HomeMy WebLinkAbout03-5518BETH A. MILLER,
VS.
: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
No, p3 - j s 8 Civil Term
JOHN R. KAJMOWICZ,
Defendant
ANNULMENT
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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St.
Carlisle, Pa. 17013
(717) 249-3166
BETH A. MILLER,
VS.
: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
JOHN R. KAJMOWICZ,
Defendant
No. O3. jam( g Civil Term
ANNULMENT
COMPLAINT UNDER SECTION 3305 OF THE DIVORCE CODE
COUNT I - ANNULMENT ??-
1. Plaintiff is Beth A. Miller, a competent adult individual, whose address is Circle Road,
Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is John Richard Kajmowicz, a competent adult individual, whose current
address is 60 Fenwick Hall, Allee #1212, Johns Island, South Carolina, 29455.
3. The Plaintiff has resided in the Commonwealth during the six months immediately
preceding the commencement of this action.
4. The Plaintiff and the Defendant were married on August 22, 2003 in Las Vegas,
Nevada.
5. Plaintiff and Defendant were under the influence of alcohol at the time of the
ceremony.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Plaintiff and Defendant have no children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Defendant is currently an officer in the U.S. Navy and is active duty; Plaintiff is not a
member of the armed forces.
10. The Plaintiff avers that the grounds on which this action is based are:
(a) That either party to the marriage was under the influence of alcohol or drugs
and an action for annulment is commenced within sixty (60) days after the
marriage ceremony.
WHEREFORE, Plaintiff requests the court to enter a decree that the parties' marriage is
annulled.
Respectfully submitted,
Date: 1 D 1? ?j 3 Ian ?A U
ams, Esquire
79465
h Pitt Street
, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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 unworn
falsification to authorities.
Beth A. Miller, Plainti
BETH A. MILLER,
VS.
: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
JOHN R. KAJMOWICZ,
Defendant
No. 03 - 5518 Civil Term
ANNULMENT
ACCEPTANCE OF SERVICE
PURSUANT TO PA.R.C.P 4 02(B) AND PA.R C.P. 1920.4
I, John R. Kajmowicz, hereby accepted service of the Notice to Defend and Complaint for
Annulment in the above-captioned matter on or about 2_5ooT- c?
any and all defects in service of the aforementioned Complaint or any amendments amendments hereto. waive
Date: 29oc,-rcs3
R. Kajm wicz, Defe:'
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BETH A. MILLER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
JOHN R. KAJMOWICZ : NO. 2003-5518 CIVIL TERM
ORDER OF COURT
AND NOW, this 22ND day of JANUARY, 2004, the request for the entry of a
decree of annulment is DENIED without prejudice. We will schedule a hearing on this
matter at the request of either party.
By o
Edward E. Guido, J.
Jane Adams, Esquire
For the Plaintiff
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Curtis R. Long
Prothonotary
Office of the protbonotarp
eum'berlanb CauntP
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTEPROMAI ING TICS OF ABO INTENTION TO PROCEED ANDW TH P?I? ACCORDANCE NTH PA
CASE IS HEREBY TERMINATED
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573