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Home My WebLink About08-1416CRAIG B. KISSINGER, Plaintiff V. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008- /f/(- CIVIL TERM CIVIL ACTION-LAW 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 Court House, Carlisle, 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 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 CRAIG B. KISSINGER, Plaintiff V. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - ]q/(1 CIVIL TERM CIVIL ACTION-LAW DIVORCE COMPLAINT 1. Plaintiff is Craig B. Kissinger, an adult individual who currently resides at 3 Sussex Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Jill E. Kissinger, and adult individual who currently resides at 3 Sussex Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 4, 2003 in Las Vegas, Clark County, Nevada. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. COUNT II -EQUITABLE DISTRIBUTION 8. Plaintiff hereby incorporates by reference paragraphs 1 through 7 above. 9. The parties have acquired real estate, personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. COUNT II - CUSTODY 10. Plaintiff hereby incorporates by reference all of the averments contained in paragraphs 1 through 9 of this Complaint. 11. The parties have one child of their marriage, Jacob C. Kissinger, born June 15, 2003. The child was born in wedlock. The child is presently in the custody of Plaintiff and Defendant at 3 Sussex Drive, Carlisle, Cumberland County, Pennsylvania, 17013. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates Craig and Jill Kissinger 3 Sussex Drive 2003- Carlisle, Pennsylvania Present The natural father of the child is Craig B. Kissinger, currently residing at 3 Sussex Drive, Carlisle, Cumberland County, Pennsylvania, 17013. He is married to the Defendant. The natural mother of the child is Jill E. Kissinger, currently residing at 3 Sussex Drive, Carlisle, Cumberland County, Pennsylvania, 17013. She is married to the Plaintiff. 13. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with the following persons: Names Relationship Jill E. Kissinger Wife Jacob C. Kissinger Son 14. The relationship of the Defendant to the child is that of natural mother. The Defendant currently resides with the following persons: Names Relationship Craig B. Kissinger Husband Jacob C. Kissinger Son 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: none. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order awarding the parties shared legal and physical custody of the child. Date: Respectfully submitted, O'BRIEN, BARIC & SCHERE Michael A. Scherer, Esquire I. D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff i VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: .2 a ? _ D Craig B. issinger ? W o T? C .:1 J -7p W 't . T a 4 _ Ir CRAIG B. KISSINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 - CIVIL TERM JILL E. KISSINGER, CIVIL ACTION -LAW Defendant IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Craig B. Kissinger, an adult individual who currently resides at 17 Luke Lane, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jill E. Kissinger, an adult individual who currently resides at 3 Sussex Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff seeks custody the Parties' son, Jacob C. Kissinger, who currently resides with Defendant at her residence as described in Paragraph two (2). Jacob C. Kissinger is four (4) years of age. The child was born in wedlock. The child is presently in the custody of Defendant who resides at the residence as described in Paragraph two (2). During the past five (5) years, the child has resided at all times with Plaintiff and Defendant in the following residences: a. 3 Sussex Drive, Carlisle, PA - September 2007 to current, and b. 325 Juniper St., Carlisle, PA - birth to September 2007. 4. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently does not reside with any other person. 5. The relationship of Defendant to the child is that of Mother. The Defendant current resides with the Parties' son. f 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other State. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff will provide a more stable, nurturing environment for the child. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child, will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests that this Honorable Court grant Plaintiff shared legal custody and primary physical custody of the child. Respectfully submitted, O'BRIEX-RARIC & Robert J. Dailey, ? I.D. 203418 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff CRAIG B. KISSINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO.2008 - 1`{ ((p CIVIL TERM JILL E. KISSINGER, CIVIL ACTION -LAW Defendant IN CUSTODY VERIFICATION I, Craig B. Kissinger, verify that the statements made in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. Craig issinger Date: as of March, 2008 `- 0 ?a - s3 yam Ww:a ; CRAIG B. KISSINGER, Plaintiff V. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - 1416 CIVIL TERM CIVIL ACTION-LAW ACCEPTANCE OF SERVICE AND NOW, this day of 'Xr j,, , 2008, I, Jill E. Kissinger accept A bore ue m-v)a vivoree'C:omp1drft m _ _ to . hk/v"'m ill E. i inger CRAIG B. KISSINGER, Plaintiff V. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - CIVIL TERM CIVIL ACTION -LAW IN CUSTODY ACCEPTANCE OF SERVICE I, Michael J. Whare, Esquire, accept service of the Complaint in Custody on behalf of my client, Jill E. Kissinger, Defendant. I certify that I am counsel for the Defendant in this matter and authorized to accept such service on her behalf. Date: 16- of PLC_ L' , 2008 Michael J. Whare, Esquire Attorney for Defendant ? ' - -- ? _--? -; ? __ - - --° ??r ?. ; -.r, -, _?;, .,. CRAIG B. KISSINGER PLAINTIFF V. JILL E. KISSINGER DEFENDANT AND NOW, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-1416 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT Friday, March 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, April 22, 2008 at 1:00 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/ john . Man an r. Es q. 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 11 tj ill FAR 24 2006r 694 CRAIG B. KISSINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-1416 CIVIL ACTION LAW JILL E. KISSINGER, IN CUSTODY Defendant ORDER OF COURT AND NOW this ZS` day of April 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Craig B. Kissinger, and the Mother, Jill E. Kissinger, shall have shared legal custody of Jacob C. Kissinger, born 06/15/2003. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The parties shall mutually agree on all activities in which the Child is involved. Neither party shall manipulate the Child's activities so as to intentionally interfere with the other parent's physical custody schedule as outlined below in paragraph 3. 3. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's partial physical custody on a two week repeating basis as follows: a. Commencing 4/23/08 the Father shall have physical custody of the Child from after day care 4/23/08 until Friday 4/25/08 whereby Father shall drop the Child off at day care in the morning. b. The Mother shall have physical custody from after day care on 4/25/08 until Monday morning 4/28/08. C. Father shall have physical custody of the Child Monday morning commencing 4/28/08 until Tuesday 4/29/08 morning whereby Father shall drop the Child off at day care/school. Father shall pick the Child up at Mother's residence, or some other mutually agreed upon location, Monday morning and Mother shall notify Father seven days in advance of her work schedule times. d. Mother shall pick the Child up at day care/school 4/29/08 and have physical custody until Wednesday 4/30/08 morning, dropping the Child off at day care/school. e. Father shall pick the Child up at day care/school on 4/30/08 and have physical custody until Thursday 5/01/08 morning, dropping the Child off at day care/school. f. Mother shall pick the Child up at day care/school 5/01/08 and have physical custody until Friday 5/02/08, dropping the Child off at day care/school. . r i .-? g. Father shall have physical custody on 5/02/08 picking the Child up after day care/school until Tuesday 5/06/08 whereby Father shall drop the Child off at day care/school in the morning. h. Mother shall have physical custody from Tuesday 5/06/08 picking the Child up from day care/school until Thursday 5/08/08 dropping the Child off at day care/school in the morning. i. On Thursday 5/08/08, Father shall pick the Child up from day care/school (approximately 4:00 pm) and return the Child to Mother's residence no later than 7:30 pm. j. Mother shall then have physical custody from Thursday 5/08/08 7:30 pm until Monday morning 5/12/08. k. It is understood and directed that once the Child begins school, the Child shall be transported to school by Father on Monday morning following his weekend and Mother shall drop the Child off at school Monday morning with Father picking the Child up from school the Monday following Mother's weekend. 1. All other transportation issues, including the summer vacation weeks outlined in paragraph 11, shall be arranged by the non-custodial parent picking up the Child for the exchanges. M. The schedule outlined in sub-paragraphs 2(c)-O) shall be repeated in subsequent weeks absent mutual agreement or further Order of Court. 4. Holidays and Birthdays: The parties mutually agree to adhere to the holiday schedule as attached. 5. The non-custodial parent shall have telephone contact with the Child four times per week, no later than 8:00 pm. Should the custodial party not be available when the non-custodial parry calls, any calls shall be returned as soon as possible so as to accommodate the non-custodial parent's contact with the Child. 6. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Child. The parties are further directed to not involve/discuss with the subject Child custodial/legal litigation issues or personal issues that the parties may have with one another. 7. In the event of a medical emergency, the custodial party shall notify the other party as soon as practicable after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. Counseling: The parties are directed to engage in co-parenting counseling with a mutually- agreed upon professional. The Mother shall provide a list of names of professionals that are included in her insurance plan and the parties shall mutually choose an appropriate professional. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 10. Neither party shall smoke in confined areas when the Child is present and neither parry shall permit another person to smoke in a confined area when the Child is present. 11. Each parent shall have two non-consecutive weeks of vacation with the Child per year. The requesting parent shall give the other parent at least 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the parry first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand/alter this vacation time by mutual agreement. It is understood that a vacation Bible School week shall constitute one of the parties' two vacation periods if the parties desire. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. 13. A status update conciliation conference is hereby scheduled for June 27, 2008 at 1:00 pm. By the Court, I ?0,k J. Distribution: „Michael Whare, Esq. Robert Dailey, Esq. o J. Mangan, Esq. J HOLIDAYS AND THWES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Da 1 S Half From 8 am until 2 m Father Mother Easter Da 2° Half From 2 m until 8 m Mother Father Memorial Da From 9 am until 6 m Mother Father Independence Da From 9 am until 6 m Father Mother Labor Da From 9 am until 6 m Mother Father Halloween From one hour before trick or Father Mother treating to one hour after trick or treating Thanksgiving I' From 8 am Thanksgiving Day to 2 Mother Mother Half m on Thanksgiving Da Thanksgiving 2n From 2 pm on Thanksgiving Day to Father Father half 4 m the day after Thanksgiving Da Christmas 1St Half From noon on 12/24 to noon on Father Mother 12/25 Christmas 2" Half From noon on 12/25 to noon on Mother Father 12/26 New Year's From 6 pm 12/31 until noon January Mother Father 1St (with the 12/31 year to control the even/odd determination) Mother's Da From 9 am until 6 m Mother Mother Father's Da From 9 am until 6 m Father Father Birthday I" Portion Day of his birthday 9 am until 6 pm Father Mother ( should the Child's birthday be on a weekday and the Child attending school, the period shall be from 4 pm until 8 m Birthday 2° Portion The Saturday following his birthday Mother Father 9 am until 6 m CRAIG B. KISSINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-1416 CIVIL ACTION LAW JILL E. KISSINGER, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Jacob C. Kissinger 06/15/2003 Primary Mother 2. A Conciliation Conference was held with regard to this matter on April 22, 2008 with the following individuals in attendance: The Mother, Jill E. Kissinger, with her counsel, Michael Whare, Esq. The Father, Craig B. Kissinger, with his counsel, Robert Dailey, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John gan, Esquire 11 Cus dy onciliator CRAIG B. KISSINGER, Plaintiff VS. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1416 CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: JILL E. KISSINGER c/o Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 CRAIG B. KISSINGER , Plaintiff intends to file with the court the attached Praecipe to Transmit Record on or after March w f loll , 2011 requesting that a final decree in divorce be entered. DATE: 0 ).1 2.11 ANDREW J. BENDER, ESQUIRE Attorney for Plaintiff PA Supreme Court ID #205763 Allied Attorneys of Central Pennsylv ania, L. L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax 3L* 7c-n' ice' c ca ` ? co c 'T: T s ' CRAIG B. KISSINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2008-1416 CIVIL ACTION - LAW JILL E. KISSINGER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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(d)(1) of the Divorce Code. 2. Date and manner of service of the com lp aint: March 18, 2008 via acceptance of service. 3. Complete either (aor (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff by defendant (b)(1) Date of Plaintiffs execution of the affidavit required by § 3301(d) of the Divorce Code: 02/25/11 ; Date of Defendant's execution of the affidavit required by § 3301(d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff s affidavit upon the respondent: 02/28/11 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: 02/28/11 via U.S. Postal Service First Class Mail to Defendant's Attorney of Record, Michael J. Whare Esquire (b) Date plaintiff's Waiver of Notice was filed with the prothonotary: 02/28/11 ; Date defendant's Waiver of Notice was filed with the prothonotary: DATE: Ol 1f Andrew J. Bender, squire PA Supreme Court ID #205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax Attorney for Defendant 2 CRAIG B. KISSINGER, Plaintiff VS. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1416 CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE The undersigned does hereby certify that, on the date indicated, a true and correct copy of the foregoing Notice of Intention to Request Entry of Divorce Decree was served upon the following person(s) by forwarding same via U.S. Postal Service First Class Mail at the following address(es): DATE: OZ Z? I? Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 Attorney for Defendant ANDREW J. BENDER, ESQUIRE Attorney for Plaintiff PA Supreme Court ID #205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax CRAIG B. KISSINGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2008-1416 CIVIL ACTION LV JILL E. KISSINGER, Defendant IN DIVORCE ? CO - _ AFFIDAVIT OF CONSENT r y CIL The parties to this action separated on March 18, 2008 and have continued8 lives' separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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: CRAIG K SINGER, Plaintiff CRAIG B. KISSINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2008-1416 CIVIL ACTION - LAW JILL E. KISSINGER, ; Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) 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: CRAIG B. KISSINGER, tin rn - r w:7> CO ca x-c w °-T1 ANDREW J. BENDER, ESQUIRE PA Supreme Court ID: 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax _ J ICE ICE CQUNV PE,t dSYLVrNN1A CRAIG B. KISSINGER, Plaintiff V. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1416 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION CLAIM TO THE PROTHONOTARY: Kindly withdraw the Plaintiff, Craig B. Kissinger's, request for Equitable Distribution, which is filed to Count II of the Divorce Complaint filed March 3, 2008. Date: 0 3/124II ANDREW J. BE DER, ESQUIRE Allied Attorneys of Central Pennsylvania, L.L.C. PA Supreme Court ID #: 205763 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax CRAIG B. KISSINGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1416 V. JILL E. KISSINGER, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE The undersigned does hereby certify that, on the date indicated, a true and correct copy of the foregoing Praecipe to Withdraw Equitable Distribution Claim was served on the following individual(s) by forwarding a copy of same via U.S. Postal Service, first class mail, postage prepaid, pursuant to the Pennsylvania Rules of Civil Procedure and local rules: Michael Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 Attorney for Defendant Date: D? A l h l l ANDREW J. BEN ER, ESQUIRE Allied Attorneys of Central Pennsylvania, L.L.C. PA Supreme Court ID #: 205763 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax ANDREW J. BENDER, ESQUIRE PA Supreme Court ID: 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax CRAIG B. KISSINGER, Plaintiff t r. iM- 9 9?- i?TQ?OTA1 11 tr, 22 P 12:3 #'tij110ERLAH0 COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1416 V. JILL E. KISSINGER, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: March 18, 2008 via acceptance of service. 3. Complete either (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff by defendant (b)(1) Date of Plaintiff's execution of the affidavit required by § 3301(d) of the Divorce Code: 02/25/11 ; Date of Defendant's execution of the affidavit required by § 3301(d) of the Divorce Code: N/A ; (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 02/28/11 4. Related claims ending: None. 5. Complete either (a) or (^b). (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: 02/28/11 via U.S. Postal Service First Class Mail to Defendant's Attorney of Record Michael J Whare Esquire (b) Date plaintiff s Waiver of Notice was filed with the prothonotary: 02/28/11 ; Date defendant's Waiver of Notice was filed with the prothonotary: 03/14/11 DATE: 03 2-/j1 Andrew J. Bende , Esquire PA Supreme Court ID #205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax Attorney for Defendant CRAIG B. KISSINGER, Plaintiff vs. JILL E. KISSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1416 CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE The undersigned does hereby certify that, on the date indicated, a true and correct copy of the foregoing Praecipe to Transmit Record was served upon the following person(s) by forwarding same via U.S. Postal Service, first class mail, at the following address(es): Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 Attorney for Defendant DATE: 03 ZZ 1t ANDREW J. BEN ER, ESQUIRE PA Supreme Court ID #205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CRAIG B. KISSINGER CUMBERLAND COUNTY, PENNSYLVANIA V. JILL E. KISSINGER : NO. 2008-1416 DIVORCE DECREE AND NOW, A4-CA Ot , zo) / , it is ordered and decreed that CRAIG B. KISSINGER plaintiff, and JILL E. KISSINGER , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, (fit. O*' rnaikd +Ber r nee + Czpy rnaaec( 4v detf