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Home My WebLink About03-5901Kathleen D. Johnson, Plaintiff David J. Johnson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03- ~S'9o/ IN DIVORCE CIVIL TERM NOTICE TO DEFEND 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle, PA. 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 OFF1CE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 or (800) 990-9108 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. Kathleen D. Johnson, : Plaintiff : : CIVIL ACTION- LAW David J. Johnson, : NO. 03- sgO/ Defendant : iN DIVORCE 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Kathleen D. Johnson, an adult individual, who currently resides at 22 W. Baltimore Street, Apt. #2, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is David J. Johnson, an adult individual~ whose work address is: Pine Lawn Police Department, 6250 Steve Marre Drive, North County, St. Louis, Missouri 63121. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 25, 1999 in St. Louis, Missouri. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. 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 in Divorce. WHEREFORE, Plaintiff mspect£ully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, Date: //~ Michael J. Whare, 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 89028 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 unsworn falsification to authorities. Kh~leenD. Johnso~ Kathleen D. Johnson, Plaintiff David J. Johnson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5901 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 10, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 KAg'HLEEN D. JOHNSON Kathleen D. Johnson, Plaintiff David J. Johnson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5901 IN DIVORCE CIVIL TERM WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 {c) OF THE DIVORCE CODF 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 THE FOREGOING 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 KA'I'HLEEN D. JOt~NSON Kathleen D. Johnson, Plaintiff David J. Johnson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5901 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 10, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. DAVID J. JObl~9~N ~' Date Kathleen D. Johnson, Plaintiff David J. Johnson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5901 IN DIVORCE CIVIL TERM WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 THE FOREGOING 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 I~AV~D J. JOl-I~OJ~v' / Kathleen D. Johnson, Plaintiff David J. Johnson, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - I,AW NO. 03-5901 IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint in the above-captioned action. David J. Johnson Kathleen D. Johnson, Plaintiff V. David J. Johnson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5901 IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: November 17, 2003 mailed certified, return receipt requested and Acceptance of Service was also signed on November 20, 2003.. 3. Date of execution of the affidavit of consent required by § 3301 (c) or The Divorce Code: by the Plaintiff February 23, 2004; by the Defendant February 20, 2004. 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: March 2, 2004. Date: March 2, 2004 Mark F. uire 155 South Hanover Street Carlisle, PA 17013 (717) 241 ~6070 Supreme Court ID No. 87663 IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY STATE Of PENNA. Kathleen D. Johnson VERSUS David J. Johnson NO. 03-5901 Civil DecrEe iN DIVORCE AND N OW, j~LL~ , Z~I~, IT IS ORDERED AND DecreeD THAT Kathleen D. Johnson , PLAINTIFF, AND David J. Johnson ,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 COURT: ATTES' J. PROTHONOTARY