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Home My WebLink About04-1711EILEEN KENESSEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA PE / LOUIS KENESSEY, 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 may proceed without you and a Decree in 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 divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, 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 ANY OF THEM. 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 EILEEN KENESSEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04 - 1711 LOUIS KENESSEY, CIVIL ACTION-LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Eileen Kenessey, an adult individual currently residing at 139 East Cumberland Road, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant is Louis Kenessey, an adult individual residing at 139 East Cumberland Road, Enola, Cumberland County, Pennsylvania. 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 21, 1966, in Annapolis, Maryland. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. This action is not collusive. 7. Plaintiff and Defendant have not yet separated. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c) - The marriage of the parties is irretrievably broken. 9. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 10. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. COUNTI EQUITABLE DISTRIBUTION 11. Paragraphs one through ten are incorporated herein by reference. 12. During their marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Sections 3501 et.sea. of the Divorce Code of 1980. WHEREFORE, Plaintiff respectfully requests this Honorable Court equitably distribute all marital property, both real and personal, owned by the parties. Date: 10 Respectfully submitted, THE LAW OFFICES OF SILLIKER & RdINHOLI 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Eileen Kenessey AFFIDAVIT / f t?SSer , hereby certify that the aforegoing is true and correct to the best of my knowledge, ihformation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: 1? r N !u # ode O „o O c f l ? _ EILEEN KENESSEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-1711 CIVIL TERM LOUIS KENESSEY, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of a Complaint in Divorce was served upon Louis Kenessey on May 11, 2004, by Certified Mail, return receipt requested, addressed as follows: Louis Kenessey 139 East Cumberland Road Enola, PA 17025 I hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities./ Date: VI A``???? Renee Dreisbach ¦ complete Itemii:4, 2, and 3. Also e item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mallpiece, or on the front 'If space permits. . Article Addressed to: 1'ouis Kos 13 9 &5fCc.mi Fho (a tO)? 17U?)? 2. Article Number 7 (rmnsfer from service label) PS Form 3811, August 2001`- A ? Agent X ? Addressee B. Received by (Printed ALO,) C. Date of Delivery D. Is delivery adtlrea%9lfferent ai 17 ? Yes If YES, enter dpl*.* dl _ ? No 3. - Service Type 2916artIfied Mail ? Registered 1I°? \ 4i, 4 ? ? Return Receipt for Mevchandi" 4. Restricted DeIWery7 P&a Fee) 0006 2853 7081 Domestic Return Receipt 102595-01-M-me ry - = t? G -n 'i lT? r f.? T - fT1 ?. [. t ?_ T 4Tl +- f'1 _a .? r_? ;n Gz`? Curtis R. Long Prothonotary Office of toe Vrotoonotarp ?Cum6erCanb ?ourttp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ( !q - j 1 / / 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