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HomeMy WebLinkAbout08-3257TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3 as 7 CIVIL TERM DAVID W. KARNS, : 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 will proceed without you and a decree in 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 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3a57 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Tammy L. Karns, an adult individual whose current residence is 191 Birch Lane, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is David W. Karns, an adult individual whose current residence is 3 South Road, Mechanicsburg, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and the Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and the Defendant were married on June 24, 1985 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or 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, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. The Plaintiff and the Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since December 20, 2004 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff respectfully requests your Honorable Court to enter a Decree in Divorce. Respectfully Submitted, TURD LA PFf-(CES 4s-123A-rl Date Esquire Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. 0?. C20 Date Yammy L. K/arns CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint in Divorce, by certified, return receipt requested, postage pre-paid and by depositing same in the United States Mail, first class, postage pre-paid on the Twenty-third day of May 2008, from Carlisle, Pennsylvania, addressed as follows: David W. Karns 3 South Road Mechanicsburg, PA 17050 TU CES C'a"WLF,"PA 17013 (717) 245-9688 Attorney for Plaintiff ?? ?1 i:'?J ??, -+, r l v? ?•a. ?? .. ? •?} l' ?? P\,y . ? : ?• , ?+? Q ? ? -?, ?'?, ? W r ?' . {i °? ;; ? ; l7 t ? TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3ASq CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER $3301(D) OF THE DIVORCE CODE 1. The parties to this action separated on December 20, 2004 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of marital property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF PA. C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. doos Date Tammy L. Karns TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE DEFENDANT'S COUNTERAFFIDAVIT UNDER $3301(D) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08- CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE VERIFICATION I verify that the statements made in this Counteraffidavit 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 David W. Karns CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Plaintiff's Affidavit Under § 3301(D) of the Divorce Code, with a Defendant's Counteraffidavit under § 3301(D) of the Divorce Code, by certified mail, return receipt requested, postage pre-paid and by depositing same in the United States Mail, first class, postage pre-paid on the Twenty- third day of May 2008, from Carlisle, Pennsylvania, addressed as follows: David W. Karns 3 South Road Mechanicsburg, PA 17050 ICES porPisle, nyder, Esq. 28 treet CaA 17013 (717) 245-9688 Attorney for Plaintiff -TI G'.7 i? C.+J TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3257 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW 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 divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified, Returned Receipt mail delivered on or about May 24, 2008. 3. Date of execution of the Affidavit of Consent: By Plaintiff: June 30, 2008 By Defendant: June 23, 2008 4. Related claims pending: None. Date the Waiver of Notice was filed with the Prothonotary: By Plaintiff: July 1, 2008 By Defendant: July 1, 2008 Date: July 1, 2008 bmitted, .6v Snyder, Esq. Offices Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ('.) ;3 L:_t if ??- t,_ 1. CJ © C3 "C TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3as 7 CIVIL TERM DAVID W. KARNS, : 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 will proceed without you and a decree in 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 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - .3.?57 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Tammy L. Karns, an adult individual whose current residence is 191 Birch Lane, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is David W. Karns, an adult individual whose current residence is 3 South Road, Mechanicsburg, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and the Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and the Defendant were married on June 24, 1985 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or 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, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. The Plaintiff and the Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since December 20, 2004 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff respectfully requests your Honorable Court to enter a Decree in Divorce. Respectfully Submitted, Date Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Tammy L. K/arns- CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint in Divorce, by certified, return receipt requested, postage pre-paid and by depositing same in the United States Mail, first class, postage pre-paid on the Twenty-third day of May 2008, from Carlisle, Pennsylvania, addressed as follows: David W. Karns 3 South Road Mechanicsburg, PA 17050 TU QrTtiSS A 17013 (717) 245-9688 Attorney for Plaintiff S C7 ? b CA> 3 t °? C.r7sf TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3257 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE PROOF OF SERVICE ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we cqn return the card to you. ¦ Attach this card to the back of the mailpiece or on the front if space permits. 1. Article Addressed to: D&? i ci l c? ?rn5 3 Sv"g-h ebo-a PC,- j 7CISo 2. Ankle Number (narrater from sewlce bw A. Sign X ?Agerd ? Addis B. R slued byjPrinted Name) C. Dat of D. Is delive address different from item 1 ? If YES, enter delivery address below: ? No 3. Service Type A Certified Mail ? Express Mail ? Registered ? Retum Receipt for Mer chandfw ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 7001 2510 0009 2827 0152 PS Form 3811, February 2004 n m UP ANum papaipt 102595-02-M-1540 C7 C 's ro? r`f r ?c ?c TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3257 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(d) of the Divorce Code was filed on May 23, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and the parties to this action separated on December 20, 2004 and have continued to live separate and apart for a period of at least two years. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. l L156A ?- yh Date C-amey L.Karns c- C=D TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3257 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 THE FOREGOING 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. (. s?p Date Tammy . Karns a G °: TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3257 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(d) of the Divorce Code was filed on May 23, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and the parties to this action separated on December 20, 2004 and have continued to live separate and apart for a period of at least two years. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. Dat L . Karns C 1 `=l i-•-- --TI i I7 T"' CA.) T-1 O TAMMY L. KARNS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 3257 CIVIL TERM DAVID W. KARNS, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 THE FOREGOING 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. Da David W. Karns N fT!1•. i_ _ C'7 s't1 i _- -77 YS -- f? rr CA) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Tammy L. Karns Plaintiff VERSUS David W. Karns Defendant No. 08-3257 DECREE IN DIVORCE AND NOW, 2008 , IT IS ORDERED AND DECREED THAT Tammy L. Karns AND David W. Karns ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; 7 ,tla u ? URT: : BY XO/lq ATTE w J. ROTH O N OTA RY ??'? ? ` ?I'?'??°?' ;tea -?? a ?