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Home My WebLink About99-060060 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ? 5,ni 4 KAREN MARIE RUTKOWSKI, Plaintiff NO. 99 - 6006 CIVIL VERSUS TIMOTHY DAVID RUTKOWSKI, Defendant DECREE IN DIVORCE AND NOW, - A/dre...4Z /o,_ , 2ao( , IT IS ORDERED AND DECREED THAT KAREN MARIE RDTKONSKI _ , PLAINTIFF, AND TIMOTHY DAVID RUTKOWSKI _ DEFENDANT, 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 WI-IICH A FINAL ORDER HAS NOT YET BEEN ENTERED; IUIdE. BY 1 RT: ATrE'- 1 PROTHONOTARY KAREN MARIE RUTKOWSKI, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6006 CIVIL TERM TIMOTHY DAVID RUTKOWSKI, IN DIVORCE DEFENDANT PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d) (1) of the Divorce Code. 2. Date and manner of service of the complaint: On October 2, 1999 by U.S. Mail, Restricted deliver. 3. (a) (1) Date of execution of the affidavit required by section 3301(d) of the Divorce Code: September 27, 2001; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on October 1, 2001, served September 28, 2001. 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: U.S. Mail, postage prepaid, October 23, 2001. Thomas D. Gould Attorney for Plaintiff J G jc uJfl V v U 0<? i Lt l'`: P• _ n v? 1. ? V r, r; I :i v? M a 7 J (T CL 0 J 03? (D w 0 g a b w Q N Q U = Z r a 3 f F O ?n O 0 Z n J Q Q N W n c L R_ O N KAREN MARIE RUTKOWSKI, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v• NO. 99 - UDD? CIVIL TERM TIMOTHY DAVID RUTKOWSKI, IN DIVORCE DEFENDANT 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 299-3166 KAREN MARIE RUTKOWSKI, PLAINTIFF W. TIMOTHY DAVID RUTKOWSKI, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Karen Marie Rutkowski who resides at 140 S. Locust Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Timothy David Rutkowski who resides 7 Spruce Circle, Shiremanstown, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 11/14/97 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The 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. 9. Plaintiff requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION 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. qla?)IIC)gcl ?1tu??a I??.?tKo?u<-AA Date: Karen Marie Rutkowski KAREN MARIE RUTKOWSKI, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6006 CIVIL TERM TIMOTHY DAVID RUTKOWSKI, IN DIVORCE DEFENDANT AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on October 1, 1999, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on October 2, 1999. -Z) .P?6 Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 r ? N L U G7 - L a d _ O f I` i 0 v SENDER: I also wish to receive the follow m 0Complele Hama t andlor 2lor addaonal services. Ing services (for an extra fee): A Complele items 3.4a. and 4C. Y: a Print your name and aWross on the reverse of tM son to IMI we can return Irue m cam to you. I. p Addressee's Address 3 o O AaaCh INS With to the howl of the madpioce, o, on ma Cad It space does not perms. ZVlestricted Delivery r I 13Wrile 'ReWh Receipt Requesle0'on the malpeceCebwthe article numver. (? C O The Mum Receipt will show to whom the aNGe was ealrvoreC R and the dale r a. o delivered. pt t v 3. Article Addressed to: 4a. Article Number 1 R ?Q kxa4kt ? T / ? 3 .23/ 00tf Z E tO q mu F t I y 4b. Service Type m °u n ftic?t PCI E 7 S [I Registered NCedified P - \ I ?Express Mail ?Insured 55 p Q / A 1`7011 ??Af le,"am sTQ6?q 0 Return Receipt forMercwntlise ?COD N , 7. Date of Deli v 3 0 T J eived By:(Pdnt Name) 8.Addressee' Ad es ( n/y if requested and c l ++ t -f ,) r (.°. Luis paitl c i lure (A orAgenq i. ) T N PS Form 3 1, er 1 9 +02595 99 e or.3 Domestic Return Receipt f i 1. t 1 i KAREN MARIE RUTKOWSKI, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6006 CIVIL TERM TIMOTHY DAVID RUTKOWSKI, IN DIVORCE DEFENDANT CERTIFICATE OF SERVICE AND NOW, this J? day of October 2001, I, Thomas D. Gould, Esquire, Attorney for Plaintiff, Karen Marie Rutkowski, hereby certify that I have this day sent a copy of Plaintiff's Notice of Intention to Request Entry of Divorce Decree by depositing a copy of it in the United States mail, postage prepaid, addressed to: STANLEY J.A. LASKOWSKI, ESQUIRE 3631 NORTH FRONT STREET HARRISBURG, PA 17110 DATED /0/Ij/0 r -; 1r, ., a. .ar c Thomas D. Gould, Esquire ID 4 36508 2 East Main Street Shiremanstown, PA 17011 (717,) 731-1461 ti N 7 • -- n u U o _i U KAREN MARIE RUTKOWSKI, PLAINTIFF V. TIMOTHY DAVID RUTKOWSKI, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6006 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE rt AND NOW, this 21-L day of September 2001, I, Thomas D. Gould, Esquire, Attorney for Plaintiff, Karen Marie Rutkowski, hereby certify that I have this day sent a copy of Plaintiff's Notice To The Defendant by depositing a copy of it in the United States mail, postage prepaid, addressed to: STANLEY J.A. LASKOWSKI, ESQUIRE 3631 NORTH FRONT STREET HARRISBURG, PA 17110 DATED 9-RP%O/ Thomas D. Gould, Esquire ID N 36508 2 East Main Street Shiremanstown, PA 17011 (717) 7 31-14 61 J? (_ ... t . 1 (..'. i? /i.? Lr - ' ?. l :l KAREN MARIE RUTKOWSKI, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6006 CIVIL TERM TIMOTHY DAVID RUTKOWSKI, IN DIVORCE DEFENDANT 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 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 on Separated 19, 1999 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 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. 4904 relating to unsworn falsification to authorities. Date: q-a-1-a001 Karen M. Rutkowski KAREN MARIE RUTKOWSKI, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 99 - 6006 CIVIL TERM TIMOTHY DAVID RUTKOWSKI, IN DIVORCE DEFENDANT 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 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 on Separated 19, 1999 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 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. 4909 relating to unsworn falsification to authorities. Date: q"a1- a001 tC1Jl.lR? ? • rC.AA.AJC?l?A?.?.l Karen M. Rutkowski _: > - - _ - ,..; ,'- ?,:? s c-? U KAREN MARIE RUTKOWSKI, PLAINTIFF V. TIMOTHY DAVID RUTKOWSKI, DEFENDANT IN THE COURT OF COMMON PLEAS CUIMERLAND COUNTY, PENNSYLVANIA NO. 99 - 6006 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: TIMOTHY DAVID RUTKOWSKI: KAREN MARIE RUTKOWSKI intends to file with the court the attached Praecipe to Transmit Record on, or after November 15, 2001 requesting that a final decree in divorce be entered. -,Z) . 4,a Thomas D. Gould Attorney for Plaintiff c C% n' / -- ur = o A( ; L U o U ?!9 rls3 S??yt Y n ?. ?y KAREN MARIE RUTKOWSKI, PLAINTIFF V. TIMOTHY DAVID RUTKOWSKI, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6006 CIVIL TEAM IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN MARIE RUTKOWSKI, being duly sworn according to law, deposes and says that she is the Plaintiff in the above-captioned //-2/- 200/ divorce action in which a final decree-from the bonds of matrimony was entered and she hereby elects to resume her prior surname of KAREN MARIE CANNON and, therefore, gives this written notice avowing said intention, in accordance' with #704 of the Act of November 15, 1972, P.L. 1063, 54 PA.C.S. Section 704. Notsdal Seal Usa M. Gutshalt, Notary Public Lewtsberry Boro, York County My Commission Expires Oct. 13, 2003 Sworn and subscribed to before me this a4 day of t/i( b-ppA , 2001 VLn KAREN MARIE RUTKOWSKI To be known as KAREN MARIE CANNON T C ? ?" ?^ i'' i.._ i is _ r 7 _? U -ice ? p. ? 4 ?' ? - ? ;i ? '?. N TUJ ? 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