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HomeMy WebLinkAbout04-0809TAKIYA KELLER, Plaintiff V. JUN HYON KELLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO.0.1- kOI CIVIL TERM 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 right 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 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 S. Bedford St. Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. TAKIYA KELLER, Plaintiff V. JUN HYON KELLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. ?? y CIVIL TERM COMPLAINT UNDER SECTIONS 3301 (c) & (d) OF THE DIVORCE CODE 1. Plaintiff is Takiya Keller, who currently resides at 103 West North Street Apt. A, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Jun Hyon Keller, whose current residence is 1615 Liholiho Street #406, Honolulu, Hawaii 96822-2906. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 20, 1998 in Elkton, Maryland. 5. Plaintiff and Defendant have lived separate and apart since June of 1999. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests that the court enter a decree of divorce dissolving the marriage. Date: 9/a 5104 VERIFICATION Respectfully submitted, C ? Ertn Chaffin Certified Legal Intern Anne Mac onald-F? - \ Thomas M. Place Lucy Johnston-Walsh SUPERVISING ATTORNEY FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 I verify that the statements made in this Divorce Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date: G 25 Oq 1 ?XX/U Takiya feller TAKIYA KELLER, Plaintiff V. JUN HYON KELLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. CIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in June of 1999, and have continued to live 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 unworn falsification to authorities. ZIZ0104 Date Takiya eller .. 1 .? 1 ( it C: - -- TAKIYA KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JUN HYON KELLER, Defendant : NO. D'y k&l CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Takiya Keller, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date a/05/04 Erin Chafin Certified Legal Intern '^U V E iOX THOMA LACE LUCY JOHNSTON-WALSH Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 r' -' _. .. r Curtis R. Long Prothonotary Office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Qw - e-02 - CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573