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HomeMy WebLinkAbout99-03157 r:.c j 4JF: t :it IA ?ti1T1 4 S 1,4 ?Y vM j 14r. 1 '?I tJ M. 0% 6V i i cc• xe•. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ??. PENNA. e P d :. 99 3157 Civil AMY.-MICHELE KING.......... _ ........ Nc? .:.... ...... II i o Versus w ALEX LESLIE DORIAN...KING .................. f u DECREE IN P 'E rv RC 3 37?/*1= AND NOW, 0a4-.L . ........... , 19 ........ it is ordered and decreed that ...... AMY MICHELE KING plaintiff, and .......... ALEX • LESLIE, DORIAN. KING ....... , . • • ...... • , defendant, i ••.' 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 ........... .............. F y ?i Vii: uc• •y:• .,k x x..w..W. -Wo •A". •:R• •H: :a a. te:• :e; ce:• :e:• ;r. p. Prothonotary W. IW. C?:• Le:• •:#:• •. I. I.C. •v;• •:e:• ;e;• ?J ?? AMY MICHELE KING, Plaintiff Vs. ALEX LESLIE DORIAN KING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3157 Civil IN DIVORCE PRAECIP 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: Irretrievably broken under Section (xx 3301 () or ( C ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint: Certified Mail on 51a???? 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 11,341 3301(c) of the Divorce Code by Plaintiff Y-N)\m -UA1z1D Vby Defendant (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A date of service of Plaintiff's affidavit upon Defendant: _N/A 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: _N/A_ Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff iw. ; by Defendant r •;n 1 U7 C3 C!N Cn t, 1 f Plaintiff IN THE COURT OF COMMON PLEAS e- l,/ I VL CUMBERLAND COUNTY, /PENNSYLVANIA VS. NO. ?)ex a-?Jie- rio n K.iv?, Defendant CIVIL ACTION 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 Cumberland County Courthouse, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISIONOF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOST 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 (71.7) 249 3166 or 1 800 990 97.08 CCMMUA In the a I QAt In re: The Marriage of: Court for CL+rnberl'n County, State of Qnf I J4niq f?n1y 1'11`IC.1?ea? h',i?rl and Y?le.,x LGs\'t e, iI-, ,? kt11 D eFc v1? c.vt %y - Case No: 9,? - 3/ S`7 VERIFIED ?or?y a?G, ?u?l i I v? rCe eF I„alY-if„ol?y 1. This is a -0-0)-),\ of ?i «r,llA tip, yi?a ?)c,nct between A??? 1llicl cle k?cl 2andNe-Y, Le k?`^- I)eyC IvA 2. The ??IC,'lI?A!F ` Cut°,he'r1ti ,d is a resident of Cy', c a ii, and has been for more than rn L. ' S immediately prior to filing this Q-orn PIS i?_ and has resided in the County of (-u t\*\V Q_t 3a-lam for at least G )-,Ion-1 ltil 3. The N 11-? has agreed to file an Answer and Affidavit in Support of N W? No service of process is necessary at this time. 4. Neither party is currently on active duty in any branch of the Armed Services. 5. The parties were married to each other on D(iv e r V 2 f 19 17 in the state of 1 2 Scuff( L !(L' ea , and have been separated since _ Yc" ?? - O E,2 Lepsf Forme 191M Before you use this tam. reed a and fill in the blanks. consult a Lawyer N you dWbt the famt fimass for yos purpose end use. EEZ Legal rams end the retailer maker representation a warranty, espress a Implied, with respect to the mamhantabllity of this fam fa an intended use a purpose. K102-3A 6. U Choose one of the following: No children were born to or adopted by the parties of the marriage and none are expected. b. There was/were ?- child(ren) born as issue to this marriage, to wit: (name and date of birth) 2.--- 3. 7. The t 71VC F seeks a Final bccryQ 'in iVOEC on the grounds of: T rre+Y-iQ_vo?bl,y &X-C-)terz?t 8. The parties have made provisions for the division of their property and payment of their joint obligations, they have signed a Marital Settlement Agreement and they are satisfied with those provisions. Their signed Financial Statements are attached and incorporated by reference. Each party certifies that the Marital Settlement Agreement and Financial Statements were signed without duress, force or collusion. (The Marital Settlement Agreement is attached and marked as Exhibit A.) N1 H 9. The N hereby waives any rights to findings of fact and conclusions of law, a record of testimony, motion for a new trial, notice of entry of Final Judgment or Decree, and the right to appeal, but does not waive any rights to the future modification of any judgment or decree in this cause. 10. The marriage is irretrievably broken and any continuance of these proceedings will not result in a reconciliation. Wherefore, the Iii I rvj ?F respectfully asks and prays that the court: 1. Take jurisdiction of the parties and subject matter. 2. That a Final DQC rI2Q i>? N V be granted by the court dissolving the marriage between the parties. 3. That all of the terms and conditions of the parties' Marital Settlement Agreement, which is attached, be approved and be incorporated, and made part of a Final N / hi and that the court enforce the Marital Settlement Agreement. Regardless, the Marital Settlement Agreement shall survive. 4. That the court award the parties any other further relief as may be just and equitable. Q Ed t49W Fame 1093. &ll,e you ure frn5lo: m, mad a alu lul In It,, tip:.rx,s C I'l, a hwm, it yuu doutll the fpm: fdrwsS U You, pulp,., and,x G2' Legal I°amS end Itle retailer?WAe norepre5orn.11m p Wa,s,, "P"I"nlpl"'d, Willi le&pI1Cl IU ttlA mti. CII?n1?U IIY of Its5lolm lot an IItIOn Oat use or purpose K102.39 Dated this /9 day of?nLLU , _/ 99?-tyearl. Q.NyIM tZ? • l ?t?.? Wife's Signature Address: _Arh u M. 1&1 `111 S1?e?F?er Ci , Cv1t o? It 1-7b2S Phone: t -0 `132 - q ID U VERIFICATION State of.n ca. County of _ I,- Only/ KING , being duly sworn, depose and say that: I am the Petitioner/Respondent in the within action for divorce; I have read the foregoing Complaint/Petition and know the contents thereof; the contents of the Complaint/Petition are true to my knowledge, except as to those matters therein stated to be alleged upon information and belief, and as to those matters, I believe them to be true. ?nLy1 /YI • lit {,?,^ Wife's signature On-M, before me, 7-,vn!24 y e! n! - ersonally appeared 1"v le?Az personal y known to me (or proved tome on the basis of satisfactory evidence) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. si Z Sig otary NGTA. b+L.. EAL TAMMY L. KEMP, NO-:ARV HAND VF, R. Y6ri;l CC,1L .. Affiant_Known Produced ID Type of ID ??'A PRI414eS c, /.^F uSF_' (Seal) O EZ L"d Fom,a IN& netae you use this tam, read n and fill in the blams. consult a lawyer d you doubt the famt Mross lpr yotr purpose eM use. EZ 1.n,1al Forms and the retaaer make m repreSeMBIKm a warranty, eMpiess or impl ed, w,m reseed to the me,chantabliey of this lam la an "ended use a purpose. K 102-3C Husband's Signature ct Address: Phone: VERIFICATION State of County of «1 J : ,. C U? (mi l being duly sworn, depose and say that: I am the Petitioner/Respondent in the within action for divorce; I have read the foregoing Complaint/Petition and know the contents thereof; the contents of the Complaint/Petition are true to my knowledge, except as to those matters therein stated to be alleged upon information and belief, and as to those matters, I believe them to be true. On before me, Husband's signature _, personally appeared personally known to me (or proved to me on the basis of satisfactory evidence) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. Signature Affiant-Known _Produced ID Signature of Notary Type of ID (Seal) IF A NONLAWYER HELPED YOU FILL OUT THIS FORM THEY MUST FILL IN THE BLANKS BELOW (fill in all blanks): I (name of nonlawyer) nonlawyer located at (street) (city) (state) (Phone) helped (name) who is the [d one only) -petitioner or -respondent, fill out this form. O C3 Legal Fctma 1901 Was you use this lam, read a and all in the blanks. Cwwlt a lawyer d you doubt tlm Ii fitness la your purpmia and use. 6Z Legal Forms alb the retailer make no representation a warranty, express a implied. wtth respect to the merchantabi rty of this lam la an lnlentlM use a purpose. K102.301 AMY MICHELE KING, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. ALEX LESLIE DORIAN KING, Defendant No. 1;)-3157 Civil DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 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 in Divorce. 4. 1 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. 5. I have been advised of the availability of marriage counseling, and being so advised, I do not request that the Court require my spouse and myself to participate in marriage counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date:3 Amy Mich le King, Plaintiff } co T i 1 U L) C AMY MICHELE KING, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. ALEX LESLIE DORIAN KING, Defendant No. 99-3157 Civil DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 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 in Divorce. 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. 5. I have been advised of the availability of marriage counseling, and being so advised, I do not request that the Court require my spouse and myself to participate in marriage counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, re), ing o unsworn falsification to ori7.4 Date: ! Alex Leslie Dorian Kine. efendant C3 C? '? "7 2 AMY MICHELE KING, Plaintiff Vs. ALEX LESLIE DORIAN KING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3157 Civil CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF TIME DIVORCE ODE 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 Waiver 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 unswom falsification to authorities. Date: _Ql_ G,?11tc?ik? f? Amy Mich le King, Plaintiff r r> `E- ?.. 11.1•--'. i i ?..) ,! cr, CA U AMY MICHELE KING, Plaintiff Vs. ALEX LESLIE DORIAN KING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3157 Civil CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF WENTION_TO REQUEST ENTRY OF A DIVORCE DE REE UNDER SECTION 3301( c ) OE THE DIVORCE CODE. I. I consent to the entry of a final Decree in Divorce without notice. 2. 1 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 Waiver 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 unswom falsification to authorities. Date: Alex Leslie Dorian King, Defen ant UJ 1 ?' U7 r._ C' C7i c. U -t AMY MICHELE KING, Plaintiff vs. ALEX LESLIE DORIAN KING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-3157 Civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF 9AbTHfN 0ujA6rJctn3 Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Amy Michele King, Plaintiff who being duly sworn deposes and says that a true and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce code has been served upon the Defendant, Alex Leslie Dorian King, at his address of d/l OW'cjtl- S'rv-C)ei' Phu. 1 rr1? Ala , rloh--r din 9oC6 y First Class, United States Mail, Certified No. IF,, '-1 WI S 0 7 1 a_Z Attached hereto is the returnreceipt card executed by Alex Leslie Dorian King dated TAI v7 Q-- 9 evidencing receipt of the same. Amy Michele King Swom and subscribed to before me this c2b_ day of 1999. Public L NOj $UTANNE M. ONotary PuWlt Camp HM, d County Commtss. 20.2001 ;,. Y P1 Er ? r '? ?_ = ' , ? ?! ? '? i - ??.. ,-.1 ? ?1 ; : :? ?_ nut ? V+ i ' ' , ??l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. I?C?k l ?'?e ?oYl? Defe ,jt File No. 1 - 31s / C; Vi IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the day of Cs-..4vtt? , 19 `l1hereby elects to resume the prior surname of 0. I e. ) cl, rvmCi r) , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: C?C 1 c. ID, J G) I Signature r? Signattfte of nave being resumed COMMONWEALTH OF PENNSYLVANIA: . SS. COUNTY OF CUMBERLAND On the ? day of ajObe( 19q , before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunt'set my hand and official seal. otary Public NOTARIAL SEAL 114 ZANNE U. DEOERER, Notary Public CemP HBI, Cumb&brd County CanWWM Evh3 Aug. 20, 2001 2 m N 02 I!. rl