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
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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
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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
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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
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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
~~
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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
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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,
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