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Home My WebLink About03-6268 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Carrie L. Clites, : Civil Action - Law Plaintiff : vs. : 2003 Clinton E. Kennedy, : Defendant : In Divorce a v.m. 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 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 GR3LNTED, 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 CkN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone #717-249-3166 IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Carrie L. Clites, : NO~)~,&gA~ Civil Plaintiff : VS. : Clinton E. Kennedy, : Defendant : In Divorce a v.m. COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Carrie L. clites, who lives and resides at 3471 Ritner Highway, Newville, Cumberland County, Pennsylvania, and has resided there since July 2001. 2. Defendant is Clinton E. Kennedy, who lives and resides at 10855 Tolliston Lane, Indianapolis, Marion County, Indiana, and has resided there since September 5, 2003. 3. Plaintiff has been bona fide resident of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 11, 2003, in Magins Bay, St. Thomas, Virgin Islands. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff requests the Court to enter a decree of divorce. 8. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Carrie L. cl~ites, Plaintiff Attorney for Plaintiff 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. Carrie L. Cli , Plaintiff Date: November,S_, 2003. IN THE COURT OF COMMON PLEAS OF THE 9T~i JUDICIAL DISTRICT PENNSYLVD~NIA - CUMBERLAi~D COUI~[TY BR3LNCH Carrie L. Clites, : Civil Action - Law Plaintiff : vs. : #2003 6268 Civil Term Clinton E. Kennedy, : Defendant : In Divorce a v.m. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ( SS: COUNTY OF FRANKLIN ) Michael B. Finucane, being duly sworn according to law, deposes and says that he is attorney for the plaintiff in the above entitled action, that on December 3, 2003, he mailed a Divorce Complaint to the defendant at 10855 Tolliston Lane, Indianapolis, IN 46236-8241, by certified mail Article #70023150000047115707, return receipt requested, restricted delivery to addressee only, and said address being the last known post office address of the defendant, and the said return receipt card shows the date of delivery as December 13, 2003. ~ Michael B. Fln~L~ne, Attorney for Plaintiff Sworn and subscribed to before me this 23rd day of December, 2003. Notarial Seal I=li~h~t A. ~, Notary Public ~urg Bom, Franklin County My ~on Expires June 15, 2006 · Complete items 1, 2, and 3. Also complete ~.. Signature r-I Agent item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Rlt'ach this card to the back of the mailpiece, or on the front if space permits. [] No 1. Article Addressed to: if YES 10855 TOLLISTON LANE INDIANAPOLIS IN 46236-8241 B i [xpress Mail r-I Registered D Return Receipt for Merchandise Restricted Deliver? (Extra Fee) [] YeS (Tran~ ~.CPRI-03-Z-0985 PS For, F: ~ J Permit No. G-10 J · Sender: Please pri,nt yom ~mle ad~-~-'~- ..... :;s, and ZIP+4 ~ ~is ~x · MIC~EL FINUC~E ~W O~FICE 14 N ~IN ST SUITE 50C C~BERSBURG PA 17201 h"lll,,,I,,I,lll,,-,,Ih,,lll,,I,,,,llJ,,h,l,hl,hl,,I,i IN THE COURT OF COMMON PLEAS OF THE 9'tH JUDICIAL DISTRICT PENNSYLVANIA _ CUMBERLAND COUNTY BRANCH Carrie L. Clites, : Civil Action - Law Plaintiff : VS. : #2003 6268 Civil Term Clinton E. Kennedy, : Defendant : In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on December 2, 2003. 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 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: ~ -' 2004' ~~ ( PLAINTI~F~ ~ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Carrie L. Clites, : Civil Action - Law Plaintiff : : vs. : ~2003 - 6268 Civil Term Clinton E. Kennedy, : Defendant : In Divorce a v.m. 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 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. §4:904 relating to unsworn falsification to authorities. Date:~ ~ , 2004. C~%~%~'~1-) % (PLAINTIFF~ ~~ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Carrie L. Clites, : Civil Action - Law Plaintiff : vs. #2003 6268 Civil Term Clinton E. Kennedy, Defendant In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on December 2, 2003. 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 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: J/~/,. 2004.~PJ=A I NT I F ~~ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Carrie L. Clites, : Civil Action - Law Plaintiff : : ~2003 6268 civil Term VS. Clinton E. Kennedy, : Defendant : In Divorce a v.m. 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 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 falsificati°n t° auth°rities' ~LA~iNT~I ~ Date: ~ I~ 2004. Fy! ' (DEFENDANT) IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Carrie L. Clites, : Civil Action - Law Plaintiff : vs. : #2003 6268 Civil Term Clinton E. Kennedy, : Defendant : In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD To: Linda L. Beard, 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: by certified mail, return receipt requested, deliver to addressee only, which return receipt card was signed by defendant on December 13, 2003. 3. Date of execution of the affidavit required by § 3301(c) of the Divorce Code: by Plaintiff on April 18, 2004; by Defendant on June 1, 2004. 4. Related claims pending: None. 5. Date plaintiff's Waiver of Notice was filed with the Prothonotary: May 6, 2004. Date defendant's Waiver of Notice was filed with the Prothonotary: August 24, 2004. Date: August ~___~. 2004. ~ ~~~_~ Michael B. Finucane Attorney for Plaintiff IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE Of ~*i PENNA. Carrie L. Clites NO. 2003 - 6268 Civil Term VERSUS DECREE IN DIVORCE AND now,~~~-~ ~ 2004 , IT IS ORDERED AND DECREED THAT Carrie L. Cl~.tes , PLAINTIFF, AND Cl:l.nt:on E. Kennedy , 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; l/T/ BY THE COURT:,,' '~'~ · ,.: . / P/~TH O N OTA RY