. Consult postmaster for fee. . 3. Article Addressed to: 4a. Article Number ? . ISr. Katthew H. Jenkins P 463 787 512 E. 601 Fifth Street ab.servlceType 1 - ? Registered © Cert1A New CmitteraIrld, Pa.. ? Express Mall t] Insured Its. w, 17070 ? Retum RsoW for Merdtandse O COD 7. Da of nwhtary $ , 5. Received By: (Print Name) 8. Addressee's Address (Only if requested a` twi-`t and fee is paid) ; 9 6. Signature: (Addressee orAgenf) X )its r 2 Ps Form 3811, DecerrIlAr 1994 Domestic Retum Receipt I,- ?. SUZETTE E. JENKINS Plaintiff VS. MATTHEW H. JENKINS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2887 CIVIL TERM, 1999 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c), of the Divorce Code was filed on May 12, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of 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. 4. 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. 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.A. §4904 relating to unsworn falsification to authorities. Dated: 0 0 (J-- ze to E. Je kins, Plaintiff 1-- L!.1 L'. C71 _7 ? ),, liar. ;? cl: ^ n .'8.: i3 Lll U C7 CV SUZETTE E. JENKINS Plaintiff VS. MATTHEW H. JENKINS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2887 CIVIL TERM, 1999 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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, lawyers 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 file 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. Pa. C.A.54904 relating to unsworn falsification to authorities. Dated:?? z t e E. nkins, Plaintiff ? S } f r C- 71 Y - . 7 uLu i?? c7 U SUZETTE E. JENKINS Plaintiff VS. MATTHEW !i. JENKINS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2887 CIVIL TERM, 1999 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c), of the Divorce Code was filed on May 1.2, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of 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. 4. 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. 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.A. §4904 relating to unsworn falsification to authorities. Dated: I / Is-/y t ,+ -T- Matthew H. Je tins, Defendant UJn f`) r. C; L)g v:. N _Z ] `.:. (L O U SUZETTE E. JENKINS Plaintiff VS. MATTHEW H. JENKINS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2887 CIVIL TERM, 1999 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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, lawyers 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 file with the Prothonotary. 1 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. Pa. C.A.§4904 relating to unsworn falsification to authorities. Dated matt, new H. Jenki , Defendant } :. - , ELI