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Home My WebLink About09-3859Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff TINA M. MUNKITTRICK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. KEVIN W. MUNKITTRICK, Defendant NO. 09 - 3859 Civic 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 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 the Cumberland County Courthouse, Carlisle, PA. 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 AMELA L. URDY ATTORNEY FOR PLAINTIFF Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff TINA M. MUNKITTRICK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. KEVIN W. MUNKITTRICK, Defendant NO. O9- 3559 ?t IN DIVORCE COMPLAINT IN DIVORCE COUNTI Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Tina M. Munkittrick who currently resides at 546 Meadowcroft Circle, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Kevin W. Munkittrick who currently resides at 2248 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 16, 2005 at Dillsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are: Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. WHEREFORE the Plaintiff requests this Court to enter a decree of divorce under Section 3301(c) of the Divorce Code. Respectfully submitted, Pamela L. Purdy Attorney for Plaintiff ??? Dated: PuAt-A VERIFICATION I 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 are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: G 1E1 61 ina M. Munkittrick OF THE PRO-rp OTAR 2009 JUN 10 Pty 2: 2 3 PFN1 'Syu,Al ;'liA $33$. 5o PO A" Y CK.?' i355 0 IN THE COURT OF COMMON PLEAS OF _"'COUNTY, PENNSYLVANIA TINA M. MUNKITTRICK, ) Plaintiff ) NO. 2009-CV-3859-DC 1 A.3 / G .. KEVIN W. MUNKITTRICK ) CIVIL ACTION- LAW i, Defendant ) IN DIVORCE y?Q ACCEPTANCE OF SERVICE N i, Timothy J. O'Connell, Esquire, accept service of the Complaint in Divorce on behalf of Kevin W. Munkittrick, Defendant in the above- captioned action, and certify that I am authorized to do so. Date: I Ti y j. 0' nell, Esquire 14 4701 orth Front St. Harrisburg, PA 17110 Telephone: (717) 232-4551 Counsel for Defendant, Kevin W. Munkittrick RLED-JWFICE QF Tft PROTHONOTARY 209 JUN 29 Phi 3= 28 OA48& i u 4i C?UNW PENNSYLVANIA 0 ~~ FILCf _,. ,,~,~; _,i~ 'fir ~-?~ #~ , -; ~ ;'`;~~Y ZDlO ,~~;~ 25 ~~ i0~ ~8 CU~~i~~: ~:~:., . .;~.:.:;.1N tY i~~i 9~~~SYI.~I;~,I~li.~ Pamela L. Purdy, Esquire 308 North 2"d Street, Suite 200 P.O. Box 11544 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax Attorney I.D. #85783 TINA M. MUNKITTRICK, Plaintiff vs. KEVIN W. MUNKITTRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-CV-3859 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW AS COUNSEL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw the appearance of Pamela L. Purdy, Esquire, as counsel for the Plaintiff in the above-captioned action. Z~ ~~~ D e Pamela L. Purdy CERTIFICATE OF SERVICE The undersigned hereby certifies that on th~~ day of June, 2010 a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Timothy O'Connell, Esquire Turner & O'Connell 4701 North Front Street Harrisburg, PA 17110 Tina M. Munkittrick 546 Meadow Croft Circle Mechanicsburg, PA 17055 A Pamela L. Purdy, E ire QF Cu41 Davit fD. Buell- , <9, 1 Renee Simpson z Prothonotary : _ D 1St Deputy Prothonotary Ki ks S , ..�� , it ohonage Q �:�� N�f Irene E. Morrow Solicitor 7750 n 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania 6Q -3Rg9 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291H DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • c'ax(717)240-6573