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Home My WebLink About07-2982KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 0~-9 ~~, 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 in 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. KRI5TI M. MURTORFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW • 2007 - o~-g~~-' CIVIL TERM JEREMY S. MURTORFF, . Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 33_ Ol(C) AND ~D OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Kristi M. Murtorff, by and through her attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Jeremy S. Murtorff, representing as follows: 1. The Plaintiff is Kristi M. Murtorff, an adult individual residing at 600-G North Baltimore Avenue, Mount Holly Springs, Pennsylvania 17065. 2. The Defendant is Jeremy S. Murtorff, an adult individual currently residing at 215 West Pine Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on May 24, 2005 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, Dated: May 17, 2007 IRWIN & McKNIGHT By: A. 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Knight, III, Esquire I.D. No. 25476 'rofessional Building VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. t KRI5TI M. MURTORFF Date: May 17, 2007 ~ W ~ v3 ~ ~ `~ ~ (` `/` ~ ' ~ c ~ a ~ s ~ -•~ ra ~... ~w-~ - ~, .: -n - ~_ _r~~~ ,:~, Y_.. t_... {~ - - .. :-~1 ~~I 2 _-; -- c-~ ~: ~,.; -~ KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - ~-G1~~- CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: May 17, 2007 KRISTI M. MURTORFF .. , .. ?'j~ i~ ,~. ~a s KRISTI M. MURTORFF, : IN THE COURT OF COMMON PLEA5 OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM JEREMY S. MURTORFF, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO.1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA . SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Jeremy S. Murtorff, on or about May 21, 2007, by certified, restricted delivery mail, addressed to him at 215 West Pine Street, Mount Holly Springs, Pennsylvania 17065, with Return Receipt Number 4 1350 0003 7289 3587. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit ar rue and orrect. I understand that false statements herein made are subject to the penalties 8 Pa. .Section 4904, relating to unsworn falsification to authorities. /~ ,~~ MARCi~S A. McKN?GHT, III, ESQUIRE Attorney for Plaintiff Date: May 23, 2007 { 1 _. CERTIFlE[ (Domestic Mail G v' N ~ Postage $ m ~ Certified Fee n ~ ~ Pu (EhdoreemeM R eg ired) ~ m ReaUlCted Delivery F (F~doraemeM Recur '~ Total Postage & Fees S O wentTo ^ contpisbs items 1, 2, and 3. Also compote Item 4 ii Restricted Delivery o decked. ^ Print yot~ Warne and atidrees on the rt~trerse ao that vve can return the card to you. ^ Attsch tho card to the back of the r-tailplece, ar on the trcrtt if space permits. 1. Artk;ls Addressed to: JEY~lY S Ii~TOBFF ?.15 itBST PIIi18 STYS$T iT HOLLY SPBIUGS PA 17065 ., •.~++.~.n ~r ''S > °~ ,°~ UNIT ~~~5 mN, ~ `~'y v~~ ~ { 5 ~ aD ere A // '' ~y ors ~ 'l~ `"l D ODOy~ Oz m~ i -------•-o a ®-o -...--- ~ ,oo~ A ^ Apsnt a. mad by (Pilne.a nlmns}° I a Date a Delivery D. o delvery address dM-ererd fiorn 16em 1? O Y~ N YE3, srtber delivery address below: O No 3. Service lyps g ~ O l3gxees AAeN ~~~ 2•'~0 7004 1350 0003 7289 3587 -- maraAer>iom serv/cs -eball PS Form 3811,, February, ~t«Ne !fin waoelpt ~,. ,, -M-,s~to C'-~ N -- c~ __.,i -tl .. ---1 { ~ ~ ~ A "s~ ___ -/ ~ V 1 O "~ KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 2007. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 18, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: AUGUST 17, 2007 STI M. MURTORFF Plaintiff ~~ ~~ .._ ~-~:. C? N ~.-~ a -rt _. j'. _ ~~ i_l ~t: { [. '~;,' ' ~ /~! KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: AUGUST 17. 2007 KRISTI M. MURTORFF Plaintiff `~ r-a ~~ ~~ C~ c.a s ... a1 .. ~ ~~ ;~,~ '~ -', { ' j -mss ~.. .~} .1'si w. KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 18, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: AUGUST 17 , 2007 MY S. MURTORFF Defendant ~ r~~ t~ ~, ~ r,,~ -~ ~; ~ C~ '} `i" t'~ } -i: ,r, -. ~r t~ -= >~ r+7 P',,? '- KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Ai1GiiST ~ ~ _ ~n07 J . MURTO Defendant c~? c__ ~ -r~ '~ T ~',q ~ ~ ~ ~~ G 1 _ t'r1 ~ r -a t,.~ ;r " :- c, " . _ C~} <~` ~ '~ N: . KRISTI M. MURTORFF, Plaintiff v. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: AUGUST 17 , 2007 S. MURT RFF Defendant C. c ~ `r7 °'{ ~_y Wit"'" °t7 f'~? C~ '") '_ ~~{ ; .~ _._? ~~ ~ -~ --' t ' .. r,a rn i " ` .~ N KRISTI M. MURTORFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW 2007 - 2982 CIVIL TERM JEREMY S. MURTORFF, Defendant IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Jeremy S. Murtorff, on or about May 21, 2007, by certified, restricted delivery mail, addressed to him at 215 West Pine Street, Mount Holly Springs, Pennsylvania, 17065 with Return Receipt Number 7004 13500003 7289 3587. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by plaintiff: August 17, 2007; by defendant: August 17, 2007. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) of which is attached: (b) August 20, 2007. August 20, 2007. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in Section 3301(cyDivorce was filed with the Prothonotary: Attorney for III, Esquire Date: August 20, 2007 C~ ~ ~~ t-- ~ -sa _r. ;-; .,a cve a` rt~tr~--- c . ~- ~ 4 ~...` ...k `i. C S'1 ,, t_., h.? +~ L" ~ --4 ~ G - I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~.- ~s1z x. >ist~rro~, Pi.~T11'1''i~ VERSUS JS~Q S. ~1~O~FFs N o . s~-2982 cmL ~ DECREE IN DIVORCE AND NOW, ~~taa~S~ !.~ U~~ , IT IS ORDERED AND DECREED THAT HBISTI ~• ~TOBFF ,PLAINTIFF, AND JB8ffi!Y S . )1!lQSTOYFF ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF REGORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The Marcia a Settlement A reement dated Jul 27 2007 and si ned b the parties is hereby incorporated into this Divorce Decree, but not merged. BY THE COURT: ATTEST: J' PROTHONOTARY ,5. ~~~ ~ ~-~ ~o . ,~.~-