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Home My WebLink About99-03408 u a d h ? L 2 ,i U ao 10 '•I vt ej i i i e 'Y .VY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. I1 W?k DEDORA.11._UNDERKOFFLER....................... ... Plaintiff ................... .................................... Versus KENNETH...R......UNDERKOFF. LER.,.,.$R. ............. Defendant No . ..... y. 77.3!#08 .................. 19 li I? DECREE IN DI V 0 R CE a F F AND NOW, .........r1lrr?u'' ..29 +... , 19.9.9..., it is ordered and decreed that . . .:. . . . De.b. orah. L. U.n.d.erk.o.f.fl.e.r . . . . . . . . . . . . . .. Plaintiff, ............... and.................. Kenneth R. Underkoffler defendant, are divorced from the bonds of matrimony. s 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 0 been entered; ...None ................................................................. i ny%?h C 0 n/t. Attest. J. rothonolnry l? -0W rX? h: •:4;• ?JY? {4i ^:/C• •y:• •Y, X. W, W .4? W. E .4, ti4: .6 .Oi •.4, A. .4; ..0...E ':1, .4. _ A:• 4i •:4} YO y? I x•30 DE130RAH L. UNDERKOFFLER, Plaintiff V. KENNETH R. UNDERKOFFLER, SR., Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-3408 : CIVIL ACTION - LAW : IN DIVORCE Transmit the record, together with the following information, to the Court for entry of Divorce Decree: 1. -Ground for Divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and Manner of Service of Com taint: Service on the Defendant was made by certified mail on the 8" day of June, 1999, pursuant to an Affidavit of Service filed herewith. 3. D& of execution of h Affidavit of Docent required WOO I (Q) of then rce ode: by Plaintiff on September 17, 1999; by Defendant on September 11, 1999. 4. Related Claims Pending: No related claims were filed. 5. Date Plaintiff s Waiver of Notice in §33Q I(c) Divorce M filed with the prothonotary: Dated September 17, 1999 and filed herewith. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: Dated September 11, 1999 and filed herewith. Jefinifer 1, Lehman, Esquire Date: ,of Attorney for Plaintiff boy. ?.? /999 Plaintiffs Social Security No. 19242-9929 Defendant's Social Security No. 175-38-9903 ?? 4? a J 7 U ? ? ?u CO LL N 0. ii W C`; J t U 5 m Jennifer L. Lehman Attorney at law 6130 27 South Arlene Street Harrisburg, PA 17112-0130 717-671-1200 DEBORAH L. UNDERKOFFLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. KENNETH R. UNDERKOFFLER, SR., Defendant NO. ? - .3 y4e 4zt" CIVIL ACTION - LAW 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 lase money or property or other rights important to you. When the ground for 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. 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 (717) 249 3166 or 1 800 990 9108 DEBORAH L. UNDERKOFFLER, Plaintiff V. KENNETH R. UNDERKOFFLER, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99. ,3yor ava% lee.-- CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 33010 OF THE DIVORCE CODE 1. Plaintiff is DEBORAH L. UNDERKOFFLER, currently residing in Cumberland County with a mailing address of 2417 New York Avenue, Camp Hill, Pennsylvania 17011. 2. Defendant is KENNETH R. UNDERKOFFI.ER, SR., who resides at P.O. Box 23, Rt. 209, Tower City, Schuylkill County, Pennsylvania 17980. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 29, 1991 in Pottsville, Pennsylvania. 5. Plaintiff avers that there is one child of the parties under the age of 18. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 10. Paragraphs 1 - 9 are herein incorporated by reference. 11. The Plaintiff avers that the grounds on which the action is based are as follows: (a) That the marriage is irretrievably broken. (b) The parties are now living separate and apart, at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, JENIUER L. LEHMAN, ESQUIRE Attorney I.D. 952784 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112 (717) 671-1200 Date: ` wxz 2: IM I verify that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. rlf?? 6J11L. 4.L?J ll»d41 DEBORAH L. UNDERKOFFL Date: /a///99 >- ?; u, c c? >> =S. i? `= ?-- ?,?, ..? ??-- «,?,. :, _, ?. r? -i.. ? t?.? cL F.. ? t? ? CJ \ ? ?\ ??? ? ? `?.' Jennifer L. Lehman Altorney at Um 11.0. BOX 6180 27 South Arlene Street I larrisburg, rA 17112-0130 717-671-1200 DEBORAH L. UNDERKOFFLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. KENNETH R. UNDERKOFFLER, SR., Defendant :NO. Clvl! CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 15, 1996 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand 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. §4904 relating to unswom falsification to authorities. 2+r Date: 117 ?'1 DEBORAH L. UNDERKOFFLER PLAINTIFF tic; Z G ' ?a- ? Ol U DEBORAH L. UNDERKOFFLER, Plaintiff v KENNETH R. UNDERKOFFLER, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3408 CIVIL : CIVIL ACTION -LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, JENNIFER L. LEHMAN, ESQUIRE, do hereby certify that a true and correct copy of a Complaint Under Section 3301(c) or 3301(d) of the Divorce Code and an Affidavit Under Section 3301(d) of the Divorce Code was served upon the Defendant, KENNETH R. UNDERKOFFLER, SR., by certified mail, return receipt requested, on the 8' day of June, 1999. The original signed return receipt, number P 234 041682, is attached hereto and made a part hereof. Respectfully submitted, JENNIFER-L. LEHMAN, ESQUIRE Supreme Court I.D. 452784, P.O. Box 6130 27 South Arlene Street Harrisburg, PA 17112 (717)671-1200 Date: (,111149 F SENDER: •COVRt& h6m• 1 ntdror z for eddWonW •ervim. 1 also wish to receive the m r:omgae IIM 3.40. W 4b, following services (for an •P60 your name nq •ddam m the n c4lodlo ou Me extra too): •ppNeetnftmd tNe Poem to the a0M of the mWl rwl 1 • '6 Ad eae The RO oe/WRepwsfed'onlM 2. M"cted Delivery I 5. •The aNUm eecWp wf3 chow to vdtom ae Wtltle weo daYvorW end. e dolivrred. 3. Article Addressed to: KENNETII R UNDERKOFFLER, c/o DENISE MERWINE P 0 BOX 23 RT'209 TOWER CITY PA 17980 5.q7shed 6y: (Print Name) S 6. Slgnatur Addressee or enf) PS orm 3811, December 1994 pj Donsu Poo ar r as. 4a. Ardcle Number /°R 2!2 ou/ 61 Zv 4b. Service Type ? Registered 8 CarMod t ? Express MaU ? Insured S . m Receipt for Merchetxlae ? DDD ' 3 tDal a o1 De l lye / f 3. Addressee's Address (Ontyllrequested d ! en eels pew) tv_ f :. J i.. C.J Y CIN ..J DEBORAH L. UNDERKOFFLER, Plaintiff V. KENNETH R. UNDERKOFFLER, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3408 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on June 17, 1999. 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 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 unworn falsification to authorities. Date: 7 DEBORAH L. UNDERKOFFL PLAINTIFF uj .0- i - N C? u (`i LL ( i W cn (Dp , 4 C7' C71 m DEBORAH L. UNDERKOFFLER, Plaintiff V. KENNETH R. UNDERKOFFLER, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3408 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 19991. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on June 17, . 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 after set-vice 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 unswortt falsification to authorities. Date: 4?CENNETH R. UNDERK ? ??e?? OFFL R. DEFENDANT Y In ? Ln , 4JC? M 7 Oj ? Ui`) U<i 1 ? ? LiA 1 ? _ .. i C7 U DEBORAH L. UNDERKOFFLER, Plaintiff V. KENNETH R. UNDERKOFFLER, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3408 CIVIL ACTION -LAW 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: 4 17 4 J4 ia? oZ &nd11 _ chi-t-Ol_l?-- DEBORAH L. UNDERKOFFLERt PLAINTIFF 4 UI?? M pr?: urr.i. -y' cv '_ cq :5z LLB' cr Co CL Q t71 (,J DEBORAH L. UNDERKOFFLER, Plaintiff V. KENNETH R. UNDERKOFFLER, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3408 CIVIL ACTION - LAW 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 unworn falsification to authorities. Date: E I NNETIi R. UNDERK ER, SR. DEFENDANT r5 C\j CL - w d c an U