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HomeMy WebLinkAbout09-1107KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff CYNTHIA L. KENNEY, Plaintiff V. PATRICK KENNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (? - 1107 t? tv i l Term CIVIL LAW 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 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: 1 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff CYNTHIA L. KENNEY, : Plaintiff V. PATRICK KENNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 699- / je7 cz„a re" CIVIL LAW DIVORCE COMPLAINT FOR DIVORCE COUNT I Reauest for a No-fault Divorce Under 63301(c) of the Domestic Relations Code 1. Plaintiff is CYNTHIA L. KENNEY, who currently resides at 407 North Filbert St., Mechanicsburg, Cumberland County, PA 17055. 2. Defendant is PATRICK KENNEY, who currently resides at 407 North Filbert St., Mechanicsburg, Cumberland County, PA 17055. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 18, 2006 in York County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. The Defendant is not a member of the armed services and has not been at any time during the marriage (having retired from his employment at the Federal Navy Depot in 2003). 9. There are no minor children borne of the marriage. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(c) of the Domestic Relations Code. DATE: a/i a KEN TH F. LEWIS, ESQUIRE Attorne I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff VERIFICATION I 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 of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 2-119 d CY HIA L. KENNEY -6? W ov r? KENNETH F. LEWIS, ESQUIRE Attorney I.D. 169383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff CYNTHIA L. KENNEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09 -1107 c iv;" Tew PATRICK KENNEY, CIVIL LAW Defendant DIVORCE I accept service of the Divorce Complaint. DATE: ATRICK KENNEY 407 North Filbert St. Mechanicsburg, PA 17055 -0 LC r fA " { 1 V ?.4 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff CYNTHIA L. KENNEY, Plaintiff v. . PATRICK KENNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1107 Civil Term CIVIL LAW DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on February 23, 2009. 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 in Divorce after service of notice to intention to request entry of the decree. 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. t Dated : ? ~ ~ Q 9 ~ CY HIA L. KENNEY ( ~[ -~ ~ c: l~L~if_, r,,-r~~ L~ a;~ CYNTHIA L. KENNEY, Plaintiff v. PATRICK KENNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1107 Civil Term CIVIL LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQIIEST ENTRY OF A DIVORCE DECREE IINDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: ~ ~ g ` C HIA L. KENNEY r'~F Tr-':~ ~- ~ , , ~ ~aY ~~. a. 1D~9~Uu -~ F'i`g ~~ ~ KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff CYNTHIA L. KENNEY, Plaintiff v. . PATRICK KENNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1107 Civil Term CIVIL LAW DIVORCE AFFIDAVIT OF CONBENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on February 23, 2009. 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 in Divorce after service of notice to intention to request entry of the decree. 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. Dated : ,~ ~~~ /" ~/ ~ PATRICK KENNEY ~~ t~ '~i;~~,.. ~. r:~4 "~ ~`t'u ~~' T~'~ ; 1`~'~~ CYNTHIA L. KENNEY, Plaintiff v. PATRICK KENNEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1107 Civil Term CIVIL LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQIIEST ENTRY OF A DIVORCE DECREE IINDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: '~~ ~/~ Q ~ILFC,_., :,~_, r- ~r ~1~°~riV ~'~~' '~'~"~. ~ ~~d I.! .r'o-i1 E 2Q~9 ~~'~ --6 iii ~~ ,~ ,~ ., n. CYNTHIA L. KENNEY V. PATRICK KENNEY NO. 09'1107 Civil Term DIVORCE DECREE AND NOW, ~s ~ o it is ordered and decreed that CYNTHIA L. KENNEY plaintiff, and PATRICK KENNEY , defiendant, 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 Gaims 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Prothonotary By the Court, ~ 11 ~1 • n~' ~-~~ ,mss ~~ .. ~- ,, .~ ~ti ii'1,~ }