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Home My WebLink About03-5070Klm E. Varner Plaintiff VS. Pamela E. Varner Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA : 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 in divorce or annulment may be 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 the custody or visitation rights 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 at the Cumberland County Courthouse, 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 2 Liberty Avenue Carlisle, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Klm E. Yarner, Plaintiff VS. Pamela E. Vamer, Defendant :No. Civil Action - Law In Divorce COMPLAINT UNDER SECT[ON 3301 OF THE DIVORCE CODE Plaintiff is Klm E. Yarner who currently resides at 303 North Fayette Street, Apartment 2, Shippensburg, Cumberland County, Pennsylvania, since March 4, 2002. 2. Defendant is Pamela E. Varner who currently resides at 33 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania, since August 15, 2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on lune 21, 1975 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 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 of divorce. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 ! verify that the statements made in this Complaint are true and correct, understand that false statements herein are made subject to the penalties of Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: _ Kim E. Yarner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Klm E. Varner, : No. 03-5070 Civil Term Plaintiff : : Civil Action - Law VS. : In Divorce Pamela E. Vamer, : Defendant : AFFIDAVI'r OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Pamela E. Varner, of 33 Thompson Creek Drive, Shippensburg, Pennsylvania, 17257, certified mail, return receipt requested on September 29, 2003 and was accepted on delivery by Pamela E. Varner on October 3, 2003 as shown by the attached receipt. 'H. Anthony--s, Esq-~re-'""'~ Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this ~ day of October 2003. Notary Public · My Commission Expir( · NOTARIAL SEAL I DEBORAH WARREN, Notary Public I Shippensburg, Cumbarland County ~ My Commission Expires Nov. 8, 2005] Complete Items 1, 2, and 3. Aisc complete item 4 if Restflcted Delivery is desired, Print your name and address on the reverse so that we can return the card to you, Attach this card to the back of the mailpiace, or on the front if space permits, 1. Ar[icle Addressed to: Article Number ? rJ i-] 1 ~ 5 ]/rJ fTtansfer from setvtce ~ [] Express Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) 000t 6143 ~25~ for Merchandise PS Form 3811, August 2001 Domestic Return Receipt 102§91-02-M-1540 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kim E. Yarner, : No.03-5070 Plaintiff : : Civil Action - Law VS, : : In Divorce Pamela E. Varner, : Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 24, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce alter 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. Section 4904 relating to unsworn falsification to authorities. Klm E, Varner IN THE COURT OF COMMON PLEAS O1= CUMBERLAND COUNTY - PENNSYLVANIA Klm E. Varner, Plaintiff VS, Pamela E. Varner, Defendant : No.03-5070 : Civil Action - Law : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY Ol= 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 are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Kim E. Varner Klm E, Varner, Plaintiff VS. Pamela E. Varner, Defendant [N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANZA : No.03-5070 : Civil Action - Law : : In Divorce : .. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301((:) of the Divorce Code was filed on September 24, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of flli~ng of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce al~er 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. Section 4904 relating to unsworn falsification to authorities. Pamela E. Varner Klm E. Varner, Plaintiff VS· Pamela E. Yarner, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA No.03-5070 Civil Action - Law In Divorce WA]VER OF NOT/CE OF INTENT/ON TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECT/ON 3301(c) OF THE DTVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that ! 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. ! 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. understand that false statements herein are made subject to the penalties of Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:_ G/c~/~ ~/ ~ Pamela E. Vamer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kim E. Varner, : No. 03-5070 Plaintiff : : Civil Action - Law VS, : : Tn Divorce Pamela E. Yarner, : Defendant : PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the followincl information, to the court for entry of a divorce decree; ' 1. Ground for divorce; irretrievable breakdown under 3301(d)(1) of the Divorce Code. Date and manner of service of the complaint:: Service was made by Certified Mail Return Receipt Requested on September 29, 2003 and was accepted on October 3, 2003. An affidavit of service was filed. Date of execution of the Affidavit of Consent required by Section 3301(d) of the Divorce Code; by the Plaintiff, January 19, 2004. Defendant on June 9, 2004. 4. Related claims pending: None. Plaintiff's Waiver of Notice was signed on .lanuary 21, 2004 and was filed on January 26, 2004 and Defendant's Waiver of Notice was signed on .lune 9, 2004 and is filed herewith. Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Klm E. Varner : No. 03-5070 Plaintiff : : Civil Action - Law VS. : : Tn Divorce Pamela E. Vamer : Defendant : PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 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) of the Divorce Code. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on October 3, 21:)03. An Affidavit Of Service was filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff January 19, 2004; by Defendant / 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice was signed on January 19, 2004 and was filed nuary ~26, 2004 and Defendant's Waiver of Notice was signed U~ u/.,-~-z~¢and was filed C)u~J¢ H. Anthony A~ams~'~squT~ Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Kim E. Varner VERSUS Pamela E. Varner IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ~,~,~ ~, PENNA. N o. 03-5070 DECREE IN DIVORCE AND NOW, DECREED THAT ,~m , 2004 , IT IS ORDERED AND , PLAINTIFF, AND PammJm E. Vmrnor ,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; None BY THE COURT: