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Home My WebLink About07-3148 SALZMANN HUGHES, P.C. E. Ralph Godfrey, Esquire Attorney for Plaintiff Attorney LD. No. 77052 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Telephone: (717) 249-6333 Fax: (717)249-7334 E-mail: rgodfreyna,salzmannhughes.com AMBER LYNN JEAN POTTORFF, Plaintiff vs. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA ~~ N0.2007- 3/y~ KENNETH E. POTTORFF, Defendant 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 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, 1 Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (717)249-3166 r + AMBER LYNN JEAN POTTORFF, Plaintiff vs. KENNETH E. POTTORFF, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA N0.2007- -~ ~ ~~ ~-l ~t,~-- CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff, Amber Lynn Jean Pottorff, is an adult individual residing at 615 West Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. The Defendant, Kenneth E. Pottorff, is an adult individual currently residing at PO Box 204, Franklintown, York County, Pennsylvania, 17323. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on the September 30, 2006, in Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant are not in the military or naval forces of the United States. 6. There have been no prior actions of divorce between the parties in this or any other state. 7. No children have been born of the marriage. COUNT I DIVORCE PURSUANT TO §3301(c) & (d) OF THE DIVORCE CODE 8. Paragraphs one through seven are incorporated herein by reference as if set forth in full. 9. Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff has been advised of the availability of marital counseling and that either party has the right to request that the court require the parties to participate in counseling. 11. The parties have separate and apart since February 10, 2007. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 12. Paragraphs one through eleven are incorporated herein by reference as if.set forth in full. 13. The parties have acquired real and personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is martial property. WHEREFORE, Plaintiff requests the Honorable Court to enter a decree, which effects an equitable distribution of martial property. SALZMANN HUGHES, P.C. Date: S1i > ~~ ~ By: E. Ralph God ey, Esquire Attorney I.D. No. 77052 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 (717) 249-6333 Attorneys for Plaintiff VERIFICATION I, Amber Lynn Jean Pottorff, do hereby verify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my personal knowledge or information and belief. 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: ~~~~~ ( V'^~+ w \` ,~~\} ~f a~ R `^~t w V ~ (~ r ~ ~A f ^~ .- V t_~ r..~ - ~-~ ` c _. - -~ ~ - --~?' -mot i • -' ~-~ f ~~ t t `: i, __ • ~ .2 ~~ l i ~u _f.J - i...~.J "^.. SALZMANN HUGHES, P.C. E. Ralph Godfrey, Esquire Attorney for Plaintiff Attorney I.D. No. 77x52 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Telephone: (717) 249-6333 Fax: (717) 249-7334 E-mail• rgodfrey(~salzmannhughes com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, Plaintiff N0.2007-3148 vs. CIVIL ACTION -LAW KENNETH E. POTTORFF, IN DIVORCE Defendant PROOF OF SERVICE I, E. Ralph Godfrey, do hereby certify that on May 25, 2007, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon Kenneth E. Pottorff by personal service as evidenced by the executed Affidavit attached hereto. SALZMANN HUGHES, P.C. By i Z 5.r~ ~..- ph ey, uire J Attorney I.D. .77052 354 Alexander Spring Road Suite 1 Carlisle, PA 17013 Attorneys for Plaintiff SALZMANN HUGHES, P.C. E. Ralph Godfrey, Esquire Attorney for Plaintiff Attorney LD. No. 77052 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Telephone: (717) 249-6333 Fax: (717)249-7334 E-mail: rgodfrey~a salzmannhughes.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, Plaintiff vs. KENNETH E. POTTORFF, Defendant N0.2007-3148 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE I, ~U ~~~ Q `V ` • ~~~~~hereby certify that I served a copy of the Complaint in Divorce on Kenneth E. Pottorff on May 25, 2007. I further state that I am not a party to this action and am over the age of 18. 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 1$ Pa. C.S. § 4904 relating to unsworn falsification to authorities. t-, r- r,._. --r1 _ _., -~ '- , --r-r _,-~ - ; ~- ~ ~ ; ` ;. _ .,- - ,~ _ . ,.._ r ti :. --~t ~ c> N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, Plaintiff vs. . KENNETH E. POTTORFF, Defendant N0.2007-3148 CIVIL ACTION -LAW IN DNORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on May 23, 2007, and served on May 25, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint 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 unsworn falsification to authorities. Date: ber L Je ottorff c~ N 1II ; r"~s ftj --.{ ~ fTt 7~ `1~ !'i7 _ ~_ { ~ ._~ _a ~-% ~`C7 ~~ ~:_ ~~~~ 4 -y G,? ~. • • tJ't -.~ ~' t7J -~<' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, Plaintiff . vs. . KENNETH E. POTTORFF, . Defendant N0.2007-3148 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in divorce under §3301(d) of the Divorce Code was filed on May 23, 2007, and served on May 25, 2007. 2. The mamage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint 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 unsworn falsification to authorities. Date: ~' 3t ~o'j- ~ . erne E. Pottorff rv ~ ° C7 - ' -.~, n i_, ~° ' ~ ~;, ~ . .III ~-rr -- r ~- t X -. ~ 70, -'Ti ~ GJ C.~ !'ct "'` ~.f} ~ "4r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, Plaintiff N0.200~-3148 vs. CIVIL ACTION -LAW KENNETH E. POTTORFF, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DNORCE DECREE UNDER &3301(0) AND & 3301(D) 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 aze 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 /3 ~ / a '~ Amber L Po t'J ^^a ~. ::~ ~.,, ~ tr?~,; ~ _ "~ i"71 J` ~` r'~ .. _.~ ~.__,.~ - ~ ~ . .. ~ ~ ti ~ ~>_ . L. ~~ ~ ~~ e.. •' t o t i .f . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, : Plaintiff . vs. : KENNETH E. POTTORFF, Defendant . N0.2007-33148 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER &3301(C) AND ~ 3301(D) 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 s unsworn falsification to authoritie Date: ~' - 3/ -~ "]' t~ ~ O ~ ~ t.;.; to ~.. ~-r.i ~: ~r7 tz1 ~. '~ ~: ~~ ' ~ _ ~ ~'~ ~~"' t:~ W ' GJ ! lL? r ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER LYNN JEAN POTTORFF, . Plaintiff vs. . KENNETH E. POTTORFF, Defendant . N0.2007-3148 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c)(1) of the Divorce Code. 2. Date and manner of service of Complaint: Served upon Defendant: Personal services, on May 25, 2007. Affidavit of Service filed on May 25, 2007. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to Pa.R.C.P. 1920.42(e)(1): Plaintiff- 8/31/07 Defendant - 8/31/07 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of filing and service of Plaintiff's affidavit upon the respondent: N/A. r ,_ ~ 4. Complete the appropriate paragraphs: (a) Related claims pending: None. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: N/A (b) Date Plaintiff s Waiver of Notice was filed with the Prothonotary: 9/4/07 (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 9!4/07 SALZMANN HUGHES, P.C. ~ , `~ a ~j- Date E. ph od squire LD. No. 77052 354 Alexander Spring Road Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiff r N _. K,~ ~+ J .r ! l`~ _ ~ ~ ~E.rs __ --~y rte r=- i ~ 1 "'~' ~ ! :J C'} = -e.7 = ~ -r- - ~ c~ ~~ crt w I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. AMBER LYNN JEAN POT!)ORFF VERSUS I~HJETH E. POrIZ~ORF'F N o o~-3i~s DECREE IN DIVORCE AND NOW, ~ ;"~-~ IT IS ORDERED AND DECREED THAT AI'~ER LYNN JEAN POrI'PORFF PLAINTIFF, AND I~Il~'TH E. PC7I'PORFF ,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 WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY TH'~ SOU ST: J. PROTHbNOT .~'~ {. ~' ~a. ~i ~ b gyp. ~/ -~ ~.1` / a AMBER LYNN JEAN POTTORFF, Plaintiff vs. . IN THE COURT OF COMMON . PLEAS, CUMBERLAND COUNTY, . PENNSYLVANIA . N0.2007-3148 KENNETH E. POTTORFF, . CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a fmal Decree of Divorce on the 11~' day of September, 2007 hereby elects to retake and hereafter use her maiden name of Amber Lynn Jean Lynch, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa. C. S. A. §704. Signature of Petitioner To Be Known Signature-Elected Name Document #: 179023.1 .... ~ ~ ~1 COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND On the ~ day of t.~ , 2007, before me, a Notary Public, personally appeared Amber Lynn Jean Pottorff, to be known hereafter as Amber Lynn Jean Pottorff, known to me to be the person whose name is subscribed to the with document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Publ' COMMONWEALTH OF PENNSYLVANIA Nderpi Ssel ~~y L. Coy>a, No4Vy Public ScuQt Middebn Twp., Qrnberl~nd Cotrriy My Canxr~eeton Elites July 8, 2010 Member, PenneylvaMa Aesodation of Notaries Document #: 179013.1 t7 ~ c~ ' .p ~ a ~ ,~ 'zt c~-~ ~. trs ~ O `~ r_ -> OQ ~~ ~ ~ ~ ~ p ::~ '~U ~ ~ ~' ~ W ~ ~' ~ w ''~,,.~ ~ ~ ~ `o n