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HomeMy WebLinkAbout07-7136 Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- `7134, CIVIL TERM 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 Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7/36 IN DIVORCE CIVIL TERM COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is 1 CftffibDeM , who currently resides at a0 PO IX vpr ;?- Cumberland County, Pennsylvania. 2. Defendant is who currently resides at 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 e aA ?I? 9y0? at r V v 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*Wher 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. . . .:. 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. Date Plaintiff, P Se I, Y ? AC 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. NO\(, -)r1 aoo Date: OA,), a 0 01 Plaintiff, ro Se Assisted by: Barbara Sumple-Sullivan, Esq. Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7136 CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. c? rTl J , ko 1 Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Kayce R. Campbell , Plaintiff, to proceed in forma au eris. I, Barbara Sumple-Sullivan, 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. Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 a IM, 171 ?? a . 40. Kayce R. Campbell IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 713 (o CIVIL TERM Adam M. Campbell : Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on ` a.A J and continued to live separate and apart for a period of two yeah. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I, ? "CL \k , verify that the statements made in this Affidavit 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 P.S. Section 4904. Ncw,ab aoca `+ Date 440 ksc v Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 07- Civic. TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ? 0) The parties to this action have not lived separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims for economic relief. 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. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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: Adam M. Campbell NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ?`f n t-- s? ? _ C] y t 7 CZ) j` ,Z KAYCE R. CAMPBELL, Plaintiff V. ADAM M. CAMPBELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 7136 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Certified Mail, Certified No. 7007 0710 0003 2208 5626, Return Receipt Requested, on the above-named Defendant, Mr. Adam M. Campbell, on December 10, 2007 at Defendant's last known address: 12 N. Baltimore Avenue, Mt. Holly, PA 17065. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: April 1, 2008 biffbvEa Sumple-Sullivan, Esquire For Kayce R. Campbell U.S. Postal Service,,., CERTIFIED IVIAIL,r? RECEIPT Provided) (Domestic Mail Only; No Insurance Coverage ru ...o Lr1 p1ANNttN PR 1?i)r) . r3 $0.58 rLt Postage $ eo ?yd' ru Certified Fee $2.65 M Return Receipt Fee 2.15 0 re b E3 (Endorsement Required) C3 © 3 C3 Restricted Delivery Fee ?? ??? r3 (Endorsement Required) ,q $5.38 11/29/221 Total Postage & Fees C3 - Sent To M =6 O Street, Apt No. •tn-•W or PO Box No. 5?1/I"t Y.- .... ............. State. ZIP ??\1/'1 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted 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 mailpiece, or on the front if space permits. 1. Article Addressed to: ?UY1`Irl?Yl , ? ? A. Sign ture * f ? Agent X ? Addressee B. Received by (Nnt&d Name) C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type 51 Certified Mail O Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7007 0710 0003 2228 5626 (Transfer from service tabu PS Form 3811, February 2004 Domesfic Retum Receipt 102595-024A-1540 EXHIBIT "A" I T) Kayce R. Campbell IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7136 CIVIL TERM Adam M. Campbell Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 after service of notice of intention to request entry of divorce. 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 authoritie . Date: 14I Signat K4 -e 0 Campbell, Plaintiff c ? ": c t - Kayce R. Campbell Plaintiff v. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7136 IN DIVORCE CIVIL TERM WAIVER OF NOTICE 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 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. 41, Date: ® Signatur Kayc R. mpbell, Plaintiff -„s s a'v , --? tJ1 '17 Kayce R. Campbell IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7136 CIVIL TERM Adam M. Campbell Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 after service of notice of intention to request entry of divorce. 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 , ) w I. - ?L -C1411JJ Date: I t5 Signature: Adam M. C mpb 11, Defendant t V 5 } Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7136 IN DIVORCE CIVIL TERM WAIVER OF NOTICE 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. 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 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: Signature: Adam M. Cam ell, Defendant C? rv .. ? <': ?:? f'YZ .:;... ?. ??! ??; r` ? ??' ?.? C? S CJ .? ? Kayce R. Campbell Plaintiff V. Adam M. Campbell Defendant To The Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7136 CIVIL TERM IN DIVORCE 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) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on December 10, 2008 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, April 1, 2008 ; by Defendant, Bch 16, 2008 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 2, 2008 (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 2, 2008 Dated: April 1, 2008 / LZ14-*01- L--" Barbafa Sumple-Sullivan, Esquire for Kayce R. Campbell S K- ? •__. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ira STATE OF PENNA. KAYCE R. CAMPBELL, Plaintiff VERSUS ADAM M. CAMPBELL, Defendant No. DECREE IN DIVORCE 07 - 7136 Zoos AND NOW, IT IS ORDERED AND Kayce R. Campbell DECREED THAT PLAINTIFF, Adam M. Campbell AND 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. ATTEST: PROTHONOTARY BY THE COURT: ? .r .?, a,?y •?? lam, `?, ??-?- ???