Loading...
HomeMy WebLinkAbout07-3333Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07- 333-3 CIVIL Defendant 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 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 Cumberland County Court House, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 (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. 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. Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07- 3333 CIVIL Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Chris Ann King, an adult individual, who resides at 10 Carter Place, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is David Thomas King, an adult individual, who resides at an unknown address, and is believed to be residing out of the United States. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on April 23, 1997 in Winchester, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken, and the parties separated on April 2004. 7. Plaintiff has been advised that counseling is available, 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: e -T Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. CIVIL Defendant IN DIVORCE 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. Date: ? kris Ann King, Plai iff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. CIVIL Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, Chris Ann King, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: David Thomas King Unknown Date: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Court Id. No. 81924 Attorney for Plaintiff n rv ' ?? ]? lti ?1 ?: _ ;-' p 1 G? ?r?} T' _ ' ,. ? t_.? t ?, ? ? ? ?? ?: ? o .,? Ca n Chris Ann King, Plaintiff V. David Thomas King, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-3333 CIVIL 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 May 6, 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: 2&L-- &,?? Chris Ann King, Plaintiff rv lr= r_ - ? C.7r , r> _ d r`rl r c Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07-3333 CIVIL Defendant IN DIVORCE Petition for Service of Divorce By Publication AND NOW, comes Chris Ann King, by and through privately retained counsel Karl E. Rominger, Esquire, and requests that this Honorable Court allow her to serve an Intent to Request a Divorce by Publication and in support there of avers as follows: 1. The complaint in Divorce was filed on June 5, 2007. (attached as Exhibit "A") 2. Defendant was born in Canada and is believed to be residing in Canada since his separation from Plaintiff on or about May 6, 1999. 3. Defendant's last known address was when he was residing with Plaintiff before the separation. 4. Defendant was last known to be homeless in the Calgary area. 5. Defendant has not been heard from recently and is Plaintiff has not been able to locate him. 6. There are no property issues in the divorce. 7. Plaintiff would propose publishing legal notice in Calgary Sun Official newspaper and the Patriot News in Harrisburg. 8. Plaintiff would now ask that this Honorable Court to consider that such service be adequate for purpose of allowing the Divorce to move forward. 9. Plaintiff would then ask that this Honorable Court consider that such service be adequate for purpose of entering a divorce. WHEREFORE, Plaintiff requests that this Court allow service by publication as requested above. Respectfully Submitted, ROMINGER & ASSOCIATES n ?- Date: Z CJ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07-3333 CIVIL Defendant IN DIVORCE VERIFICATION KARL E. ROMINGER, ESQUIRE, states that he is attorney for, Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C. S. Pa. C.S.§4904, relating to unsworn falsification to authorities. Dated: 4L J Z !- ZUG ? ? Karl E. Rominger, Esquire Attorney for Plaintiff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA N • c o CIVIL ACTION - LAW i David Thomas King, N. No. 07-3933 CIVIL Defendant IN DIVORCE NOTICE cn 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 Cumberland County Court House, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 (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 2?rt e j? to it iness ?bCfnre then. the Court. All arrangements must be made at least 72 hours prior to You must attend the scheduled conference or hearing. ; .qbvww WMmot,1 i V Irl Unto Set MY har,` tt* of if law n at Cu**, Pa• 7 d" of 14 Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. D 7- 33 39 CIVIL Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Chris Ann King, an adult individual, who resides at 10 Carter Place, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is David Thomas King, an adult individual, who resides at an unknown address, and is believed to be residing out of the United States. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on April 23, 1997 in Winchester, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken, and the parties separated on April 2004. 7. Plaintiff has been advised that counseling is available, 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: - '' Respectfully submitted, ROMINGER & ASSOCIATES .lam, Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. CIVIL Defendant IN DIVORCE 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. Date: Chris Ann King, Plain Jiff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. CIVIL Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, Chris Ann King, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: David Thomas King Unknown Date: - v; r v Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Court Id. No. 81924 Attorney for Plaintiff N CHRIS ANN KING, Plaintiff V. DAVID THOMAS KING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3333 ORDER OF COURT AND NOW, this 30th day of August, 2007, upon consideration of Plaintiff's Petition for Service of Divorce by Publication, the petition is granted pursuant to Pennsylvania Rule of Civil Procedure 1930.4(a)(3), and Plaintiff is authorized to effectuate service of the divorce complaint by publication one time in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County, as well as the Calgary Sun. BY THE COURT, Karl E. Rominger, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff 4- :rc Ll V, f. 8 0 :9 " Y'' z - ?i.:a LC Z Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07-3333 CIVIL, Defendant IN DIVORCE MOTION TO FINALIZE DIVORCE NOW COMES, Chris Ann King, by and through her counsel, Karl E. Rominger, Esquire, and asks this Court enter a Divorce in the above captioned matter and in support of her Petition avers as follows: 1. Petitioner filed for a Complaint in Divorce on June 5, 2007. 2. Your Petitioner obtained permission in front of the Court to serve Notice of said divorce by publication (attached hereto as Exhibit "A") 3. Said publication has been completed and Notice of the Divorce was published in the Cumberland Law Journal in Carlisle, Pennsylvania, on August 30, 2007, (attached hereto as Exhibit "B") The Sentinel in Carlisle, Pennsylvania on September 21, 2007, (attached hereto as Exhibit "C") and the Calgary Sun in Calgary, Canada on September 26, 2008, (attached hereto as Exhibit "D"). 4. No response was received from Defendant or Defendant's counsel by Plaintiff or Plaintiff's counsel. 5. More than two years have lapsed since Plaintiff and Defendant have separated. 6. Defendant has failed to raise any issues as to property, alimony or the like, and Plaintiff is seeking no relief in the form of equitable distribution, alimony of the like. WHEREFORE, Plaintiff respectfully asks that this Court enter a Decree in Divorce in this matter. Respectfully submitted, Rominger & Associates l Date: December 23, 2008 K E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Plaintiff Chris Ann King, Plaintiff V. David Thomas King, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-3333 IN DIVORCE CIVIL VERIFICATION Karl E. Rominger, Esquire, states that he is the attorney for Chris Ann King, Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date?-?P-ft hp Karl . Rominger, Esquire Attorney for Plaintiff Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07-3333 CIVIL Defendant IN DIVORCE CERTIFICATE OF NON-SERVICE I, Karl E. Rominger, Esquire, certify that I this day was unable to serve the Defendant a copy of the attached Motion to Finalize Divorce in the above referenced matter as his addresses is unknown and Defendant was last known to be homeless in Canada. Date: December 23, 2008 Respectfully submitted, Rominger & Associates Kar . Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Plaintiff r lJ/ / l.. `JY CHRIS ANN KING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAVID THOMAS KING, : Defendant NO. 07-3333 ORDER OF COURT AND NOW, this 30`x' day of August, 2007, upon consideration of Plaintiff's Petition for Service of Divorce by Publication, the petition is granted pursuant to Pennsylvania Rule of Civil Procedure 1930.4(a)(3), and Plaintiff is authorized to effectuate service of the divorce complaint by publication one time in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County, as well as the Calgary Sun. BY THE COURT, Karl E. Rominger, Esq. /155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff :rc 'r RUE Y FkoM RECOfft T " , I hfsa I 0W# c A go s of ski cv] at Cries pit, PLAINTIFF'S ? - EXHIBIT w a Pit" a d PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz September 21, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. -11 Lis Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this 21 day of September, 2007 Notary NOTARIAL SEAL DEBORAH A COLUNS PLAINTIFF'S Notary Public a CARLISLE BORO, CUMBERLAND COUNTY j EXHIBIT MY CommisWw Expires Apr 211, 2010 a a W r. CUMBERLAND LAW JOURNAL NOTICE IN DIVORCE Court of Common Pleas, Cumberland County, Pennsylvania Civil Action-Law Docket Number: 2007-3333 Chris Ann King, Plaintiff vs. David Thomas King, Defendant NOTICE You have been sued in court. If you wish to defend against the claim 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 visition of your children. When the ground for the divorce is indignities or irretriev- able breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotarv at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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, PA 17013 Phone (717) 249-3166 and/or (800) 990-9108 Sept. 21 Y CJY PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) September 19, 2007 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this I` 19th. day of September, 2007. 1 , Notary P c My commission expires: ?l//v r COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Chnsft L. Woth3, Notary Pudic Cadisle em, Cwftdarid County My Commission Expires Sept 1, 2008 Member, Pennsylvania Association Of Notaries a PLAINTIFF'S W EXHIBIT {{J-- !!) P _ f 'hF"a b ?' i it}}ti Y g pI ? 7r Wm ? EXHr81T S p r' r on'? L"°r } ?.? ?::r °=T3 ? _.{ '? Yl " k""7 ' ' f ' __, f"t1 ?3 ; C..' C.A> ; °.. ?tt;t .?» t`T`1 ;^?„? ?? G -- CHRIS ANN KING, Plaintiff V. DAVID THOMAS KING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3333 IN RE: PLAINTIFF'S MOTION TO FINALIZE DIVORCE AND NOW, this go' day of January, 2009, upon consideration of Plaintiffs Motion To Finalize Divorce, and it appearing that Plaintiff has not served Defendant with Plaintiffs affidavit or with a notice of intent, the motion is denied, without prejudice to Plaintiffs right to serve Defendant with the said affidavit and, subsequent thereto, with the notice of intent, and thereafter to file a praecipe to transmit record and proposed divorce decree. PLAINTIFF'S AFFIDAVIT and, subsequent thereto, the notice of intent may be served upon Defendant by publication once in a newspaper of general circulation in Cumberland County. V Karl E. Rominger, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff :rc copy m?,&Cc. J BY THE COURT, 61 of 40 Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07-3333 Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: David Thomas King, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or after February 19, 2009, the plaintiff 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. 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. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 1-800-692-7375 (PA only) or 1-717-238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin 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. .v 'r C Chris Ann King, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW David Thomas King, No. 07-3333 CIVIL Defendant IN DIVORCE PRAECME TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Order on Petition for Service of Divorce by Publication granted on August 30, 2007, (attached as Exhibit "A"), proof of Publication with the Cumberland Law Journal dated September 21, 2007, (attached as Exhibit "B"), proof of Publication with The Sentinel dated September 19, 2007, (attached as Exhibit "C"), and proof of Publication with the Calgary Sun dated September 26, 2008, (attached as Exhibit "D"). 3. Related claims pending: None. 4. (1) Date of execution of the Plaintiffis Affidavit required by §3301 (d) of the Divorce Code: May 31, 2007; (2) Date of filing and service of the Plaintiff' Affidavit upon the Respondent: Filed June 5, 2007, Order on Plaintiffis Motion to Finalize Divorce dated January 8, 2009, (attached hereto as Exhibit "E"), Proof of Publication with the Sentinel dated January 30, 2009, (attached as Exhibit "F"). 5. Date and manner of service of the Waiver of Notice to file praecipe to transmit record, a copy of which is attached: Order on Plaintiffs Motion to Finalize Divorce dated January 8, 2009, (attached hereto as Exhibit "E"), Proof of Publication with the Sentinel dated February 25, 2009, (attached as Exhibit "G") Respectfully Submitted, Romin er & Associates Date: March 5, 2009 1 E. Rominger, Esquire 155 Hanover Street Carlisle, Pennsylvania 17013 Supreme Court ID # 81924 (717) 241-6070 Attorney for Plaintiff CHRIS ANN KING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAVID THOMAS KING, : Defendant NO. 07-3333 ORDER OF COURT AND NOW, this 30`x' day of August, 2007, upon consideration of Plaintiff's Petition for Service of Divorce by Publication, the petition is granted pursuant to Pennsylvania Rule of Civil Procedure 1930.4(a)(3), and Plaintiff is authorized to effectuate service of the divorce complaint by publication one time in the Cumberland County Law Journal and in a newspaper of general circulation in Cumberland County, as well as the Calgary Sun. BY THE COURT, Karl E. Rominger, Esq. % 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff :rc PLAINTIFF'S EXHIBIT TRUE COPY F T mo WWW' I e Wil Maw. A tm cow of aid !CCU at t:KW Pt -1 C' ..Aw ?If7i?w Ja2- .r J ' c4-q/4'e( PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz September 21, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of g6neral circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lis Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this 21 day of September, 2007 Notary / NOTMK SEAL DEBORAH A COLLINS PLAINTIFFS No.C B EXHIBIT CARLISLE $ORO, CUMUBERtRLANp COUNTY MY CORWrblion Expket Apr 2$,1010 CUMBERLAND LAW JOURNAL NOTICE IN DIVORCE Cumberland County Bar Association Court of Common Pleas, 32 South Bedford Street Cumberland County, Pennsylvania Carlisle, PA 17013 Civil Action-Law Phone(717)249-3166 and/or Docket Number: 2007-3333 (800) 990-9108 Chris Ann King, Plaintiff VS. David Thomas King, Defendant NOTICE You have been sued in court. If you wish to defend against the claim 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 visition of your children. When the ground for the divorce is indignities or irretriev- able breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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. Sept. 21 c?_ ct PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising ?Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) September 19, 2007 COPY OF NOTICE OF PUBLICATION NOTICE Kingi PlaietiB versus David Thomas King; Defendant in the'Court of n Pleas of CumEerlegd County, Pennsylvania; civil action law, docket 2007,-3333 iri divorce Not.. You have been sued in court. It you wish to against the t4aimset ?o0fi 7n-1he foIIovvfng pages, you must take prompt ou are wamef(lhai if;you 1 , to do so, the:case may proceedwithout.you acres of divWCepr ant]Irtientmay be entered againstyou bythe court. A ant may also be entered against you fog any.other claim or relief requested PaPers by ing-P,iamtlftkYgu may lose money or property or other "ghts it,to you !? q9 ?ustody9r y"' Lion of your children WAen3tts rotind nrorge-isindignttitls orlrretrl?vapie bTo kc?gtrrn of the marriage; you may r rday¢ co r geflng. A list of rtlart)d4e r Oypselors Is available in the Office Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. LOSE THE RIGHT TOCLAIM•ANYOF s :R TO YOUR LAWYER AT ONCE.IF:YOU HELP. __- timberland County Bar Association, 32 South Bedford Street, Carlisle, Pennsylvania 17013, phone (717) 249-3188 and or (800) 9909108. Sworn to and subscribed before me this 19th. day of September, 2007. Notary P c My commission expires: p///tom COMMONWEALTH OF PENNSYLVANIA NohVW Seal Chnsina L. Wdle. Notary Pubic Carlisle Bozo, Cwftrlend County My CAmrtubeion Eow Sept 1.2008 Member. Pennsylvania Association Of Notaries E7 181T 44 ? } Y} r F,.y_ k? --ar?1T - T 4,:,< Y k P C CHRIS ANN KING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DAVID THOMAS KING, : Defendant NO. 07-3333 IN RE: PLAINTIFF'S MOTION TO FINALIZE DIVORCE AND NOW, this 8t" day of January, 2009, upon consideration of Plaintiff's Motion To Finalize Divorce, and it appearing that Plaintiff has not served Defendant with Plaintiff's affidavit or with a notice of intent, the motion is denied, without prejudice to Plaintiffs right to serve Defendant with the said affidavit and, subsequent thereto, with the notice of intent, and thereafter to file a praecipe to transmit record and proposed divorce decree. PLAINTIFF'S AFFIDAVIT and, subsequent thereto, the notice of intent may be served upon Defendant by publication once in a newspaper of general circulation in Cumberland County. BY THE COURT, ? ? L, - - i'o' J esley Ol Jr., J. K . Rominger, Esq. 55 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff :rc . .?:. copy Ro Ri twpu ..? to lewxr ? "- wI rd. I Mm Wft set aik PLAINTIFF'S ad ? sp" d salt! at ? , P& EXHIBIT this A-p\ Avy PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): Tanuary 30, 2009. COPY OF NOTICE OF PUBLICATION F PLAINTIFF'S EXHIBIT Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are e. C a, ?' ?? t? U Sworn to and subscribed before me this b. U-1 V V/ Notary Public My commission expires: NOTARM SEAL BONrK A CANUP Notary Pubic CARt.IlLE BOROUGH. CUMBERLMO COtM My CamffMw bq*" Jun S. 2009 ¦ PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): Februar3? 25, 2009 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL EBAMBI ANN HECKENCORN, Notary Public p Hill Boro., Cumberland County mmission Expires January 27, 2010 EXHIBIT -6- ctt '? OR - cr t Chris Ann King IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. David Thomas King No. 3333-07 DIVORCE DECREE AND NOW, M U ?? 13 , 16°9 , it is ordered and decreed that Chris Ann King , plaintiff, and David Thomas King , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order` for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") None. By the Court, P ??