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Home My WebLink About09-2106Paul Leroy IGesow PLAINTIFF, ) V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Revchell Ramirez Kiesow ) NO. DEFENDANT ) &9 -02/ 6(o c .j,-t +crm- NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 CHILD(REN). WHEN THE GROUND FOR THE DIVORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT , PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY, LAWYERS 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. LAWYERS REFERRAL SERVICE Telephone: ( ) For Petitiofier / Address: 2002 Warren Way Mechanicsburg PA 17050 Telephone: 717-364-9660 Paul Leroy Kiesow PLAINTIFF, V. Reychell Ramirez Kiesow DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO: c -16 6 ?tlh. COMPLAINT IN DIVORCE AND NOW COMES, the Petitioner, Paul Leroy Kiesow, by FILING PRO SE, who files this Complaint in Divorce statement of which is as follow: The Petitioner is Paul Leroy Kiesow, an adult individual currently residing at 2002 Warren Way Mechanicsburg PA 17050. 2. The Defendant is Reychell Ramirez Kiesow, an adult individual currently residing at 6176 Spring Knoll Dr. Harrisburg PA 17111. 3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Petitioner and Respondent were married on date: January 24, 2004 in the Philippines. There is 1 child born of this marriage. Name(s) Jake Otis Kiesow Birthdate: 10-21-2005. Neither party is a member of any branch of military. The marriage is irretrievably broken. The Petitioner, Paul Leroy Kiesow, respectfully requests this Honorable Court to a grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code Respectfully kited, Name: Paul LetoZKiesow Full Address: 2002 Warren Way Mechanicsburg PA 17050 Telephone Number 717-364-9660 I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject to penalties of 18 S.A. Section 4904, relating to unsworn falsification to authorities. "/ Dated Z l Z -tP ? ? q s tai A :;o G N ` ''5 ? Paul Leroy Kiesow PLAINTIFF, V. Reychell Ramirez Kiesow DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION (NO: ACKNOWLEDGEMENT A complaint in Divorce under Section 3301 (c) of the Divorce code was filed on agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. IN WITNESS WHEREOF, I sent my hand and seal this a day of QQ,4(l . 2001. Name Reychell Ramirez Kiesow On this day of d9ex-1 9 IN WITNESS WHEREOF, I hereunto set my hand and official seal. n t ?s ay o 200 before me, a Notary Public, the undersigned officer, personally appeare Reychell Ramirez Kiesow, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. i Notary Public WEALTH OF PENNSYLVANIA Nflkm? 7Ckjot4nm d * Ca WdNlM E j*», 9D10 Merobsr, Penn A ftmAftmWt on of Notartss Paul Leroy Kiesow PLAINTIFF, V. Reychell Ramirez Kiesow DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION (NO: ACKNOWLEDGEMENT A complaint in Divorce under Section 3301 (c) of the Divorce code was filed on agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. IN WIT ESS WHEREOF, 1 sent my hand and seal this -Z4-? day of 200 Name aul Leroy Kiesow On this day of J&j '200 9 , before me, a Notary Public, the undersigned officer, personally appearedWhoW Paul Leroy Kiesow, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public COMMONWEALTH OF PENNSYLVANIA I'M ''So Lym K Soh d* Nobly Pd* CII? Of %WW u% Ow0* 0=* *Cmwh Ion 8Vh* j,Iy 11, 2010 Member Psnneylvenie Aeecdedw at NoW1se Paul Leroy Kiesow PLAINTIFF, ) V. Reychell Ramirez Kiesow ) DEFENDANT ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 69- -It G6 MILITARY AFFIDAVIT I, Reychell Ramirez Kiesow {full legal name), Defendant, being sworn, certify that the following information is true: [Mark all that apply] I am not on active duty in the armed services of the United States. I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. / lC? DATED:O , O ? 4 jy, i ature of Defendant Printed Name: Reychell Ramirez Kiesow Address: 6176 Spring Knoll Dr. City, State, Zip: Harrisburg PA 17111 Telephone Number: 717-982-1055 Fax Number: STATE OF PENNSYLVANIA'S , .? COUNTY OF GW4ffERttCfM 4 On the P/ day of , 20 oO9 , before me, a Notary Public, personally appeared eychell Ramirez Kiesow, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. cONNr+oNwEALTH O PENNSYLVANIA IN -''&W Lynn K Sdv i* Ndrry Pd& My Of HmWx % DWOM Canty Tiny 0wvrkmbn EtpY=J* 11, 2010 Uamhar_ ParmavivaNa Assock im of Ntftadss IN WITNESS WHEREOF, I have hereunto t my hand and seal. No Public / FILED-CE OF THE PROll-C^nTAR( 2H9 APR -3 FH Z: 57 YYM?L r i,- ND +?OU f T f PDASYLVANIIA. Paul Leroy Kiesow PLAINTIFF, ) V. Revehell Ramirez Kiesow ) DEFENDANT ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. D / -'2-t 6 & ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE PLEASE take notice that I, Reychell Ramirez Kiesow, Defendant, was provided with a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept service of same. I further enter my appearance in this acti n for all purposed. 61,5W i - pi? e ndant Address: 6176 Spring Knoll Dr. Harrisburg PA 17111 Telephone: 717-982-1055 I t FfLEK4-fCE OF THE MOT, t40NOTARY 1009 APR -3 PM 2: 57 CUM ; +ur 14 '4) COUNTY r D4NS V IA Name: Paul Leroy Kiesow Address: 2002 Warren Way City: Mechanicsburg Telephone: 717-364-9660 PA Zip: 17050 Email (x.i- -n aa?? l ?o 35Phof"ei?' / - _ o.m Paul Leroy Kiesow IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CV ??j-?lO?o crff Reychell Ramirez Kiesow . . CIVIL ACTION - LAW Defendant PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: Pursuant to Pa.R.C.P. No. 240, 1 hereby certify that I am without financial resources to pay the costs associated with my case, and therefore believe that I am entitled to proceed in forma pauperis. In support of my petition, I have attached to it a certification of indigency and incorporate it herein by reference, a certification which fully and truthfully describes my overall financial condition at the present time. WHEREFORE, the undersigned asks leave of court to proceed in forma pauperis, without the need to pay any costs in connection with the instant action. Respectfully submitted, '11-2-0 ? 7, e /?i ? Date Si natu of Petitioner ?? { ?? t W ??, ?'G d"? 1 M Name: Paul Leroy Kiesow Address: 2002 Warren Way City: Mechanicsburg , PA Zip: 17050 Telephone: 717-364-9660 Email: a r'rv, u d; I o 3.5 LC 4otr",-/, co, Paul Leroy Kiesow IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CV Reychell Ramirez Kiesow CIVIL ACTION - LAW Defendant CERTIFICATE OF INDIGENCY 1. I am the Plaintiff Defendant) in the above matter and because of my financial condition, I am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. 1 am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Paul Leroy Kiesow Address: 2002 Warren Way l V Mechanicsburg PA 17050 Social Security Number: 264-84-4282 (b) Employment: If you are presently employed, state (c) Employer: Central Pennsylvania College Address: Cr---p -s vn ??/lege bill Valley ka kd5 Sa-, r" erd I-e PA 1-70737 G J J -3 Salary or wages per month: Type of work: D a ., - l i n,,-e ?e a J1 If you are presently unemployed, state Date of your last employment: Salary or wages per month: Type of work: Other income within the past twelve (12) months Business or profession per month: h/a Other self-employment per month: 0 Interest per month: 0 Dividends per month: 0 Pensions and annuities per month: 0 Social Security benefits per month: n /u. Support payments per month: Disability payments per month: 0 Unemployment Compensation and supplemental benefits per week: Yl /A Workers' Compensation per month: n ti Public Assistance per month: 0 14 I r Other per month: 1 8 (d) Other contributions to household support Wife/Husband Name: lie Sa 't,-r If your wife/husband is employed, state: Employer: /a Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: (e) Property owned Cash: I 6r (f) Checking account: Yb DF 5,5- a 6 Savings account: 7 U Certificates of deposit: Real estate (including home): u Motor vehicle: Make: P°,"7'4 -C Year: /1,73 Cost: 1 0 & 5_0 Amount Owed: o Stocks; bonds: o Other: 0 Debts and obligations - average per month Mortgage: o Rent: 8 o j Loans: Other: u ?-i 1 f, H .- J 3 3 .-, (g) Persons dependent upon you for financial support Wife/Husband Name: ?e ?h P 11 l?? s .? Children, if any: Name: LLA'ke 0, K i e s 3 -w Age: 3 WUde S. 1'eSo 9 IJreio P, 23ow V ?/ l 1 l G..vc /• R/ e j J W / "71 Other persons dependent upon you for financial support (such as parents, grandparents, etc.): Name: Relationship: 4. 1 understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements herein are being made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dat Signature Petitioner ca -ra ?t C1'1 rf2 ? ?y f ? ,,.+ ?^' 7 ?' 4 """"???.. w.? 0 9 -.2-10 6 REQUIRED INFORMATION TODAY'S DATE 41 -3 -o g Plaintiff Cumberland County Domestic Relations Department Income and Expense Statement Name: Paul Lerov Kiesow PA Date of Birth 06/12/1952 SS# 264-84-4282 Phone #717-364-9660 Home Address 2002 Warren Way_ Mechanicsburg PA 17050 Drivers License # 28 !Y2-1 141 Employer Central Pennsylvania College Position yar-f-f?m f-e-ack.zc Address u s Collefe 6111 e r u m a Phone Number q c - Z 2 Date Employed /o o 6 Other Employment non 2 Health Insurance Company Name n/a Policy # Address Group # 1. Check Method of Payment and List Gross Income: Paid: ? Every 2 weeks [ Twice Monthly ? Monthly ? Weekly $ /j 3 8 6 Gross Income 2. Subtract tax deductions: Federal Income Tax Social Security State Income Tax Local Income Tax Health Insurance Union Dues Pension Contributions Credit Union Other Deductions Total Deductions $ 8 /06 22 rc% h ?u a Subtract Totals from Gross Income NET INCOME ALL OTHER INCOME List any interest dividends, pensions and annuity, Social Security, net income from property, Unemployment Compensations, Workmen's Compensation or other, such as royalties, expense accounts, gifts, etc. (if no other income check none) NONE Total Other Income Deduct Estimated Income Taxes on such Other Income Final Net Income Per Week C-t rn? a s r i ,. ,? f.? $? C? • 7 ?e?, log REQUIRED INFORMATION TODAY'S DATE Defendant Cumberland County Domestic Relations Department Income and Expense Statement Name: Revchell Ramirez Kiesow Date of Birth 11/18/1984 SS4 166-84-6746 Phone 4717-982-1055 Home Address 6176 Spring Knoll Dr. Harrisburg PA 17111 Drivers License # Employer UPS Uet erg n Io., e d Position Address Phone Number Date Employed Other Employment t Health Insurance Company Name /1 ?1 Z Policy # Address _ Group # 1. Check Method of Payment and List Gross Income: Paid: 0 Every 2 weeks ? Twice Monthly ? Monthly ? Weekly $ Gross Income 2. Subtract tax deductions: Federal Income Tax $ Social Security State Income Tax Local Income Tax Health Insurance Union Dues Pension Contributions Credit Union Other Deductions Total Deductions Subtract Totals from Gross Income 0 NET INCOME ALL OTHER INCOME List any interest dividends, pensions and annuity, Social Security, net income from property, Unemployment Compensations, Workmen's Compensation or other, such as royalties, expense accounts, gifts, etc. (if no other income check none) NONE Total Other Income Deduct Estimated Income Taxes on such Other Income Final Net Income Per Week ' ? ? ? -4Rtt7? 3.li O tt s w '? • APR 0 6 200 6 Paul Leroy Kiesow Plaintiff V. Reychell Ramirez Kiesow Defendant IN THE COURT OF COMMO PLEAS CUMBERLAND COUNTY, PENNS LVANIA NO. CV CIVIL ACTION - LAW P AND NOW, this 13 ` day of ?& ,' b 20VI, upon presentation and consideration of the within petition and attached certification, we grant the relief prayed for, and grant Petitioner leave to proceed with thi case in forma -P) - pauperis, without the need to pay anyAcots connected therewith, all of which is pursuant to Pa.R.C.P. No. 240. BY THE COURT: JU ?! y 1 LZ ?8 Wtl S 1 HAV 60OZ 3Hi 30 3001