Loading...
HomeMy WebLinkAbout99-04036?? to i i i i i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. No. 19.9.97.49.3.61- g J0SBPH..M...KNOBLB. ? Versus .KATHRYN Me KNOBLE_ DECREE IN DI VORCE s A; C-T Xa AND NOW ......... ................... . 19*6..... it is ordered and decreed that ..............JOSEPH M. KNOBLE•,, plaintiff, and ....................... KATHRYN. M.. KNOBLE................. , 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 is been entered; N/A ................... ......................... P j By The o y Attest: ^ _._ __ J s Prothonotary i /A}. •?.. ,?. .S. .A. .A• :?• <?• :?: cE• :W} W. -W 'W} 1XI s• A.- -W, 1W... U:• ?•:?: t? .V? :e. to 'W.- -XI IV, :V.• W. 1 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 1999 - 4036 Kathryn M. Knoble, Defendant In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit to record, together with the following information, to the court for entry of a divorce decree: Code. Ground for divorce: irretrievable breakdown under 3301(d) of the Divorce 2. Date and manner of service of the complaint: Complaint was mailed to defendant on July 6, 1999, by certified mail, restricted delivery. Defendant accepted service of the complaint on July 9, 1999. 3. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code: June 29, 1999; (2) Date of filing and service of the plaintiffs affidavit upon the respondent: Plaintiffs Affidavit was filed on July I, 1999. Plaintiffs Affidavit was served on Defendant on July 9, 1999. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Notice of Intention mailed by regular mail on August 2, 1999. ?zct dP arbara B. Tow end c Attorney for Plaintiff ?,, ,.: _:., ?. ?. . .. . IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. AK. 1999- W36 4w- Kathryn M. Knoble , Defendant In Divorce a v.m. 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 Office of the Prothonotary at the First Floor, Franklin County Court House, 157 Lincoln Way East, Chambersburg, 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 1999- qO.3G &c J 7 t-- Kathryn M. Knoble, Defendant In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE NOW comes the Plaintiff and for cause of action against the Defendant says: Plaintiff is Joseph M. Knoble, who currently resides at Lot 225 S.M.E., Shippensburg, Southhampton Township, Cumberland County, Pennsylvania with a mailing address of P.O. Box 241, Shippensburg, Pennsylvania 17257, since February 1999. 2. Defendant is Kathryn M. Knoble, who currently resides in Borough of Camphill, Cumberland County, Pennsylvania with a mailing address of 128 South 31st Street, Camp Hill, Pennsylvania 17011, since April 1997. 3. 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 March 25, 1995, at Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment of marriage between the parties in this or in any other jurisdiction. 6. The marriage is irretrievably broken and the parties have lived separate and apart for a period of at least two years. 7. Plaintiff has been advised of the availability of counseling 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. arbara B. Town end Attorney for Plaintiff I hereby verify that the facts set forth in the foregoing instrument are true and correct to the best of my knowledge, information and belief, and that I make this verification subject to the penalties of 18 Pa.C.S. 9909 relating to unsworn falsification to Authority, as authorized by the Judicial Code and Pennsylvania Rules of Civil Procedure. Date: (', t 1 ??. I 1 l _ 1 _f - ; _ ,., CJ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. ?Glf 1999 - 1103 Kathryn M. Knoble, Defendant In Divorce a v.m. NOTICE TO THE DEFENDANT 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. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated not later than April 1997, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I understand 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: Lo-A9- 99 fiJ 1? Plaintiff L IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 1999 - 4036 Kathryn M. Knoble , Defendant In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE To: Kathryn M. Knoble: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter affidavit to the 3301(d) affidavit. Therefore, on or after August 23, 1999, the other party can request the Court to enter a final decree in divorce. If you do not file with the prothonotary of the Court an Answer with your signature notarized or verified or a counter affidavit by the above date, the Court can enter a final decree in divorce. A counter affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter affidavit alone does not protect your economic claims. 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 - " ?r; . ?: V: ?n -J t_l ?? U IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 1999 - 4036 Kathryn M. Knoble, Defendant In Divorce a v.m. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): -- Ua I do not oppose the entry of a divorce decree. __(b) I oppose the entry of a divorce decree because Check (i), (ii), or both: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): __(a) I do not wish to make any claims for economic relief. 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 wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. ' fi fY: ._ J (' ?, I L•? •• la 1 i:l :? ,i l.. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ss4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 199 - Kathryn M. Knoble, Defendant In Divorce a v.m. AFFIDAVIT OF NON-MILITARY SERVICE Plaintiff avers that the Defendant, Kathryn M. Knoble, is not now and has not been since the commencement of this action in military service of any branch of the United States or any political subdivision thereof. A/` 8'G?G9 P?IFF I verify that the statements made in this Affidavit of Non-Military Service 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 perjury contained in 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: Cl - I -92 O'? P I TIF ?, i.J ?(? _.? L ?, I . ! V G': ?.? __ :J IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 1999 - 4036 Kathryn M. Knoble, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA :SS COUNTY OF FRANKLIN Barbara B. Townsend, Esquire, being duly sworn according to law, deposes and says that she sent a true and correct copy of the Complaint in Divorce and Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code to Kathryn M. Knoble, at her last known address of 128 South 31 st Street, Camp Hill, PA 17011, by certified mail, restricted delivery, addressee only, No. P 520 057 733, receipt attached hereto, postage prepaid on July 6, 1999, from the United States Post Office at Chambersburg, Pennsylvania. Barbara B. To send ? - ,, ___ ..._ .... .........._ PS Form 3800, A r m 8 9 n LforsNtbnal Mass; I also wish to receive the p II 1895 (Reverse) a h. , o lowinB-' amices (for in extra 1 7.4 z.. . EM', }ee): .2 a 1.. ? Addressee's Addreec j 'Ins« 2 lieRestrleted Deliver „La w y t I1 P? : ; s f71.b 1 44,Arti cle Number - 4b. Service Type ? epi ? Insured ? C III S ., COD s e " - , ? ?? ss M j t etum Receipt for erchandive g 7.?:D teof Y . er __ a AA ' t T A sea's d' s (Only if requested l Vkei d) . . O a oa _ o ?LL os101fice,S e,a21P 0000 1 I I Postage $ . Certified Fee Specal Delivery Fee Resldged Delivery Fee Rolum Recepf ShoWg m VRwm B Data Delivered gpNm Rttetp Slbnrx; to VNam Dale, a Mdessee's Adhss TOTAL Pm' - aFees rJ PoslmaA or Dale O? IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Civil Action - Law Plaintiff VS. F.R. 1999 - 4036 Kathryn M. Knoble, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN ? SS Barbara B. Townsend, Esquire, being duly sworn according to law, deposes and says that she sent a true and correct copy of the Complaint in Divorce and Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code to Kathryn M. Knoble, at her last known address of 128 South 31st Street, Camp Hill, PA 17011, by certified mail, restricted delivery, addressee only, No. P 520 057 733, receipt attached hereto, postage prepaid on July 6, 1999, from the United States Post Office at Chambersburg, Pennsylvania. /Barbara B. Tovy(isend Notary Public 78renemar Renee fary Public Chambenklln County My Comune 9, 2003 r r L13 L N -fir i • 1 fL - ti i'jJl' J 7i CJ a L_ U I ,?? _) I SENDER: r f complete items 1 mi 2 for additional service.. • Complete hams 3, and ea a b. I also Wish to receive the t • Print Your name and address on the reverse of this form so that via can return this card to you. t0110Wing services ?Or an extra feel: e P e Attach this form to the front of the mellPllce, or on the back if space does not permit. 1. ? Addressee's Address t 4 b r I Write "Return Receipt Requested" on the mellplece below the article number. • The Return Recelpt will show tp whom the article was delivered and the d t gyp/ 2' IR Reatrlcted Delivery C r $ delivered. 3. Article Addressed to: a e 4 A Consult Orttmaster for fee. R b r ;$ / 1hLjn r rticle Number So? C> ; B c. :7 ? « O 6f I'?"?'? t S+ e 46. Service Type ? 9eglaterad _, o Insured ` , • m W al ^ / •M1A^ , 1 A r 1 i I I PA W .ruffled- . `.?] COD E] R E e ,? I 0 44 , zpr ea M I O eturn Receipt for h n i M 9 f l , 1-70 1 1 glEg s 7.,, Date of Oe Very O. j E ,. t 6. i nature (Addressee) 1 A ) B. Addre. see's Address (Only if requested an fee is paid) ' ,r o ; . ? 8. Signs pent ? -.... PS Form 1 , De rather 1991 rY U.S.O. P. 0.: 1992.901.530 DOMESTIC RETURN RECEIPT ' a, m a Q O O m C) E 0 LL P 520 057 133 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. o,r -, ., n In, mt.+m:alnnal Mall ISee rerersa) o m ? r . Snoet R Wlmbnr I I S ? ?• SJIl ost O'hve Sn c t ZIP Goee i ^ l f 1 /, 1 Postagr. S Lnn.liCd •.•? 5 Speaal Dell:ery Fee _ I ? iloamC.nd Denuery Feu ?? Aelum Receipt showing to Mere 8 Dare Debvered Pehm RXopt sr y.vg tow" .]tP 5r ,,Vv 5 Ajule,s TOTAL Post 8 Fees S S PavmaM1: cr Darn t999 ..- j: I IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Joseph M. Knoble, Plaintiff V. Kathryn M. Knoble, Civil Action - Law F.R. 1999 - 4036 Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN : SS Barbara B. Townsend, Esquire, being duly sworn according to law, deposes and says that she served a copy of the Notice of Intention to Request Entry of Divorce Decree upon the Defendant by mailing the same to Kathryn M. Knoble at her last known address of 128 South 31st Street, Camp Hill, Pennsylvania 17011. by regular mail on August 2, 1999, from the United States Post Office in Chambersburg, Pennsylvania. ,iiar-bara B. Townsp d Sworn and subscribed to before me this fl,?ZLL9 day of / r:9, 19? '? n Notary Public Notarial Seal Renee D. Brenemen, Notary Public Chambersburg Boro, FranMln County My CamMeslon Expires June 9, 2003 :?, ?_: - _ _.. ' ?. _ _ ,,? L ?. ;'?, - - _ ?.