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HomeMy WebLinkAbout09-106716- 1 . . Susan L. Nutting Plaintiff V. Kenneth M. Nutting Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- /661 CIVIL TERM 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 of divorce or annulment may be entered against you by the Court. A judgment may also he 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 ol' your children. When the ground for divorce is indignities or irretrievable breakdown of the marriaLIe. You may request marriage counseling. A list of marriage counselors is available in the OPl'ice of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvaria. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMEN'C 1S 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 TELEPHONF,, THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAI, HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Susan L. Nutting Plaintiff V. Kenneth M. Nutting Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- ) 6?` CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is S ,"Cv) L Cl)tat i Y?-, who currently resides at u5 5.1,?,?sar Si t6tIIiJIe PA 11o13 -- Cumberland County, Pennsylvania. 2. Defendant is YiennE- h M - NLAb Y\3 who currently resides at Ill S- MYYM?A Cove P-.D 02CAC4 1 C41 d W ' 11.1110 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on I - 2?G -08 _ at 6 6S f , (?A 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ,I' ? ?0 -oy C&\ A - Date Plaintiff, Pro Se I, -U-, irV I_ b0i+11'-\C verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: ,6u,r, A Plaintiff, Pro Se Assisted by: Michael A. Scherer, Esq. O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 f7z > t•,_ Susan L. Nutting : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- J 6 6 -7 CIVIL TERM Kenneth M. Nutting Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Susan L. Nutting, Plaintiff, to proceed in forma au eris. I, Michael A. Scherer, attorney for the party proceeding in forma paiperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. t Michael S. Scherer, Esquire Attorney for Plaintiff O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 ?? <'? t? : ?? r-_ C-, ?? . -,-?, ? ? '?? `?.: ,, _. :. -={ r?..> ?.4, Susan L. Nutting IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 09- l (?2(p7 CIVIL TERM Kenneth M. Nutting Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Kenneth M. Nutting- (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 31310 /,-y kt Date Kenneth M. Nutting, Defer t s? cr+ Susan L. Nutting IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- CIVIL TERM Kenneth M. Nutting Defendant IN DIVORCE AFFIDAVIT OF CONSENT complaint in divorce under 53301(c) of the Divorce Code was filed on 2. The man-iage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: c7 Signature: 27 Kenneth M. Nutting, D ndant ?ILEC?::??=? ?c OF THE 2003 JUR 30 AM 10: 4 0 Susan L. Nutting Plaintiff V. Kenneth M. Nutting Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- \ © L" CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 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. Date: Signature: e Kenneth M. Nutting, efendant 2009 JUIN 30 AM 10, 4 CUd? r 1'r?P Susan L. Nutting IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- I (?CQ-7 CIVIL TERM Kenneth M. Nutting Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on rP_bf?3aru I. 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: Signature: 6LAOCAA Susan L. Nutting, Plaintiff OFD ;. 1rV'y 2009 ju --2 PHI 3: i4 CuI Susan L. Nutting Plaintiff V. Kenneth M. Nutting Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 10&-7 IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 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. Date: Signature: . &w; Susan L. Nutting, Plaintiff FILED OF THE P71"I""-f 20U9 JUIL -2 PIN '.J, 4 ?' b SUSAN L. NUTTING IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION KENNETH M. NUTTING ; NO.?}q -10V ? CIVIL TERM Defendant PRAECIPE TO TRANSNUT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under 3301 (c) 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section) Date and manner of service of the complaint: re Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: &L,? - by defendant \ by plaintiff b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: 04) 6 ,\ S O (](e?? rN C?. Complete either (a) or (b) a. Date and manner of service of the notice of intention file praecipe to transmit record, a copy of which is attached: b. Date of plaintiff's Waiver of Notice in 33 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: M om(e ; r laintiff/Defendant OF THE ;r rrt. r?T 1f 2009 JUL -2 PM 3: 44'