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HomeMy WebLinkAbout08-0629KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff /? CASE NO. ?$ - 10o' T? Olvi [ (er m v. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW 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 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 minor 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 Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 South Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 Date: January 25, 2008 By: P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 F:\Home\KKNIGHTIDOCS\Harper\Complaint. WPD 2320 North Second Street KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA CASE NO. V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE AND NOW, comes the Plaintiff, Kristi K. Harper, by and through her counsel, Cunningham & Chernicoff, P.C., and seeks to obtain a Decree in Divorce from the Defendant, Michael A. Harper a/k/a Adam Harper, and support thereof avers as follows: 1. The Plaintiff, Kristi K. Harper ("Plaintiff'), currently resides at 413 Fourth Street, New Cumberland, Cumberland County, Pennsylvania 17070. The Plaintiff is a citizen of the United States of America. Plaintiff s Social Security Number is 193-64-4231. 2. The Defendant, Michael A. Harper a/k/a Adam Harper, ("Defendant"), currently resides at 27 South Market Street, Duncannon, Perry County, Pennsylvania 17020. The Defendant is a citizen of the United States of America. Defendant's Social Security Number is 215-17-9041. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on February 5, 2003, in Cumberland County, Pennsylvania. 6. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the Court the parties to participate in counseling. WHEREFORE, Plaintiff, Kristi K. Harper, hereby respectfully requests this Honorable Court to enter a Decree in Divorce from the bars of matrimony. COUNT II - CUSTODY 9. The averments of Paragraphs 1 through 8 are incorporated herein by reference as if fully set forth. 2 10. The Plaintiff seeks primary physical of the following child: Name Shane Michael Harper Present Residence 413 Fourth Street New Cumberland Cumberland County, Pennsylvania 17070 Date of Birth March 6, 2003 11. The minor child, Shane Michael Harper ("Minor Child"), was not born out of wedlock. 12. The Minor Child is presently in the custody of the Plaintiff, who currently resides at 413 Fourth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 13. During the past five (5) years, the Minor Child has resided with the following persons at the following addresses: Persons Plaintiff; Defendant; Jasmyne Renae Harris (Plaintiffs Child) Address 100 South Locust Street Apartment 1-A Cumberland County Pennsylvania 17011 Dates March 6, 2003 to June 10, 2006 Plaintiff, Defendant; Jasmyne Renae Harris (Plaintiffs Child) Plaintiff, Jasmyne Renae Harris (Plaintiffs Child); Bryan O. Kleeman (Plaintiffs Father) 33 North Market Street Duncannon, PA 17020 413 Fourth Street New Cumberland, PA 17070 June 10, 2003 to June 9, 2007 June 9, 2007 to Present 14. The Mother of the Minor Child is Plaintiff, Kristi K. Harper. She is married to the Defendant. 15. The Father of the Minor Child is Defendant, Michael A. Harper a/k/a Adam 3 Harper. He is married to the Plaintiff. 16. Plaintiff has no information of another custody proceeding concerning the Minor Child pending in a Court of this Commonwealth. 17. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the Minor Child or claims to have custody or visitation rights with respect to the Minor Child. 18. The best interest and permanent welfare of the Minor Child will best be served by granting the relief requested because the Plaintiff has been the primary caretaker of the Minor Child; remains the primary caretaker of the Minor Child; can provide a stable, safe and secure environment and can provide for the Minor Child's emotional, psychological, and spiritual needs. Furthermore, the Minor Child views the Plaintiff as a source of stability, a source of love and a source of emotional support. 19. Each parent whose parental rights to the Minor Child has been terminated and all persons who have physical custody of the Minor Child has been named as a party of this action. All other persons named below, who are known to have a claim or right to custody of visitation of the Minor Child have been given notice of the pendency of this action and their right to intervene; NONE. 20. The parties have executed a Stipulation of Custody for the Minor Child (the "Stipulation"). A true and correct copy of the Stipulation is attached hereto as Exhibit "A". 21. Plaintiff and Defendant requests that this Honorable Court enter an Order, in the 4 form of the proposed Order attached to this Complaint, which reflects the parties agreement for custody as set forth in the Stipulation. WHEREFORE, Plaintiff, Kristi K. Harper, hereby respectfully requests this Honorable Court to grant primary physical custody of the Minor Child to the Plaintiff and grant her such further relief as is just and proper. By: 011- Date: January , 2008 F:\Home\KKNIGHTIDOCS\Harper\Complaint. WPD Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Attorneys for Plaintiff, Kristi K. Harper 5 P.O. Box 60457 VERIFICATION I verify that the statements made in the foregoing 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. KRISTI K. HARP Date: t-a 'S-v? .2008 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss; The Plaintiff, being duly sworn according to law, deposes and says that she is the Plaintiff in the above captioned matter and that he personally knows that the Defendant is over the age of eighteen (18) years. The Plaintiff further avers that the Defendant is not in the Military Service or in any branch of the Armed Forces of the United States of America or its Allies or otherwise within the provisions of the Soldier's and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. SWORN and Subscribed to BefoTe me this day of,-J CL-n 2008 41ST?I K. HA OTARY B"JOIJUH OF NIA SEAL JULIEANNE AMETRANO, Notary Public City of Harrisburg, Dauphin County My Commission Expires Feb. 22, 2011 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . ss; I, KRISTI K. HARPER, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and , understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. KRISTI K. HA Z!) SWORN and Subscribed to Befor me this ??5 day of 2008 ARY PUBLIC J COMMONWEALTH OF PENNSYLVANIA / NOTARIAL EAL JULIEANNE AMETRANO, Notary Public City of Harrisburg, Dauphin County My Commission Expires Feb. 22, 2011 "? t O ? ? .... O -p v n ?? ? ° _ F ?r?i A (aJ u ?Y KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CASE NO. C)00- &a.9 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW 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 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 minor 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 Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 South Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 By: Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Date: February q , 2008 Attorneys for Plaintiff, Kristi K. Harper F:\Home\KKNIGH7PDOCS\Hatper\Complaint. WPD P.O. Box 60457 KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS OF THE 41 IT JUDICIAL DISTRICT Plaintiff OF PENNSYLVANIA CASE NO. 08-629 Civil Term V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE AMENDED COMPLAINT IN DIVORCE COUNT I - DIVORCE AND NOW, comes the Plaintiff, Kristi K. Harper, by and through her counsel, Cunningham & Chernicoff, P.C., and seeks to obtain a Decree in Divorce from the Defendant, Michael A. Harper a/k/a Adam Harper, and support thereof avers as follows: 1. The Plaintiff, Kristi K. Harper ("Plaintiff'), currently resides at 413 Fourth Street, New Cumberland, Cumberland County, Pennsylvania 17070. The Plaintiff is a citizen of the United States of America. Plaintiff s Social Security Number is 193-64-4231. 2. The Defendant, Michael A. Harper a/k/a Adam Harper, ("Defendant"), currently resides at 27 South Market Street, Duncannon, Perry County, Pennsylvania 17020. The Defendant is a citizen of the United States of America. Defendant's Social Security Number is 215-17-9041. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on February 5, 2003, in Cumberland County, Pennsylvania. 6. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the Court the parties to participate in counseling. WHEREFORE, Plaintiff, Kristi K. Harper, hereby respectfully requests this Honorable Court to enter a Decree in Divorce from the bars of matrimony. COUNT II - CUSTODY 9. The averments of Paragraphs 1 through 8 are incorporated herein by reference as if fully set forth. 10. The Plaintiff seeks primary physical of the following child: 2 Name Shane Michael Harper 11. The minor child, Shane Michael Harper ("Minor Child"), was not born out of wedlock. 12. The Minor Child is presently in the custody of the Plaintiff, who currently resides at 413 Fourth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 13. During the past five (5) years, the Minor Child has resided with the following Present Residence 413 Fourth Street New Cumberland Cumberland County, Pennsylvania 17070 Date of Birth March 6, 2003 persons at the following addresses: Persons Plaintiff; Defendant; Jasmyne Renae Harris (Plaintiffs Child) Address 100 South Locust Street Apartment 1-A Cumberland County Pennsylvania 17011 Dates March 6, 2003 to June 10, 2006 Plaintiff, Defendant; Jasmyne Renae Harris (Plaintiffs Child) Plaintiff; Jasmyne Renae Harris (Plaintiffs Child); Bryan O. Kleeman (Plaintiffs Father) 33 North Market Street Duncannon, PA 17020 413 Fourth Street New Cumberland, PA 17070 June 10, 2003 to June 9, 2007 June 9, 2007 to Present 14. The Mother of the Minor Child is Plaintiff, Kristi K. Harper. She is married to the Defendant. 15. The Father of the Minor Child is Defendant, Michael A. Harper a/k/a Adam Harper. He is married to the Plaintiff. 3 16. Plaintiff has no information of another custody proceeding concerning the Minor Child pending in a Court of this Commonwealth. 17. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the Minor Child or claims to have custody or visitation rights with respect to the Minor Child. 18. The best interest and permanent welfare of the Minor Child will best be served by granting the relief requested because the Plaintiff has been the primary caretaker of the Minor Child; remains the primary caretaker of the Minor Child; can provide a stable, safe and secure environment and can provide for the Minor Child's emotional, psychological, and spiritual needs. Furthermore, the Minor Child views the Plaintiff as a source of stability, a source of love and a source of emotional support. 19. Each parent whose parental rights to the Minor Child has been terminated and all persons who have physical custody of the Minor Child has been named as a party of this action. All other persons named below, who are known to have a claim or right to custody of visitation of the Minor Child have been given notice of the pendency of this action and their right to intervene; NONE. WHEREFORE, Plaintiff, Kristi K. Harper, hereby respectfully requests this Honorable Court to grant primary physical custody of the Minor Child to the Plaintiff and grant her such further relief as is just and proper. 4 Respectfully Date: February -?-, 2008 By: KellYM. Ifniit, Vquire I.D.1#87365 / 2320 North Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 F:\Home\KKNIGH I?DOCSUHarper\ComPlaint. WPD - PLO ? ?c:n ? C. N ?t N KRISTI K. HARPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-629 CIVIL ACTION LAW MICHAEL A. HARPER A/K/A ADAM HARPER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, February 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, March 17, 2008 at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. 4 Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 44, 4p - ?r? WAR 24 2008 P,/ 15- KRISTI K. HARPER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-629 CIVIL ACTION LAW MICHAEL A. HARPER A/K/A ADAM HARPER Defendant IN CUSTODY ORDER OF COURT AND NOW, this Z s fih day of t r A\ 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father shall obtain an alcohol evaluation to be conducted by a professional to be selected by agreement between the parties. The Father shall provide information concerning his insurance coverage to the Mother who, along with her counsel, will investigate the options for the evaluation. Any costs of the evaluation which are not covered by insurance shall be shared equally between the parties. The purpose of the evaluation shall be to obtain professional guidance as to whether or not the Father's use of alcohol affects his ability to provide care for the Child and also to obtain recommendations concerning whether the Father requires treatment for alcohol related issues. The Father shall obtain the recommendations of the evaluator in writing. 2. Pending completion of the evaluation, the Mother shall have primary physical custody of the Child and the Father shall have periods of custody with the Child every weekend at a mutually selected location as arranged by agreement between the parties. 3. Within sixty (60) days of completion of the evaluation, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. BY THE COURT, cc: elly M. Knight, Esquire, Counsel for Mother uglas Holden, Esquire - Counsel for Father 1 L I ..1 Wd SZ SVW ROOZ KRISTI K. HARPER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-629 CIVIL ACTION LAW MICHAEL A. HARPER A/K/A ADAM HARPER Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Shane Michael Harper March 6, 2Q03 CURRENTLY IN CUSTODY OF Mother 2. A custody conciliation cotsti rence was held on March 17, 2008, with the following individuals in attendance: the Mother K. Harper, with her counsel, Kelly M. Knight, Esquire, and the Father, Michael A. Harper, who appeared at the conference without counsel although the Father indicated that he is represented by Douglas Holden, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ) Date Dawn S. Sunday, Esquire Custody Conciliator r- ? KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08 -.6?K 6-P-1 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Julieanne Ametrano, Legal Assistant with the law firm of Cunningham & Chernicoff, P.C., hereby certify that on the Pt day of March, 2008, a true and correct copy of the Complaint in Divorce was served via certified mail, restricted delivery, return receipt requested and regular mail as evidenced by the Acceptance of Service, attached as Exhibit "A" to: Mr. Michael A. Harper a/k/a Adam Harper 27 South Market Street Duncannon, PA 17020 CUNNINGHAM & CHERNICOFF, P.C. J ieanne Ametrano 2 20 North Second Street 0. Box 60457 Harrisburg, PA 17106-0457 Date: March 18, 2008 F:UHome\KKNIGHT\DOC S\Harper\COS. wpd EXHIBIT `A' l -1 . , ¦ CWOM* Anne t 2? mW & Abc CEllfs?llst! ttwn 4 N RMhtcttd dWboy W deskrd. ¦ Prktt your fwris and address on the rwv ns so OW wcon Mum Ow cwd to you. ¦ Attech Ws cad to the back of the npW *m. or on the A+cnt K space permits.' 1. Male Adlseasd tm rs=• A. X ` C . r pp" 7 'n"Nw* 1Or o. m dd vvy sddrsm dlfs w from ibm 1? Min If YM, enter delivery address below: ;2"No 3. Sorvloelyps ) Cs wm Mal D Express Marl WIJO&WW Retum Rs "O for Msrdwxme 0 Inetred Mal ? C.O.D. 4. Restricted D~ pft Fbo IIKYOS 13 x. Article Nuffber ftmswvioaMw 7006 QBZa OQ 0333 5484 lTS FoLm,' 11' F*"11e'n7299411 1111 Ror"mc R.a,m Rscw 102595-W-W15W U1 m m m ru 0 M 0 C3 r-I CO Q r0 C3 C3 r%- CD i C_Y i % KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08-629 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 29, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 unworn falsification to authorities. Date: isti 4KFYarper?j '`'° C1 G ??' . ?- ? ?„- ?. ? ? ? . _, ;= ? ,? . N ? ? ?-=' -l? , = ? ??` ?; ?,, G`" ? , t.? { Th KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08-629 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE 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 falsification to authorities. Date: V}? 1 ? U "st . H m ?3f r' tom:. ?X KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO:.- MICHAEL A. HARPER A a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 29,2008 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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: /? /// )% ; z L Michael A. Harp r aWa Adam Harper i 1 t KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08-62f v. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE 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 falsification to authorities. Date: I l ? 9 Michael A Harp a/k/a Adam Harper G n °rx -0 G ? g { r- .?q V% ., AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF ss; I, MICHAEL A. HARPER a/k/a ADAM HARPER, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MICHAE A. H ER a/k/a ADAM HARPER SWORN and Subscribed to Before me this / .? day of 2008 AR EE E. WEIiIEY A., lhiN1 of Duncannon, Perry ff&*" Uft Mall 1qNA , F:\Home\KKNIGHT\DOCS\Harper\Divorce.C\Waiver of Counseling.wpd n ` 3 iz? r ? n? i 21- KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08-629 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant 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 §3301(c) or 3301(d)(-1) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: Defendant was served with the Complaint in Divorce Under §3301(c) of the Divorce Code on March 1, 2008, via certified mail, restricted delivery return receipt requested and regular mail, as evidenced by the Certificate of Service filed with this Court on March 20, 2008. 3. (Complete either Paragraph (a) or (b)). (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code was signed by Plaintiff on June 12, 2008 and by Defendant on June 11, 2008. Both Affidavits were filed with this Court simultaneously with the filing of the instant Praecipe to Transmit Record. (b)(1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code: N/A (2) Date of filing and service of the Plaintiff s Affidavit upon the Respondent: N/A 4. Related claims pending: None. Count II of the Complaint regarding Custody was resolved by this Courts Order of March 25, 2008. 5. (Complete either Paragraph (a) or (b)). (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record. N/A (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Plaintiffs Waiver was executed June 12, 2008 and was submitted to this Court simultaneously with the instant Praecipe to Transmit Record. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Plaintiffi 1 KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08-629 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Julieanne Ametrano, Legal Assistant, with the law firm of Cunningham & Chernicoff, P.C., hereby certify that a true and correct copy of the Praecipe to Transmit Record was served by first-class U.S. Mail, postage prepaid, to: Mr. Michael A. Harper a/k/a Adam Harper 27 South Market Street Duncannon, PA 17020 Date: June 12, 2008 CUNNINGHAM & J lieanne Ametrano 20 North Second Street 0. Box 60457 Harrisburg, PA 17106-0457 COFF, P.C. F:UHome\KKNIGHT\DOCS\Harper\Divorce.C\Praecipe to Transmit C.wpd C ' ZZ ('y?f mf' Cr? .r N ..1 ''? ?'? ? Ala . (..1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KRISTI K. HARPER „ VERSUS MICHAEL A. HARPER a/k/a ADAM HARPER No. 08 DECREE IN DIVORCE AND NOW, DECREED THAT 'S Q N?. 17 KRISTI K. HARPER 629 , ?oO , IT 1S ORDERED AND , PLAINTIFF, AN D MICHAEL A. HARPER a/k/a ADAM HARPER , 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 PROTHONOTARY r---44 v- L' - ?, 0 j. KRISTI K. HARPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA CASE NO: 08-629 V. MICHAEL A. HARPER a/k/a ADAM HARPER, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE OF INTENTION TO RETAKE PRI,QR NAME Notice is hereby given that Plaintiff in the above matter, having been granted a Final Decree in Divorce on thel7th day of June, 2008, hereby elects to retake and hereinafter use her previous name of Kristi K. Kleeman and gives this written Notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, 54 Pa. C.S. § 704. ka- /0;2 Date Kristi K. Harper TO BE KNOWN AS: o?-) IJ)-k)A Kristi K. Kleeman (Signature of Name to be Resumed) ?, c STATE OF CONNECTICUT COUNTY OF SS. On this, the X day of 2008, before me, a Notary Public, personally appeared the affiant, known to me (or satisf ctorily proven) to be the person described in the within instrument, and acknowledged that she executed the same in the capacity therein stated and for the purposes therein contained. ficis IN WITNESS WHEREOF, I hereunto =U , Or e N Public i } °*+.. ?/ [`*?, 'w.p ^?.. ?. ?..3 ?? <.?, f.,,. ? rn? ?. -. '?Y ?? ? l_? ..r ?_ ,_?l`f"4 ( "• ,._. ?? r 3 )( ^ , ,. ?i.