HomeMy WebLinkAbout03-6223MICHAEL S. KINSEY,
Plaintiff
KIM B. KINSEY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
: NO. 03- ~2~ 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 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 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
Telephone No. 1-800-990-9108 or 249-3166
Attorney for Plaintiff
TUCKER ARENSBERG, P.C.
P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
MICHAEL S. KINSEY,'
Plaintiff
KIM B. KINSEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 03- ~ Civil Term
: IN DIVORCE
COMPLAINT UNDER 3301 (c) OF THE DIVORCE CODE
1. Plaintiff is Michael S. Kinsey, an adult
individual who is sui juris and resides at 5147 S. Deerfield
Avenue, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Klm Bo Kinsey, an adult individual
who is sui juris and resides at 5147 S. Deerfield Avenue,
Mechanicsburg, Cumberland County, Pennsylvania. The present
whereabouts of the Defendant, Kim B. Kinsey, to the knowledge of
the Plaintiff, is the same.
3. Both Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on
May 29, 1993, in St. Croix, Virgin Islands.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff has been advised
counseling and the right to request that
parties to participate in counseling.
of the availability of
the Court require the
7. The Defendant is not a member of the Armed
Services of the United States or any of its Allies.
8. The Plaintiff avers that the ground on which the
action is based is that the marriage is irretrievably broken.
WHEREFORE,
A. Dissolving the marriage
Defendant; and
B. For such further relief as
equitable and just.
Plaintiff requests the Court to enter a Decree:
between Plaintiff and
the Court may determine
TUCKER ARENSBERG, P.C.
Sandr~ L. ~eilton
No. 32551
111 N. Front Street
P.O. Box 889
Harrisburg, PA 17108
Attorneys for Plaintiff
I verify that the statements made
true and correct. I understand that false
made subject to the penalties of 18 Pa.C.S.
to unsworn falsification to authorities.
64059.1
in this Complaint are
statements herein are
Section 4904, relating
Michael S. Kins~intif%
MICHAEL S. KINSEY,
Plaintiff
KlM B. KINSEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 03-6223 Civil Term
:IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF DAUPHIN )
AND NOW, this 5th day of December, 2003, personally appeared before me, a
Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, paralegal
to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on
December 2, 2003, she mailed a certified copy of a Complaint in Divorce to Kim B. Kinsey,
5147 S. Deerfield Avenue, Mechanicsburg, PA 17055, by certified mail no. 7099 3400 0016
3623 6139, return receipt requested, and the same was received by her on December 4,
2003, as indicated by the return receipt card which is attached hereto.
Gloria M. Rine
Sworn to and subscribed
before me this 5th day
of December, 2003.
Notary Public
(SEAL)
Postage $
Certified Fee
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
2iIM~ B....KINSEY ..........................................
~ 51~ S. DEERFIELD AVENUE
~- ~9~L~NTCSBURG, PA 17055
· 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:
MRS. KIM B. KINSEY
5147 S. DEERFIELD AVENUE
MECHANICSBURG, PA 17055
PS Form 3811, July 1999
If YES, ente
3. Service Type
}~Certlfled Mail [] Express Mail
F'I Registered [] Return Receipt for Merchandise
D Insured Meil [] C.O.D.
4. R~ D~/ery? (~ ~) ~
0016 3623 6139
Do,-n~t~ Return F:~:e~
102595-99-M-1789