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Home My WebLink About07-3803w r Susan I. Strunk IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 3 S't 0.3 CIVIL TERM Randy L. Strunk, Jr. Defendant 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 V Susan I. Strunk Plaintiff V. Randy L. Strunk, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 31ra-3 CIVIL TERM IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ® ??TMK- , who currently resides at 2. Defendant is who currently resides at a I'j() 9D 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 Z2-003 at 5. The marriage is irretrievably broken, and the parties separated on 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. Cumberland County, Pennsylvania. i 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. x-21- of Date ?Umk tLwo Plaintiff, Pro Se I, _-:5t 1?n Arun L , 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. (D-ZI-U"} Date: 1tnn Plaintiff, Pro Se Assisted by: GJ Marcus A. McKni ht, II Irwin & McKnight Law ices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 ? oo 7N rr, ; _ •? Q Susan I. Strunk IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 3 'j-6 3 CIVIL TERM Randy L. Strunk, Jr. Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Susan I. Strunk Plaintiff, to proceed in forma au eris. 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 party. Marcts A. MckWa, III, Esq. Attorney for Plaintiff Irwin & McKnight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 June 25, 2007 ? o -! G1 7i 1 SUSAN L. STRUNK, Plaintiff V. RANDY L. STRUNK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3803 CIVIL TERM 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, Randy L.Strunk, Jr., on June 26, 2007, by certified, restricted delivery mail, addressed to him at 501 Windy Hill Road, Lot 23, Shermans Dale, Pennsylvania 17090, with Return Receipt Number 7004 1350 0003 7289 3464. 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 are true and correct. I understand that false statements herein made are subject to the penalties 18 Pa. C S. Section 4904, relating to unsworn falsification to authorities. .? MARCS A. McKl?T, III, ESQUIRE Attorn v for Plaintiff Date: Jjune 29, 2007 CEkTIFIFC (Domestic Mai! C ro cfl mi&S ? rU C? POMP $ m O CedMod Fee ° ° Return Re d W Fee qu euked) (Endorsemern R ° U1 m r-, Tote) P ° nt To ° MR RANDY L N 1tieZ ti ?5 a o° N UN% ar ornvpfz s? -lik o ? t tJ? ¦ 'tWVW learns 1, 2, OW a Also crorrrpiete item 4 N Restricted Delivery is desired. 4 Print your ne me and address on the reverse so that we can mW the card to you. ¦ Attach this card to the back of the medlpiece, or on the f nt N space permits. 1. ArWeAddreseedto: MR ROW L STRM JR 501 V3111DY HILL ROAD LO? 21 SAS DALE PA 17090 P6 ews X? (ftftd B by r? C. Date of Delivery D. is domy adtrses dune rtt Rom item 17? 0 yes H YES, eter n delivery eddma below. 3. servioe Type O-Om d Md ? Ettpnes Mali ? Repfatered F1 1 PAoelpt,br MerCtl X9W 4. PAft tee 2' Artlole Number i?44 1350 0003 7289 3464 (liaralbr' Avrn ? • PS Form 3611, February 2004 Doreedta Return Receipt 102595.OZ.44-1540 n ? ? ?„ 43 ?'_.r r1 ?? f? ? ? 1 ?}? 'is N ?-?tc._? -?-? °-c, i-" ?:? ? .: ? SUSAN L. STRUNK, Plaintiff V. RANDY L. STRUNK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3803 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: 67 &2& c - , 5?'- RANDY L. STRUNK, JR.. Defendant 0 CC-- C3 C:3, Z? -., n Kxz t 33 " yti ?._ T7 ?? T7 C.J t0 SUSAN Z. STRUNK, Plaintiff V. RANDY L. STRUNK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3803 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 June 25, 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 unworn falsification to authorities. Date: g-,24,-07 ? IC/ 'X _ SUSAN L. STRUNK Plaintiff 4 a 17;C :e rn at3 SUSANM. STRUNK, Plaintiff V. RANDY L. STRUNK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3803 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: 9 • G • Dy ?MAT Q ,( ? SUSAN L. STRUNK Plaintiff C`) r C] r t y SUSAN L. STRUNK, Plaintiff V. RANDY L. STRUNK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3803 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 2007. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 25, 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: 6:z Uk L ztiU4 X RANDY L. STRUNK, JR. Defendant 06 SUSAN L. STRUNK, Plaintiff V. RANDY L. STRUNK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3803 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 unworn falsification to authorities. Date: DEED _? $M::& c -'Sa *- RANDY L. STRUNK, JR. Defendant Q C rn C' ; 77 .4 C7 SUSAN L. STRUNK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA y, CIVIL ACTION - LAW NO. 2007 - 3803 CIVIL TERM RANDY L. STRUNK, JR., 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, Randy L. Strunk, JR., on or about June 26, 2007, by certified, restricted delivery mail, addressed to him at 501 Windy Hill Road, Lot 23, Shermans Dale, Pennsylvania, 17090, with Return Receipt Number 7004 1350 0003 7289 3464. 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 26, 2007; by defendant: September 26, 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) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: October 9, 2007. October 9, 2007. Date defendant's Waiver of Notice in Section 3301(c) jivorce was#ed with the Prothonotary: for (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: III, Date: October 9, 2007 -i l srr C ) f . ? Lf O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SUSAN I. STRUNK, PLAINTIFF NO. 2007-3803 CIVIL TERli VERSUS RANDY L. STRUNK. JR. DEFENDANT DECREE IN DIVORCE AND NOW, A t l q , _Z_007, IT IS ORDERED AND DECREED THAT SUSAN I. STRUNK , PLAINTIFF, AND RANDY L. STRUNK9 JR. , 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 THE CO •i OTA RY NONE. vw