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HomeMy WebLinkAbout08-5999., GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY 213 A. Enola Street Enola, PA 17025 SS# 137-58-8437 vs. KEITH A. ULERY 213 A. Enola Street Enola, PA 17025 SS# 207-64-5281 Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. U8- s99q u..? 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 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 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 Cumberland County Courthouse, I Courthouse Square, 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. Lawyer Reference Service Carlisle, PA Phone 717 249-3166 r GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS 213 A. Enola Street CUMBERLAND COUNTY, PA Enola, PA 17025 FAMILY COURT DIVISION SS# 137-58-8437 vs. NO. O Y 5'4 9 9 CA-?;-( .c,.. KEITH A. ULERY 213 A. Enola Street : DIVORCE Enola, PA 17025 SS# 207-64-5281 COMPLAINT IN DIVORCE 1. Plaintiff is Christine D. Ulery, who currently resides at 213 A. Enola Street, Enola, Pennsylvania, Cumberland County, Pennsylvania. 2. Defendant is Keith A. Ulery who currently resides at 213 A. Enola Street, Enola, Pennsylvania, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been a bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 30, 1992 at Philadelphia County, Pennsylvania. 5. 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. -1- .0 COUNTI DIVORCE 6. The prior paragraphs of this Complaint are incorporated by reference. 7. The marriage is irretrievably broken. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a Final Decree in Divorce between the parties. 14?? IM41rl?? eorge Lusk s squire Attorney for Plaintiff ,... 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. Cons. Stat. Ann. Sec. 4904, relating to unsworn falsification to authorities. Date: c c & A: e CHRISTINE'D. ULE GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY 213 A. Enola Street Enola, PA 17025 SS# 137-58-8437 VS. KEITH A. ULERY 213 A. Enola Street Enola, PA 17025 SS# 207-64-5281 Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. : DIVORCE COUNSELING NOTICE UNDER Pa.R.C.P. RULE 1920.45(A)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: 3301(c) Irretrievable breakdown Mutual consent 3301(d) - Irretrievable breakdown Two (2) year separation Where the Court determines that there is a reasonable prospect of conciliation. A list of certain professionals is available for inspection irthe Office of the Prothonotary at Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania, 17013. GEOR LUSKUS, ESQU RE, P.C. George Lus Esquire Attorney laintiff ?( C7 Cam? W ...° ?' R 09 -% vc?' r'.7 c_-a CD cT --4 4] ?T7 --) Fri -C GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE PROOF OF SERVICE George Luskus says that he is the attorney for the Plaintiff, Christine D. Ulery and that he served a true and correct copy of the Counseling Notice and Divorce Complaint, by certified mail, return receipt requested; and that on December 8, 2008 Defendant, Keith A. Ulery did receive it, as evidenced by the signed return receipt attached hereto, made a part hereof, and marked Exhibit "A". Plaintiff is familiar with the signature of Keith A. Ulery, has reviewed the return receipt and has verified that the signature on the return receipt is, in fact, the signature of Keith A. Ulery. George Luskus verifies that the statements made in this affidavit are true and correct upon his personal knowledge or information and belief, and he understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. O GEOR E USKUS Attorney for Plaintiff, Christine D. Ulery Date: c2b 7 d V. EXHIBIT "A" A 8 QonVWte Rants 1, 2, and 3. Abo omnpbte ibm 4 N ReelricW DelWwy Is desired. a Mt your name and address. on the reverse 4~ we can return the cards to you. ¦ Atsach this card to the pack o the maitpiece, or on the front N space pemdts. 1. A409 Addamd to: 2. Ardob NuMber j •7 O 3(- a A..ft x rl (Ptfr?ted Acme) /_Date of DSHWY b d*iwy address x H YES, enter detiwty An 0`,c 3. swwm lype e Ce dit Map O Eepr I MIN O Repbtetsd O Relvrn Reoei?t for Merd', O 6mteed Md O C.O.D. 4. Reedlcted DelMsry? (Ev" Fee) O Yes 7004 0750 0002 7335 6203 I 41k t? c?:. ,?. _ {_ ? r_n -? ? E ?,`-` r ; - - c ??:t _ ; ._ x . J ? i:} r -- ,__ :? ;- GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 6, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.A. Section 4904, relating to unworn falsification to authorities. Date: S-?2 09 ezz-- c J9 4/ CHRISTINE D. ULER a C? ? ? ?.? f ? .Sti c ?? Y ? ?.? r r ? .?- ?tl N ? .. -- cf? GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 6, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.A. Section 4904, relating to unworn falsification to authorities. Date: 3 s 01 C> o lla .? r rn .4. +w. GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. 08-5999 DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail/Return Receipt Requested on December 8, 2009. Proof of Service is attached. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff 3/12/09; by defendant 3/5/09. (b)(1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code% 4. Complete the appropriate paragraph(s): (a) Related claims pending: NONE (b) Claims withdrawn: NONE (c) Claims settled by agreement of the parties: NONE (d) State whether any agreement is to be incorporated into the decree: NONE If so, attach a true and correct copy of the fully executed agreement. (e) Has a request for counseling been made by either party? NO. If so, has the counseling been completed? N/A. 5. I certify that the notice required of Rule 1920.42(d) was mailed on March 25, 2009 and a copy thereof is attached. 6. A proposed Decree is attached. Attorney laintiff George Luskus, Esquire BLED -Cll't ivtt OF 1 -Hr- }=F; j i f 4' JTARY 2009 MAY _g PH 12: 53 CHRISTINE D. ULERY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW KEITH A. ULERY, Defendant NO. 08-5999 CIVIL TERM ORDER OF COURT AND NOW, this 14'h ' day of May, 2009, upon consideration of the praecipe to transmit decree in the above-captioned case, and it appearing (a) that a copy of the notice of intent referred to in the praecipe as "attached" does not appear in the record and (b) that Defendant's affidavit of consent was executed less than 90 days after service of the complaint upon him,' a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiencies and file a new praecipe to transmit. ""George Luskus, Esq. 745 Yorkway Place Jenkintown, PA 19046 Attorney for Plaintiff C-CF7 ,.qnz111CCL 44017 BY THE COURT, J Wesley e , Jr., J. 1 See Pa. R.C.P. 1920.42(b)(1). 4 '? f ?C. ?? ??q ??? ???U??L >rti? GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 6, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.A. Section 4904, relating to unworn falsification to auttoritiq. Date: 510/0 DF THE- r its 20 9..1UN' -3 Fi 1: 13 t GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. 08-5999 DIVORCE PROOF OF SERVICE George Luskus says that he is the attorney for the Plaintiff, Christine D. Ulery and that he served a true and correct copy of a Notice of Intention to Request Entry of Section 3301(c) Divorce Decree and Counter-Affidavit Under Section 3301(c) of the Divorce Code, by certified mail, return receipt requested; and that on June 3, 2009 Defendant, Keith A. Ulery did receive it, as evidenced by the signed return receipt attached hereto, made a part hereof, and marked Exhibit "A". George Luskus verifies that the statements made in this affidavit are true and correct upon his personal knowledge or information and belief, and he understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. GEOR USKUS Attorney for Plaintiff, Christine D. Ulery Date: 6 -- .6 'D ¦ Complete items 1, 2, and 3. Also Complete A. MEm 4 if Reetkied. Delivery is desired. X ¦ P* ft your name and address on the reverse so that we can return the card to you. • Altach fhis card to the hack of the mailpieoe, or on the front N space permits. 1. MU*Temd to: lA-'1 ?jr?ms ?N.cu.?C Aged by (Prlnled fv m) ., 1 C. date en Delbeq Is ddywy address dMferertt from itdn 1? M Yee 1f YES, enter delhwy address below. X No 3 SWWM Type Mao I Eegtreeta Mail /J-- / ?T 17 o pa&tww D lnsurod M ll 0 Rown Receipt for Ntetdunl?e O C D O L41-1 1 a . . . j "7U ro 4. Restricted Wlueryt (Erna Fee) 0 Tires L AAde Number 7004 0750 OOH---7335 6-2-65- PS1Form $811, AdiwV 2M oo. r.atttalwurrtfMosMrt 102595-02 Mane Ln - • - (Domestic -0 For delivery information visit our • . U1 El O?CF t s ?t p !'?i S ?. ? rn F $ W,b1 f-I y, IN T G CerVad Foe i .'o' U ? j _ 2 D C3 pEndorr e n R' eye,;reem 2. wll 'l7 ." 11 NOW a O Ln PA&I tad Derwery Fee (Endorsement RegWreM Qi ?/ O t..e?o...n .ee cme 9: X5.71 (?f?/ n i rv O o -? a or PO Box NO U,-hi Al -j d,1Ai,..1OA EXHIBIT "A" A T T o June 1, 2009 Keith A. Ulery 921 D. Innsbruck Drive Hummelstown, PA 17036 Re: Ulery v. Ulery 08-5999 Dear Mr. Ulery: L A W Enclosed please find a Notice of Intention to Request Entry of §3301(c) Divorce Decree and Counter-Affidavit Under §3301 of the Divorce Code. You do not need to file the Counter-Affidavit unless you wish to claim economic relief. In addition, I enclose a Praecipe to Transmit the Record which I intend to file on June 22, 2009. Thank you. Sincerely yours, George Luskus GL:cf Enclosures Law Offices of George Luskus, Esquire, P.C. 745 Yorkway Place, Jenkintown, PA 19046 phone: 215-886-9030 fax: 215-886-2830 email: george@luskus.com GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. KEITH A. ULERY : NO. 08-5999 DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(C) DIVORCE DECREE To: Keith A. Ulery You have signed a Section 3301(c) affidavit consenting to the entry of a divorce decree. Therefore, on or after June 22, 2009, the other party can request the court to enter a final decree in divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the date in the paragraph above, or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSON AT A REDUCED FEE OR AT NO FEE. LAWYER REFERENCE SERVICE CARLISLE, PA PHONE: 717 249 3166 GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION : NO. 08-5999 DIVORCE COUNTER-AFFIDAVIT UNDER § 3301 (c) OF THE DIVORCE CODE I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses, or other important rights. I understand that I must file my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: Keith A. Ulery, Defendant (Notice: If you do not wish to claim economic relief, you should not file this counter- affidavit.) GEORGE LUSKUS, ESQUIRE, P.C By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. 08-5999 DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail/Return Receipt Requested on December 8, 2009. Proof of Service is attached. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff 3/12/09; by defendant 5/28/09. (b)(1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code% 4. Complete the appropriate paragraph(s): (a) Related claims pending: NONE (b) Claims withdrawn: NONE (c) Claims settled by agreement of the parties: NONE (d) State whether any agreement is to be incorporated into the decree: NONE If so, attach a true and correct copy of the fully executed agreement. (e) Has a request for counseling been made by either party? NO. If so, has the counseling been completed? N/A. 5. I certify that the notice required of Rule 1920.42(d) was mailed on June 1, 2009 and a copy thereof is attached. 6. A proposed Decree is attached. ttorney fo 1 ntiff George Lu s, Esquire Rk0--r r OF THE K °"i "F )NOTARY M9 J0;'j 10 PM 1: 3 3 C U pp GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail/Return Receipt Requested on December 8, 2009. Proof of Service is attached. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff 3/12/09; by defendant 5/28/09. (b)(1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code% 4. Complete the appropriate paragraph(s): (a) Related claims pending: NONE (b) Claims withdrawn: NONE (c) Claims settled by agreement of the parties: NONE (d) State whether any agreement is to be incorporated into the decree: NONE If so, attach a true and correct copy of the fully executed agreement. (e) Has a request for counseling been made by either party? NO. If so, has the counseling been completed? N/A. 5. I certify that the notice required of Rule 1920.42(d) was mailed on June 1, 2009 and a copy thereof is attached. 6. A proposed Decree is attached. Attorney Plaintiff George us, Esquire GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. 08-5999 DIVORCE PROOF OF SERVICE rq C,7 e George Luskus says that he is the attorney for the Plaintiff, Christine D. Ulery and that he served a true and correct copy of the Counseling Notice and Divorce Complaint, by certified mail, return receipt requested; and that on December 8, 2008 Defendant, Keith A. Ulery did receive it, as evidenced by the signed return receipt attached hereto, made a part hereof, and marked Exhibit "A". Plaintiff is familiar with the signature of Keith A. -Ulery, has reviewed the return receipt and has verified that the signature on the return receipt is, in fact, the signature of Keith A. Ulery. George Luskus verges that the statements made in this affidavit are true and correct upon his personal knowledge or information and belief, and he understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: 7 d sGEOR USKUS Attorney for Plaintiff, Christine D. Ulery FE-c" "1? EXHIBIT "A" GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 Attorney for Plaintiff, Christine D. Ulery 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE VERIFICATION OF SIGNATURE I, Christine D. Ulery, hereby verify that I have reviewed the attached return of service, that I am familiar with the signature of Keith A. Ulery and that the signature on the return receipt is the signature of Keith A. Ulery. Christine D. Ulery verifies that the statements made in this affidavit are true and correct upon her personal knowledge or information and belief, and she understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. CHRISTINE D. ULERY ?/?7/v GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION NO. 08-5999 (. j-T DIVORCE a i W AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 6, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.A. Section 4904, relating to unworn falsification to authorities. Date: .r-iZ-o9 ez• 7 c J9 CHRISTINE D. ULER GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 JUN 0 5 2009 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 6, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.A. Section 4904, relating to unsworn falsification Date: Jam! 190?9 n COPY GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 Attorney for Plaintiff, Christine D. Ulery 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA cn_- FAMILY COURT DIVISION ?, VS. n c - NO. 08-5999 j.., !C T ? KEITH A. ULERY - DIVORCE L PROOF OF SERVICE George Luskus says that he is the attorney for the Plaintiff, Christine D. Ulery and that he served a true and correct copy of a Notice of Intention to Request Entry of Section 3301(c) Divorce Decree and Counter-Affidavit Under Section 3301(c) of the Divorce Code, by certified mail, return receipt requested; and that on June 3, 2009 Defendant, Keith A. Ulery did receive it, as evidenced by the signed return receipt attached hereto, made a part hereof, and marked Exhibit "A". George Luskus verifies that the statements made in this affidavit are true and correct upon his personal knowledge or information and belief, and he understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. /GEORUSKUS Attorney for Plaintiff, Christine D. Ulery Date: d, 3. Also complete ery is desirecl. :"draw on the rename r the card to ou l y . !Itte back of the mallpleee by (Pd'n ) , 02 permits. 1. Is delivery address different 6, t 7 ff YES, enter delivery address below: ^ ??Q ?. ?_ T?rpe Mail ©&rio M 1401 aA C? ltegWemd 19 M t m 4 r GM 0 insured Mail ? 00.13. -7613 / 4. RoSbWed lv7 i 7004 0750 OOa2-7335 6-21!1? 1 WIN ,. Lr) 4 ..n RJ .D m ++g .UTTl C-1 M L # u c V S G . a CerOW Fee ?f 0 ReturrtRedeptFee 2, _ _ madc'. p ! D f?tdedDellmyFeeFn ! Lri f ReQWted) i 1 O r e e.e emrme @ Lc a lfp1:-TY!Q O [? b`beet or Po Box Na Br.? :%!4 7J3,6 EXHIBIT "A" A T T June 1, 2009 Keith A. Ulery 921 D. Innsbruck Drive Hummelstown, PA 17036 Re: Ulery v. Ulery 08-5999 Dear Mr. Ulery: L A W Enclosed please find a Notice of Intention to Request Entry of §3301(c) Divorce Decree and Counter-Affidavit Under §3301 of the Divorce Code. You do not need to file the Counter-Affidavit unless you wish to claim economic relief. In addition, I enclose a Praecipe to Transmit the Record which I intend to file on June 22, 2009. Thank you. Sincerely yours, ""/ 4?7?? George Luskus GL:cf Enclosures Law Offices of George Luskus, Esquire, P.C. 745 Yorkway Place, Jenkintown, PA 19046 phone: 215-886-9030 fax: 215-886-2830 email: george@luskus.com GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION : NO. 08-5999 : DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(C) DIVORCE DECREE To: Keith A. Ulery You have signed a Section 3301(c) affidavit consenting to the entry of a divorce decree. Therefore, on or after June 22, 2009, the other party can request the court to enter a final decree in divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the date in the paragraph above, or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSON AT A REDUCED FEE OR AT NO FEE. LAWYER REFERENCE SERVICE CARLISLE, PA PHONE: 717 249 3166 GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 CHRISTINE D. ULERY VS. KEITH A. ULERY Attorney for Plaintiff, Christine D. Ulery COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION : NO. 08-5999 : DIVORCE COUNTER-AFFIDAVIT UNDER § 3301 (c) OF THE DIVORCE CODE I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses, or other important rights. I understand that I must file my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904 relating to unworn falsification to authorities. Date: Keith A. Ulery, Defendant (Notice: If you do not wish to claim economic relief, you should not file this counter- affidavit.) GEORGE LUSKUS, ESQUIRE, P.C. By: George Luskus, Esquire Attorney Identification No. 20856 745 Yorkway Place Jenkintown, PA 19046 (215) 886-9030 Attorney for Plaintiff, Christine D. Ulery CHRISTINE D. ULERY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA FAMILY COURT DIVISION VS. NO. 08-5999 KEITH A. ULERY DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail/Return Receipt Requested on December 8, 2009. Proof of Service is attached. - 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff 3/12/09; by defendant 5/28/09. (b)(1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code% 4. Complete the appropriate paragraph(s): (a) Related claims pending: NONE (b) Claims withdrawn: NONE (c) Claims settled by agreement of the parties: NONE (d) State whether any agreement is to be incorporated into the decree: NONE If so, attach a true and correct copy of the fully executed agreement. (e) Has a request for counseling been made by either party? NO. If so, has the counseling been completed? N/A. 5. I certify that the notice required of Rule 1920.42(d) was mailed on June 1, 2009 and a copy thereof is attached. 6. A proposed Decree is attached. ttomey fo 1 tiff George Lu s, Esquire ?d r ryi if 2 * 2 IN THE COURT OF COMMON PLEAS OF CHRISTINE D. ULERY CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. ULERY NO. 08-5999 DIVORCE DECREE AND NOW, Zbo , it is ordered and decreed that CHRISTINE D. ULERY plaintiff, and KEITH A. ULERY defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, Prothonotary 7 •/G? ? D?f ?o?cs rtcG:?'? ?" ° l?r