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Home My WebLink About01-6394KERRI J. KIRK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. OI- ~,_~' ROY L. KIRK, 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 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, PA 17013. 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 (800) 990-9108 McNEE_S WALLACE & NURICK LLC D-el'an(~ M~ -Lantz Pamela L. Purdy KERRI J. KIRK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ROY L. KIRK, Defendant : IN DIVORCE COMPLAINT Divorce Under 3301(c) or 3301(d) of the Divorce Code 1. Plaintiff is Kerri J. Kirk who currently resides at 495 B Glenn Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Roy L. Kirk who currently resides at 495 B Glenn Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. 5. parties. 6. 7. Plaintiff and Defendant were married on July 11, 1990 at Izmir, Turkey. There have been no prior actions of divorce or for annulment between the The marriage is irretrievably broken. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Section 3301 (c) or (d) of the Divorce Code. Dated: il I '1ol McNEES WALLACE & NURICK LLC By Delano M. Lantz I. D. #21401 Pamela L. Purdy I.D. #85783 100 Pine Street P, O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff -2- VERIFICATION 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. Dated: Kerri J. Kirk I RECORD OF DIVORCE OR ANNULMENT Cumberland [] (CHECK ONEI [] WiFE HUSBAND Roy L. Kirk .,.T. 0b 01 68 495 B Glenn Street, Mechanicsbura. Cumberland. A.,-.- Illinois o. ~.,s 2 [~ [] Police Officer Robenseifner g~rrl j. Kirk '495 B Glenn Street. M~mh~n~$hurg. C~_~mb~-r!~-nd 04 03 70 c-,~o--,o r-i [] [] [] Pcnnsvlvania 1 [] [] Legal Secretary Izmir Turkey .^..,^~ 07 11 3301 (c) or (d) WALLACE ~ NURICK IOO PINE STREET KERRI J. KIRK, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 01-6394 Civil Term ROY L. KIRK, Defendant : IN DIVORCE PROOF OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce in the above matter was served on the Defendant, Roy L. Kirk, by certified mail, restricted delivery, return receipt requested on November 13, 2001. See Exhibit "A" attached. The Complaint in Divome was received and signed for by the Defendant on November 14, 2001. The original of the return receipt is attached hereto as Exhibit "B". McNEESWAL-'L~E & NURICJ&fLLC~ ~~ I. D. #21401 Pamela L. Purdy I.D. #85783 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: January 7, 2002 McNees Wallace & Nurick attorneys at law PAMELA L, PUP. DY DIRECT DIAL: (717) 237-5479 E-MAIL ADDRESS: PPLIRDY~MWN.COM November 13, 2001 Mr. Roy L. Kirk 495 B Glenn Street Mechanicsburg, PA 17055 Re: Kirk v. Kirk No. 01-6394 Civil Term Dear Mr. Kirk: Enclosed and served upon you is a certified copy of the Complaint in Divorce Under 3301 (c) or 3301(d) of the Divorce Code which was filed of record in the Office of the Prothonotary, Cumberland County Courthouse on November 9, 2001 to No. 01-6394 Civil Term. Very truly yours, McNEES WALLACE & NURICK LLC PLP/msb Enclosure cc: Kerri J. Kirk (w/enc.) CERTIFIED MAIL, RESTRICTED DELIVERY EXHIBIT "A" PO Box 1166 · 100 PINE STREET ° HARRISBURG, PA 17108-1166 · TEL: 717.232.8000 · FAX: 717.237.5300 · WWW. UWN.COM COLUMBUS, OH · HAZLETON, PA · WASHINGTON, DC · C~nplete items 1, 2, and 3. Also complete It~ 4 if Restricted Delivery is desired. · Print your name and address on the revere 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. [] Expc'~=,s Mall [] Return Receipt for MenYnendlee EXHIBIT "B" KERRI J. KIRK, ROY L. KIRK, Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6394 Civil Term Defendant IN DIVORCE AFFIDAVIT OF CONSENT OF PLAINTIFF 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on November 9, 2001 and served on November 13, 2001. 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 the 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: March r~ ,2002 Kerri J Kirk, F~laintiff 159-56-8926 (Social Security Number) KERRI J. KIRK, ROY L. KIRK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6394 Civil Term 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: March r/ ,2002 Kerri J. Kirk, Plair~tiff- - KERRI J. KIRK, ROY L. KIRK, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6394 Civil Term Defendant IN DIVORCE AFFIDAVIT OF CONSENT OF DEFENDANT 1. A Complaint in Divorce under {}3301(c) of the Divorce Code was filed on November 9, 2001 and served on November 13, 2001. 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 the 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. Roy L. Kirk, Defendant Date: March 0'~ ,2002 337-54-3790 (Social Security Number) KERRI J. KIRK, ROY L. KIRK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6394 Civil Term 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: March 0'? ,2002 Roy L. Kirk, Defendant KERRI J. KIRK, ROY L. KIRK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 01-6394 Civil Term : Defendant · 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 a Divorce: 23 Pa. C.S. §3301(c) - Mutual Consent - Marriage irretrievably broken. Date and Manner of Service of the Complaint: Date of service was November 14, 2001. The Complaint was served by certified mail, restricted delivery, return receipt requested on or about November 13, 2001. The return receipt was signed by Defendant, Roy L. Kirk on November 14, 2001, the date the Complaint was delivered to Defendant by the Post Office. A Proof of Service of the Complaint which attached the original green card was filed of record in the Office of the Prothonotary of Cumberland County on January 9, 2002. of the Divorce Code: By Plaintiff (Social Security Number 159-56-8926): Date of Execution of the Affidavit of Consent Required by Section 3301 (c) March 7, 2002 By Defendant (Social Security Number 337-54-3790): March 7, 2002 Related Claims Pending: No claims were raised. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date Plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: N/A , Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: N/A ; McNEES WAt]..ACE & NUI~ICK LLC By ~Lan~~~" I.D. No. 21401 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5348 Attorneys for Plaintiff Dated: March 8, 2002 IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE Of ~ PENnA. KERgI..J.,. ~!...RK ............................................ Plaintiff Versus ...................................... ~n.t ............................. DECREE IN DIVORCE AND NOW, ............ . ./~..~,,.~.../.~..~.., ~t.2. QQ~., it is ordered and decreed that ....~.e.r.r.~..~... ?.~.~.~. ................................. plaintiff, and ....~oy. L.. ~:*rk ........................................... 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; By Th~ Court/ .... ................................................. Att~/