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Home My WebLink About07-6792DEBRA L. KUHN, Plaintiff VS. HARRY E. KUHN, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE :-NO: 07 - 4-?9o''k CIVIL TERM 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 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. You must attend the scheduled conference or hearing. DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., ; Defendant : NO. 07 - CIVIL TERM DIVORCE COMPLAINT UNDER 23 Pa C S §§3301(c) AND 3301(d) OF THE DIVORCE CODE The plaintiff, Debra Kuhn, by her attorney, the Family Law Clinic, sets forth the following cause of action in divorce: 1 2 3 4, 5. 6. 7. 8. Plaintiff is Debra L. Kuhn, who currently resides at 12 Wilbert Drive, Carlisle, Cumberland County, Pennsylvania, 17013. Defendant is Harry E. Kuhn Jr., who currently resides at 632 North West Street, Carlisle, Cumberland County, Pennsylvania, 17013. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on October 4, 2004, in Harrisonburg, Rockingham County, Virginia. Plaintiff and Defendant have lived separate and apart since June 27, 2007. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Date ? ? 0 Respectfully submitted, EIt,??.u?Fi-P Katherine k Certified Legal Intern 84kz-?"7 tLUCY STON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date 1 ELW v Debra L. Kuhn, Plaintiff Tj f?= [tl z F T? ?? t DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., : Defendant : NO. 07 - &Wok, CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Debra L. Kuhn, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date - ' ? 4 i&- Pxt? -T/o7 Katherine Fitz-Patri Certified Legal Intern ?" &'M 1z'j'e:n' -- LUC JOHNSTON-WA SH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C:` ..?? ? ?? ? ca -r-i __ ? - - c:::? ..:: ?:?? ; r= ? - i?r ? ? , ' - _ _' r, _ --? ? , _,.., . y c' ` - .. ., : ri __.? .. -i -^C DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 - 6792 CIVIL TERM CERTIFICATE OF SERVICE I, Katherine Fitz-Patrick, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Harry E. Kuhn, Jr., residing at 632 North West Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Harry E. Kuhn, Jr., on the 8th day of November, 2007 as evidenced by the attached green card. Katherine Fitz-Pafric Certified Legal Intern 4{ki ok4_?? - ag Lucy Aryffon-Walsh Anne MacDonald-Fox, Esq. Megan Riesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 3639 ¦ Com 14Restricted Items 1, 2, and 3. Also complete item Delivery is desired. Print r name and address on the reverse so tha can return the card to you. ¦ Attacis card to the back of the mailpiece, or on the front It space permits. 1. Article Addressed to: ?Gtrr? f j u.-h? G 3a A/. 4&es74 L5;4. Oo,11,51e A. Signature X ? Agent ? Addressee B. R by (Prf, ) C. Da of i 134 D. Is Ivory address different from Rem 1? If YES, enter delivery address below: ? No 3. Service Type MCertifled Mall ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) JKYes 12. '7005 0390 01103 2632 6031 t`? r`'r-? d rn f`V DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 - b CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on November 7, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce and waive 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 unworn falsification to authorities. I? DatZ De ra L. Kuhn, Plaintiff L"> rv C_ `? _ ? _ f-??; ? ???.., ? ... _.. ? ? -? { T.? -T ? - - - ,?. -. ? -. t "?. - C , ? ?? j °C ?., ?+a? ?C1 .._.. ? DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 - 649,1 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 0301(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. §4904 relating to unsworn falsification to authorities. Date kkk ebra L. Kuhn, Plaintiff d ? C; ? cp ; --?i ? ? ? ? ?`?" ??1 i '._ t-n ? rs?s-^-- ..CS i'r? -u ? r ? ,..- .. ,z A t -'' C ? ?^??•J ?? ..? ^... DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 - ( j92 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on November 7, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce and waive 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 Z- 410T ???-- Harry . uhn, Jr., Defe ant ?? ? ? ? ? ?`,1 [?.? .f r _- ? ^"„? ? ? . 1 ? fk ?? ? ?? _r k. = , ... +54. r i R? , .? ?? ?r +r. -?' `S: DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 - ( 4% CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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. §4904 relating to unsworn falsification to authorities. Date 2z?z`G $ / Gz_ -I H . Kuhn, Jr., Defers ant CJ ^' `rl x r -? rTt m -n DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 (o412 CIVIL TERM CERTIFICATE OF SERVICE I, Todd Klein, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of both the Plaintiff's and Defendant's Affidavit of Consent and Waiver of Notice on Paul Bradford Orr, Esquire, at his place of business located at 50 East High Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, first class, on February 11, 2007. &-- Todd Klein Certified LeWntern Lucy Jo on-Walsh, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C3 ? r?. DEBRA L. KUHN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE HARRY E. KUHN, JR., Defendant : NO. 07 CIVIL TERM 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. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Harry E. Kuhn, Jr. on November 8, 2007. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff- February 7, 2008; by defendant- February 7, 2008. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: February 11, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary: February 11, 2008. a l i boo-, ?iL Date Todd Klein Certified Legal- hithern j? ( 13 Lucy o s on-Walsh, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff C) rv Ji, d ? IN THE COURT OF COMMON PLEAS DEBRA L. KUHN, OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS HARRY E. KUHN, JR., Defendant No. h7g2 2007 DECREE IN DIVORCE AND NOW, ( t' YJtyls 1 2-1 2-602, IT IS ORDERED AND DECREED THAT DEBRA L. KUHN , PLAINTIFF, AND HARRY E. KUHN, 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; NONE BY THE COURT: is /a io/. / ATT T: J. . -11? PROTHONOTARY loe ".-cc .r :,? .40L- -'r