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Home My WebLink About09-1620KYLEE R. ODOM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. KYLE E.ODOM, Defendant : CIVIL ACTION - LAW NO. 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 KYLEE R. ODOM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KYLE E. ODOM, : NO. 0 - /l/ a 0 CIVIL, TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Kylee R. Odom, an adult individual currently residing at 2142 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Kyle E. Odom, an adult individual currently residing at 10 Edgehill Lane, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 27, 2007, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301(c) of the Domestic Relations Code. Respectfully submitted, nffie, Esquire r Plaintiff & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ?.1 = - 7 0 .1 KYLEE R. ODOM, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW KYLE E. ODOM, NO. 09-1620 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Bradley L. Griffie, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, Kyle E. Odom, at his address of 10 Edgehill Lane, Shippensburg, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on March 23, 2009. . Gr' ,Esquire o ttorney for laintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this day of 2009 NOTARY BL IC k 1. poll Sk'' '. MOO My CdA1M111fMoA. iitphN Apr 17. 2011 N fDofnesloc Mao bm;?, : No Ins urance Covorage Provide'), .0 Ln Postage $ fl1 ? Certlaed Fee ru O 0 Retum Receipt Fee (Endorsement Required) 0 %MftWd Delivery Fee (Endorsement Required) 13 N Tatal Postage & Fees $ E, O r I-ww TO or PO Box K Z ------- City, State, DWG - cL - -° - -- °--....- -- s Gift f, 2, OW & Aso 11 Ipisle A. Skrakmw ftn4Wvm=wvwmpll?J)dvoryiii-dollpI -7 1-93 All" s P#b t y" rNOWS d on e thg so 00 tare oil 4lure #* card Ao you. B. by (A1 IiWW ?Med a nwl* • Aftch cod to the back of the madow% _ or oq *w* it spew pwmRs. CIAS dhvwy adlsese dMlaewtt bam Nem t? O tiYe t? to d YM m 6m dd y addlses No r. ?3 r /Q ?.>ehi// ZAl z e- & Swim Too )OW 05 OwWW Md E3 P OR'911-mef I / 7o75 7 0 kamed Md o C.O.D. 4. Reehlolad DeMrsey4 #Dftre* mm 2• ArUcbIMPnbw 7007 0220 0002 2526 6247 mwnft4m S w?ce PS Form 1. tl"W"D t"m iAraeitrt 10 -WI5 0 I 1 r t,7 f ? .L w i KYLEE R? ODOM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW KYLE E. DOM, NO. 09-1620 CIVIL TERM Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME hereafter 'tx& a )k-;w KYLE ROSE ODOM KY ROSE MOTTER is hereby given that the Plaintiff in the above matter hereby elects to retake and her previous name of KYLEE ROSE MOTTER. OF PENNSYLVANIA COUNTYi CUMBERLAND : SS On personally satisfactory acknowledg IN ` day of 2009. before me, the undersigned officer. ared Kylee Rose Odom, now known as Kylee Rose Motter, known to me (or ven) to be the person whose name is subscribed to the within document and that she executed the same for the purpose therein contained. NESS WHEREOF, I hereunto set my hand and official seal. Notary Publ ?OtARytt ?E/i ROM t ry MisETT +. C AND ;"' AU FILE J ?F THE 2009 HAY ? 1 Fili (2- C 0 -11 - az? e //. uv JAU , 14k411tlTQY! 11MAO 4180% ?)13duq y' fCA?) +'1'?'i1NCY? t;?p,p,l?iMdl19? ,Ni??t7NCt?i r tot t t iql? t??Ngtti rr1?1MI?M 1!M KYLEE R. (ODOM) MOTTER, Plaintiff V. KYLE E. ODOM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-1620 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 O of the Divorce Code was filed on March 16, 2009 and served on March 23, 2009 as indicated on Affidavit of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: -b2-2q-061 , Kylee It Motter, Plaintiff t 2Qu? ,F?,,t .. P ?? ( ?,, a`? ? ?j;' j?;: `_ ° ._r ?, -?, ?_,?, KYLEE R. (ODOM) MOTTER, Plaintiff V. KYLE E. ODOM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-1620 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE STATEMENTS MADE IN THE FOREGOING 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: ?? Zq_'?X Ky ee R. Motter, Plaintiff Of- TF Y 2009 juf -- I pd 3