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Home My WebLink About07-3800i Kathy L. McKenzie Plaintiff v. Eric W. McKenzie Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.07- 3800 CIVIL TERM 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 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, 1 Courthouse Square, 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 i ~ Kathy L. McKenzie Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. Eric W. McKenzie Defendant N0.07- 38"06 CIVIL. TERM IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ~_~~~ ~ ~ `~ ' l~lPa'l i e ,who currently resides at ~-~o G r~eY, ~~1~ ~d. f'V~ w u, ll.~ P f 7~-~ ~ Cumberland County, Pennsylvania. 2. Defendant is ~ r LC, ~(1"t ~ E~YI Zt '~., who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on /~~ U~w1 ~~- ~-(~„(~ ~ at 5. The marriage is irretrievably broken, and the parties separated on O ~.-~-a b-er ~ oa ~P 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. ~ ~ ~ 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Pla ntiff, o Se I, ~~~~~--- -~~e-'~Z~e- ,verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. C~ - al - ~o~ Date: ~~~ Pl 'ntiff, Pr Se Assisted by: Marcus A. McKnig t, III, E uir Irwin & McKnight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 C -;~ ~ a --., ~ ~i ~t~~ } .~ -,:. ~ ~ N T~t ~ '~ ~ ~_:; Cf1 g C~tJ _t` / ~ ~ ' .4_ ~y R ~ f ~ ~ .. t `` ^^ W Kathy L. McKenzie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. N0.07- 3 ~(~a CIVIL TERM Eric W. McKenzie Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Kathy L. McKenzie, Plaintiff, to proceed in forma ap uperis. I, Marcus McKnight, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the P~Y• Date: June 25, 2007 Marcus~A. lvic mgn ,iii, ~sy. Attorney for Plat f Irwin & McKnight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 ~ cam, _ ~~ ~. ~r~' ~, ~ ~ ~ ~ r' ~ ~ ~ ,~~ ~ .i --o .z} ~ ~ N C1T ~ CrJ -C KATHY L. McKENZIE, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA ~, N0.2007-3800 CIVIL TERM ERIC W. McKENZIE, IN DIVORCE DEFENDANT ACCEPTANCE OF SERVICE I, ERIC W. McKENZIE, the defendant in the above-captioned divorce action, hereby verify that I have accepted service of the Complaint in Divorce filed under Sections 3301(c) and 3001(d) of the Divorce Code on or about June 27, 2007. ERIC W. cKENZIE Date: SEPTEMBER 24, 2007 C`:~ C` ra ~ -~_ .;; ~..i Y '"~'? :- . _ " : c- - ~ t1 1 ~ ~3{~.3 ~_ '~' E. ~ ~'1's '~:: j ~..,1 a,. ~~k ~ KATHY L. McKENZIE, PLAINTIFF v. ERIC W. McKENZIE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-3800 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 June 25, 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: SEPTEMBER 24, 2007 ERIC W. McKENZIE Defendant Ca ~' ~ ~ -~ ~ .~ N =.' ' ~-~ to =^~ ~: .~ __, ~- .. ~ ~ -,..z "c KATHY L. McKENZIE, PLAINTIFF v. ERIC W. McKENZIE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-3800 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: SEPTEMBER 24, 2007 ERIC W. McKENZIE Defendant ~+~+~ e+Y -~ ~' ~ ' ` ~....~ L..~ r- --r- ~r >_ ~3 . ~C <~ ~ ~~v N ~C - KATHY L. McKENZIE, PLAINTIFF v. ERIC W. McKENZIE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-3800 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. r ~ l Date: SEPTEMBER 24, 2007 ERIC W. McKENZIE Defendant ~ ~ _ :~_ ~a '"J -r1 _:. (~ i "~ ~ . ~7 tl ! ~' . . ., - ~ x~ ~ ; t~ ~ f t, -^~[ ~ wy~ KATHY L. McKENZIE, PLAINTIFF v. ERIC W. McKENZIE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-3800 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 25, 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. • SEPTEMBER 24 2007 ." Date. , KA HY L. cKENZIE Plaintiff ~ ' _,., _ ~'"` ~ ~~ ~~-' 4~ . .S'i C r -~: , ~ ~ ~ -- -~r~ ~ : - _ ` sy' rl \ t~ ~ ~ ~ ~.y~4 KATHY L. McKENZIE, PLAINTIFF v. ERIC W. McKENZIE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-3800 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE VEST 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. 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: SEPTEMBER 24, 2007 (~ < KATHY cKENZIE Plaintiff C"f Cr' ~ ~' ca -~. s.. - "., , t t - Lrz -~, . ' ~ r =`~( ~ ~~ 'e -~ -;. -~-^ `rz ~- ~ ~ ~ N ~ 1" J >? - C7Q -'G KATHY L. McKENZIE, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA ~, : N0.2007-3800 CIVIL TERM ERIC W. McKENZIE, IN DIVORCE DEFENDANT 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, Eric W. McKenzie, on or about September 27, 2007, by regular mail, addressed to him at 514 Park Drive, Boiling Springs, Pennsylvania, 17007. An Acceptance of Service has been filed on September 24, 2007. 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: September 24, 2007; by defendant: September 24, 2007. ~)(1) rox2) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: 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: ~) September 25, 2007. September 25, 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(c was filed with the Prothonotary: A. M ht, III, Esquire v for tiff Date: September 25, 2007 r•,a ~ W.~. . F .- ~~s~ ~,~, ~ ~ v..# ~J R ~ ~^ . I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ,~' . =~~ - KATHY L. McKENZIE, PLAINTIFF N O. N0. 2007-3800 CIVIL TERM VERSUS ERIC W. McKENZIE DEFENDANT DECREE IN DI~IORCE AND NOW, (1Lto~['~ ~ , ~~~, IT IS ORDERED AND DECREED THAT KATHY L. McKENZIE~ PLAINTIFF, AND ERIC W. McKENZIE ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHIGH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE. E A L°~s~ ~~ ~~°~s ~-