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Home My WebLink About87-3571..~~~ e ~ ,. r l N THE COURT OF COMMON PLEAS .. OF CUMBERLAND COUNTY ., ,~, ,. ~~ STATE OF PENNA. ;, .. ~~ ,., c ,< JUDY KIRKPATRICK, I •, ' NO..35.~.1............ CIVIL.... 1~~ - Pl.aznit-~-ff_ l ~, ~ .,. Verszzs ~ TIMOTHY KIRKPATRICK, !~ .' ;:? -_ Defendant.-_... __ _ -- ;i•; .. ~~' i ~' ~: ;. DECREE IN DIVORCE ~ .. t AND NOW, ~ .... . ~ ........ 19.8 $.. , .. decreed that U Y KIRKPATIRCK .. 36 ~- it is ordered and ...... ,plaintiff, and ...TIMOTHY KIRKPATRICK . . _ ...... ,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 ., ---- -- Qy T u t F ..- - - -_ -'J. Attest. /~ ?~ti , Prothonotary f" ~w.:: "fl~l•., a,*., :.y • '~A'.,. fir-: ?* .. '•:~•;.: l-:•-::: A2; . A'i; ` :~s :IR'.•:; ' :~~ ::~ •-:. ~I• ~ • ' .~ • •'~ • :~ • . ~ , ; :~ •.: ~ • ,•'A ~ •: :~ • :~ • ~ •: •;~ i i :~ ;, i ;i; i 0 :~~ •. J 1 ~ ~~I ~r n -~ k _~ ~1 3~ JUDY KIRKPATRICK, Plaintiff v. TIMOTHY KIRKPATRICK, Defendant . IN THE COURT OF COMr'!ON PLEAS . OF CUr1BERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 3571 CIVIL 1987 IN DIVORCE 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. Ground for divorce: irretrievable breakdown under Section 201(c) of the Divorce Code. Z. Date and manner of service of the complaint: 12-5-87 United States mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the affidavit of consent required by Section 201(c) of the Divorce Code: By the plaintiff: 4-24-88. By the defendant: 4-12-88. 4. Related claims pending: none. Date ~ 3 X ~ ~ ~`~ -~ ~~ ~ RICHARD KUPERSMITH Student Attorney 1 THOMAS 'LAC ROBERT E. RAINS Supervising Attorney FAMILY LAW CLINIC 150 South College Street Carlisle, PA 17013 717/243-8897 ~:: $J~, ~® ,~, ti y JUDY K. KIRKPATRICK, IN THE COUP.T OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW NO. ~;~j~( CIVIL 1987 TIl`1OTHY M. KIRKPATRICK, .~ Defendant 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 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, 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 CAPdNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717)249-1133 ~ . JUDY K. KIRKPATRICK, Plaintiff, v. TIMOTHY M. KIRKPATRICK, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. CIVIL 1987 IN DIVORCE nn~,.tnr n TrTT Plaintiff, JUDY KIRKPATRICK, by her attorneys, Family Law Clinic, sets forth the following cause of action: COUNT I. DIVORCE UNDER SECTION 201(c) AND 201(a}(6) OF THE DIVORCE CODE 1. Plaintiff is JUDY KIRKPATRICK, who currently resides at R.D.~~ 8, Box 385 C (mailing: Box 528, Carlisle), Carlisle, Cumberland County, PA 17013. 2. Defendant is TIMOTHY KIRKPATRICK, who currently resides at R.D.~~ 1, Box 179, Shermans Dale, Perry County, PA 17090. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and defendant were married on September 15, 1979 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff avers that the marriage is irretrievably broken. 6. Plaintiff avers that defendant, in violation of his marriage vows under the laws of the Commonwealth of Pennsylvania, has offered such indignities to the person of the plaintiff, his injured and innocent spouse, as to render the condition r of the plaintiff intolerable and life burdensome. 7. Plaintiff and defendant have lived separate and apart since May 1, 1987. 8. There have been no prior actions of divorce or for annulment between the parties. 9. Plaintiff has been advised of the availability of counseling and of the plaintiff's right to request that the court require the parties to participate therein. 10. Neither plaintiff nor defendant is in the Armed Forces of the United States. WHEREFORE, plaintiff prays your Honorable Court to enter a decree in divorce, dissolving the marriage. Date /,.;~` / %~ ~' ~ ~~~u ~` ~~ RICHARD T. PERSMITH Student Attorney ~~°' ~ ~~~~~' THOMAS "M . P L`A~Fr` ROBERT E. RAINS Supervising Attorney FAr1ILY LAW CLINIC 150 South College Street Carlisle, PA 17013 717-243-8897 f ~ COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.§4904, relating to unsworn falsification to authorities. `\ , UDY K I K ATR .~ Date -1~ l~~ ~, . l . ~ ~ 4~; -- ~~_ ---a;- ~. ',T ~-. „\ ~-~ ~- ~ ` .t*v »~~~\ ~Jr"• r~ti. l :-F ~ c~ M ~~~ t 7 -i f K_ 7.. ~ i L • ~ +r~= ~ JUDY K. KIRKPATRICK, Plaintiff v. TIMOTHY M. KIRKPATRICK, Defendant IN THE COURT OF COMP90N PLEAS . OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW , N0. 3571 CIVIL 1987 IN DIVORCE CERTIFICATE OF SERVICE I, TERENCE W. CAriP, student attorney, Family Law Clinic, ereb certify that I have served a true and correct copy of h y residing said Complaint in Divorce on Timothy M. Kirkpatrick, Shermans Dale, PA 17090, by depositing a at R.D.~rll, Box 179, certified, restricted copy of same in the United States mail, delivery, return receipt requested, postage prepaid, this lst day of December , 19E7 . ~, ~,..-- ,-, TERENCE W . CAr'IP SENDER: Complete items 1 and 2 when additional services are deNred, snd complete ltema 3 and A. Put your address in the "RETURN TO" space on the reverse slde. Failure to do this will prevent this card from being returned to you. The return receipt fee will prGlltde von tfia name of the aerson delhrored to and the date of d h~6 M ~` - o- 1: ~ ~ ~ _ ~, or ~ no~ ~. e ..rw~s die eVaiiaole. ~:or-sult posgflatter a ox es) for additional servk;e(s) requested . ,, / ,, , ,, 1: 'Show to whom del ,data, and addressee's address: 2. L7 Restricted Delivery. 3. Article Addressed to: 4. Article Number 1 ~ jig ~~ ~ ~ _ Type of Sendu: . ~ Insured COD /~ _ f ~ `v1~ ~" i~~c-G~e~-5 ~GU~ MWI ! 170 9o Ahivays otnain stprerture of ac~ire~e or avant and oA~ itMluvi~aea. b. Sign re -Addressee ° 8: Addreaea'a Addreaa ~O NL Y if X ~ regetested and fee P~J X s q~ ure - A~ 4 r~~ " 7. D of Deliv ~ J S ra rorm se i ~, r~o. iyao DOMESTIC RETURN RECEIPT i ) G- '~ y ti ~-' ~, ~~ j ' ~~ JUDY KIRKPATRICK, IN THE COURT OF COMP]OPd PLEAS Plaintiff OF CU1`1BERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. N0. 3571 CIVIL 1987 TIMOTHY KIRKPATRICK, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on December 1, 1987. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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 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 ~Q ~t`~~` J DY K PA R I C -~ ~J. ~, -sa r~ cam: JUDY KIRKPATRICK, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNT:, PENNSYLVANIA v. CIVIL ACTIOPI - LA4J N0. 3571 CIVIL 1987 TIMOTHY KIRKPATRICK, . Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on December 1, 1987. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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 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. ~~ ~ ~ ~ ~ ~'r ~ ~ t~ Date ~ ;C l'IIIC" ~L~'' ~G l~C~) r- ~~ TIMOTH KIRKPAT ~ CK ~~ ~. ~ _ 1 Q