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Home My WebLink About01-6035MARK R. KLINE DEBRA A. KLINE Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01- /a~ CIVIL TERM : IN DIVORCE NOTICE 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 divome 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 MARK R. KL1NE DEBRA A. KLINE Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 01- ~ : IN DIVORCE CIVIL TERM COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mark R. Kline, who currently resides at 1122 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania, since 1996. 2. Defendant is Debra A. Kline, who currently resides at 267 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, since March 2001. 3. Plaintiffand Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 2, 1992, at Hagerstown, Washington County, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. I verify that the statements made in this Complaint 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: Iv~k R. Kline, Plaintiff''''~ - - ANDREWS & JOHNSON B '/ Ronald E. Jo~fi{~n, Esq. ! Attorneys ~Sr/,Plalntiff 78 W. Poffffret Street Carlisle, PA 17013 (717) 243-0123 MARK R. KLINE DEBRA A. KLINE Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01- 6035 CIVIL TERM : 1N DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : COUNTY OF CUMBERLAND ) AND NOW, this 29th day of October 2001, I, Ronald E. Johnson, Esquire, attorney for Mark R. Kline, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiffin the above-captioned matter, upon the Defendant at her residence at 267 West Ridge Street, Carlisle, PA 17013, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on October 26, 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON Sworn and subscribed to before me this 29th day of October 2001. Nt~ry Puglic [ Ronald ~. JohI~/e~ / Attorney for ~)fiintiff LY SEXTON, NOTAfly PUBLIC BORO, CUMBERLAND COUNTy I MY COMMisSION EXPIRES APRIL 26 2003 · Complete items 1, 2, and $. Alao complete A. Reciived b Item 4 if Re~tricted Delivery is desired. · Print your name and address on the reverse .o that we can return the card to you. · Attach this card to the back of the mallplece, [] Age~ o~ o~ the front if space permits. I~ Addnl~ll~ D. tsd~add,~difismntfm~lteml? r'lye~ : , 7 J'(~e~ ~ ~'~J-' 77~0 PS Form ~200~"'~'"""'""""'Dom#t~c Re~u~n~ Exhibit A MARK R. KL1NE DEBRA A. KLINE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01- 6035 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 22, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. § 4904, relating to unswom falsification to authorities. Date: Debra A. Kline, Defendant MARK R. KL1NE DEBRA A. KLINE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01- 6035 CIVIL TERM : 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, 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. §4904, relating to unsworn falsification to authorities. Date: Debra A. Kline, Defendant MARK R. KLINE Vo DEBRA A. KLINE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01- 6035 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 22, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) 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. [ 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: Mark~_..- Kline, l~laintiff MARK R. KLINE DEBRA A. KLINE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01- 6035 CIVIL TERM : 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 ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 thc decree will be sent to mc immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit arc true and correct. I understand that false statements herein are made subject to thc penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: Mar(R. Kline, Plai ' MARK R. KLINE DEBRA A. KLINE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01- 6035 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THEPROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2 Date and manner of service of the complaint: October 26, 2001 by restricted delivery, certified mail return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff March 8, 2002; by Defendant February 6, 2002. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~'~. ~'~ /~,, ,~ Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date: Marcl~t_~,,, 2002 March 5, 2002 ANDREWS & JOHNSON 7 ~n~id 1~. Joh~o~ [~sq. / 78 West Pom~rj~f Street [ Carlisle, PA. t'7013 (717) 243-0123 Supreme Court ID No. 16453 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~ PENNA. PLEAS .................................. ~LA-IN-T-I-F-F ............................... Versus .... DEBRA..A~._KLINE_, ............................................. .............................. pEFg_~D:ANT N o .... 0x.-.6aas ....................... 19 DECREE IN DIVORCE AND NOW, . ........... ~ .... it is ordered and decreed that ~RK R. K~.ZN~. plaintiff, d D-S~ A. ~zN~. defendant, an ......................................................... ' 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; ........... ~ ...... / /~ Prothonotary