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Home My WebLink About08-3305 TERESA H. KESSEL, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :1N DIVORCE BRIAN L. KESSEL, _ Defendant :NO. p$ _ 33p5 Civil lerlh 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 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 TERESA H. KESSEL, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW JN DIVORCE BRIAN L. KESSEL, 33o S C't cry 7?e? ... Defendant :NO. 0,F COMPLAINT AND NOW comes the Plaintiff, Teresa H. Kessel, who, by and through her attorneys, Elizabeth S. Beckley, Esquire, Charles O. Beckley, II, and Beckley & Madden, of Counsel, files this Complaint, in which she avers that: 1. Plaintiff, Teresa H. Kessel, is an adult individual residing at 1439 English Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Brian L. Kessel, is an adult individual residing at 1439 English Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on September 14, 1996. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. §§3301(c) or (d), Plaintiff, Teresa H. Kessel, respectfully requests the Court to enter a Decree of Divorce. DATED: of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 6 2 Respectfully submitted, VERIFICATION I, Teresa H. Kessel, hereby verify that the statements made in the foregoing document 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 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: -a 46- Teresa H. Kes el w m cr.) =. TERESA H. KESSEL, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE BRIAN L. KESSEL, :NO. 08 -- 3305 Defendant ACCEPTANCE OF SERVICE 1, Brian L. Kessel, hereby accept service of the Divorce complaint filed in the above-captioned action. DATED: Brian L. essel c, A N) ,y p ! t4 '? TERESA H. KESSEL, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW JN DIVORCE BRIAN L. KESSEL, Defendant :NO. 08 -- 3305 NOTICE OF INTENTION TO RETAKE PRIOR NAME Notice is hereby given that the Plaintif in the above-captioned matter, a Final Decree in Divorce having not yet been granted, hereby elects to retake and use her previous name of Teresa L. Hamrick and gives written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. §704. L Teresa H. I sel To be Known as: Teresa L. Hamrick COMMONWEALTH OF PENNSYLVANIA ) `??l? )SS: COUNTY OF ' ) I- ? ? On the day of i"? '2008, before me, a Notary Public, personally appeared TERESA H. KESSEL, now known as TERESA L. HAMRICK, known to me or satisfactorily proven to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have set my han d and eal. o u 1'c *(SEALEAL) COMMONWEALTH OF PENNSYLVANIA NOTARUII. SEAL LELUZABETH S. BECKLEY, Notary Pubic ty of Harris Dawhio CoCortanission Al s Match 17, 2009 ?' c, *4 1% TERESA H. KESSEL, Plaintiff V. BRIAN L. KESSEL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE Defendant :NO. 08 - 3305 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 28, 2008. 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 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. Dated: to -15-w Brian L. Kessel r -.6, TERESA H. KESSEL, JN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW JN DIVORCE BRIAN L. KESSEL, Defendant :NO. 08 - 3305 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Dated: 0'1-54 Z ?? Brian L. Kessel a c? ss . 'C3 C- 4/? F.: Ln TERESA H. KESSEL, Plaintiff V. BRIAN L. KESSEL, Defendant JN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE :NO. 08 - 3305 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 28, 2008. 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 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. Dated: Oy-,(K T esa H. Kes ow known as Teresa f TERESA H. KESSEL, JN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW JN DIVORCE BRIAN L. KESSEL, Defendant :NO. 08 - 3305 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 unworn falsification to authorities. Dated: P-ITA? Teres essel known as c? Teresa L. Hamrick f? cC-31a s ?$ p Cl) 4 -- 4Ln ? . am ?- yL C . y h W TERESA H. KESSEL, Plaintiff V. BRIAN L. KESSEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 08--3305 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for the entry of a Decree of Divorce. 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Brian L. Kessel, on June 5, 2008, by him signing an acceptance of service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on October 15, 2008; by defendant on October 15, 2008. 4. Related claims pending: No economic claims raised. 5. (a) Date plaintiff's Waiver of Notice October 15, 2008, and it is being filed contemporaneously herewith. (b) Date defendant's Waiver of Notice October 15, 2008, and it is being filed contemporaneously herewith. DATED: 1of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717)233-7691 Respectfully submitted, for cn 0 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff No.. 2008-3305 VERSUS BRIAN L. KESSEL, Defendant DECREE IN DIVORCE AND NOW, toes 23 , 2e) IT IS ORDERED AND DECREED THAT TERESA H. KESSEL n/k/a TERESA L. HAMRICK , PLAINTIFF, AND BRIAN L. KESSEL , 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 THE COU ATTE T. a PROTHONOTARY 40eov e ??, m - p/