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HomeMy WebLinkAbout01-6447CHRISTOPHER J. KARRASCH, Plaintiff KATHLEEN A. KARRASCH, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- /,14¥7 CIVIL TERM : CIVIL ACTION - LAW : 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 divome 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the 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 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, Pennsylvania 17013 (717) 249-3166 CHRISTOPHER J. KARRASCH, Plaintiff KATHLEEN A. KARRASCH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-/~¥~7 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Christopher J. Karrasch, through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Christopher J. Karracsh, is an adult individual who currently resides at 3 Butterchum Lane, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant, Kathleen A. Karrasch, is an adult individual who currently resides at 121A Third Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 10, 1990 in Bradford, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiffand Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Christopher J. Karrasch, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. lly submitted, Attomey for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX 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. ~HRISTOPHEi~ J. KARRASCH,~P~intiff MISMTSKY AND DIEHL ONE WEST HIGH STREET, SUITE 208 CARLISLE, PEN~-~YL'~IA 17013 CIIRISI'OPHI(II ,I. KARRASCIt, l~laintiFf KAIHI,1A, A, KARRASCI1, Defendant : IN Tile COURT OF C()MMON PI,EAS O1: : CUMBERLAND COUNTY. PENNSYI,VANIA : NO. 2001-6447 CIVII~ TI:,P,M : CIVIl, ACTION - I~AW :IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 19~h day of November 2001. comes Thomas S. DieM, Esquirc. Attorney for the PlaintilT, Christopher J. Karrasch, and states that he had cause to be mailed a ccrtificd copy ol'a Complaint in Divorce to the Dcfcndant, Kathleen A. Karrasch, by certified, restricted dclivcry, return-receipt rcqucstcd. A copy of said rcceipt is attachcd hcrcto indicating service was made on November 16, 2001. Respectfully submittcd, l'h~0r~ras ~i Diehl ' Attorney for the Plaintiff One West lligh Street, Suite 208 Post ()fficc Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ON [] Lg~' 08L8 IO00 OL9I 000~'~''~''e~'~ CHRISTOPHER J. KARRASCH, Plaintiff KATHLEEN A. KARRASCH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6447 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 13, 2001. 2. The marriage of the 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unswom falsification to authorities. Date: ~Z?,~?/d ~_- CHRISTOPHER/J. KARRASCH~-Plaintiff 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 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. § 4909 relating to unswom falsification to authorities. D ate: PA~ ~ ~/~Mr.s~/~ CHRISTOPHER J~. KARRASCH, Plaintiff tAW OFFICES OF MISLITSKY AND DI£HL ONE WEST HIGH STREET, SUITE 208 CARLISLE, PENNSYLVANIA 17013 TELEPHONE (717) 2&0-0~33 FAX (717) 240-0893 CHRISTOPHERJ. KARRASCH. Plaintiff · ~ N KAq HI,EE A. KARRASCH, Defendant : IN 'FILE COURT OF COMMON PI.EAS : CUMBERLAND COUNTY. PENNSYLV~ : : NO. 2001-6447 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under §3301(c) of the Divorce Code was November 13, 2001. 2. The marriage of the Plaintiff' and Defendant is irretrievably broken an (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 ~ intention to request entry of the Decree. I verify that the statements made in this affidavit are true and correct. I unders false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to falsification to authorities. KATHLEEN A. KARRASCH, Dell WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A D1VO DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divorce without notice. 2. I understand that I ina),' lose rights concerning alimony, division of 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 entre Court and a copy of the Decree will be sent to me immediately after it is filed Prothonotary. I verify that the statements made in this affidavit are true and correct. I under false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating falsification to authorities. Date: KATHLEEN . KARRASCH, De LAW OFFICES OF MISLITSKY AND DIEHL ONE WEST HIGH STREET, SUITE 208 CARLISLE~ PENNSYLVANIA ] 7013 TELEPHOIN~E (7~7) 2~0-08:33 FAX (717) 240-0893 CHRISTOPHER J. KARRASCI Plaintiff KATHLEEN A. KARRASCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO[JNTY, PENNSYI,V,ANIA NO. 2001-6447 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce tinder ~.330l(c) of the Divorce Code was flied o~: November 13, 2001. 2. The man'iage of thc PlaintilT 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 off intention to request entry of the Decree. I verify that the statements made in this affidavit are trne and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unsworn fhlsification to authorities. KATHLEEN A. KARRASCH. Defendant 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 in Divorce without notice. 2. I understand that I ]nay' 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 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. § 4909 relating to unsx~orn falsification to authorities. Date: ~ , ~1 ,,~, '~",., ,~. , :;}"~,!':r I .A~I: ~, .... ~?':','~'!.~ !i~ I 5'_ .' . KA~I'HLEEN A. KARRASCH. Defendant LAW OFFICES OF MISLITSKY AND DIEHL ONE WEST HIGH STREET, SUITE 208 CARLISLE, PENNSYLVANIA 1 7013 TELEPHONE (717) 240-0833 FAX (717) 240-0893 CttRISTOPHER J. KARRASCH, Plaintiff KATHLEEN A. KARRASC! 1, Defendant IN TI tE COURT OF COMMON PI,EAS CUMBERLAND COUNFY. PENNSYI,VANIA NO. 2001-6447 CIVILTERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under s:~:(~ s ....(c) of the Divorce Code was filed November 13, 2001. 2. The marriage of the 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. § 4909 relating to unswom falsification to authorities. KATHLEEN A. KARRASCH, Defendant 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 in 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 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. {} 4909 relating to nnsv, om falsification to authorities. Date: ' :i -1~.. t:;' ';)- ¢:,..!'!':i' { ..i:,[~!;,L il, ~ cJz,~(i! ~.i~ : . KNi'HLE}~N A. KARRASCH, Defendant CHRISTOPHER J. KARRASCH, Plaintiff KATHLEEN A. KARRASCH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6447 CIVIL TERM : : CIVIL ACTION - LAW : 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 § 3301(c) .... ~,~'-~ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on November 16, 2001 by certified, restricted mail signed for by the Defendant. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by the Plaintiff.' February 18, 2002; by the Defendant: February 16, 2002. (b) (1) Date of execution of the Plaintiff's Affidavit required by § 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 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 to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by § 3301(c) of the Divorce Code: by the Plaintiff.' February 16, 2002; by the Defendant: February 16, 2002. Date: March 4, 2002 Thomas S. Diehl, Esquire Attorney for Plaintiff DIVORCE INFORMATION SHEET ~URSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1, 2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: DATE OF MARRIAGE: IN The COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~~ PENNA. CHRISTOPHER J. KARRASCI':f-~ '~! '''~'*~ '~ Plaintiff N o. 2001-6447 VERSUS kathlEeN a. kARRASCh, Defendant DECREE IN AND NOW, DECREED THAT CHRISTOPHER J. KARRASCH , PLAINTIFF, KATHLEEN A. KARRASCH AND , 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.