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HomeMy WebLinkAbout09-5033ERIN JUNKINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. N -60M5 CIVIL TERM SCOTT JUNKINS, CIVIL ACTION - LAW Defendant 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 ._ BOM & LITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 ERIN JUNKINS, Plaintiff V. SCOTT JUNKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09- S033 CIVIL. TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Erin Junkins, who currently resides at 1545 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Scott Junkins, who currently resides at 1545 Longs Gap Road, Carlisle, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on September 14, 2002, at Assateague Island, Virginia. COUNT I - DIVORCE 4. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since January 1, 2009 and continue to do so. 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 such counseling. 8. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, ABOM & KUTULA"S, L.L.P. DATE I 2-Z 109 l?Gy -Ti'I? • ? ,L Kara W. Haggerty, Es Supreme Court ID No. U 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, ERIN JUNKINS, verify that the statements made in this Divorce Complaint 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. § 4904 relating to unsworn falsification to authorities. Date I LIK I fa411)A v ERIN JUNKINS Al FG-iYFICC- OF THE n-, n?4RY 2009 JUL 23 PH 3: 31 CUP,? L +:_fv VTy $338.50 PO A-n-Y CL V 101 2T# Ia8377 AM & TULAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 ERIN JUNKINS, Plaintiff V. SCOTT JUNKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09-5033 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this 28th day of July, 2009, I, Marylou Matas, Esq., hereby certify that I did receive and accept service of the Complaint in Divorce in the above captioned matter on behalf of the Defendant, Scott Junkins, and I further certify that I am authorized to do so. DATE Z ?? Marylo t s, Esquire FILED-OFF ,a: TAR 2009 JUL 29 AN 9: C I ERIN JUNKINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 09-5033 SCOTT JUNKINS, CIVIL ACTION - LAW Defendant IN DIVORCE PRA.ECIPE TO WITHDRAW NOTICE TO RESUME PRIOR SURNAME To the Prothonotary: Kindly withdraw the Notice to Resume Prior Surname that was filed in the above-referenced matter. Respectfully submitted, ABOM& KUTULAIUS, L.L.P. Date. Kara W. Haggerty Supreme Court ID 6 14 2 West High Street Carlisle, PA 17013 (717) 249-0900 FILE `r 2009 AUG 31 °s 2: 2 3 cum, Mom CSC' U uLAKIS Kara W. Haggerty, Esquire Attomev I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 ERIN JUNKINS, Plaintiff V. SCOTT JUNKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09-5033 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on May 16, 2006. 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 this 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: JI ll ?U 1 ?? FiLED--On CE OF THEE PROTHONOTARY 2004 NOV -3 PM 3: 58 ?uc:a s;N Ty Aom cSZ TLiLAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 ERIN JUNKINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. SCOTTJUNKINS, Defendant NO. 09-5033 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the 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 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 this 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: 101 J 0 1 o g BLED-C)i iCE p THc PIiC 7!nNOTARY 2009 NOV -3 PM 3* 58 CU?vI . UilTY rtiE'1'4'N ERIN JUNKINS V. SCOTT JUNKINS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N O. 09-5033 DIVORCE DECREE AND NOW, ~-,~ ~.-, Z 3 Z v t r' , it is ordered and decreed that ERIN JUNKINS SCOTT JUNKINS bonds of matrimony. plaintiff, and defendant, are divorced from the 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 claims 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. By the Court, ~~~ L-~ Atte Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. Defendant • ? DC' FILE NO "' . . . IN DIVORCE rte- -0r,-, ter' z- r? w X ; C, -v C :)-n C) GO NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the Z 3 r ri day of rf 10 hereby elects to resume the prior surname of F ,-r 1 rl K J-C' L (x.11 C, and gives this written notice pursuant to the provisions of 54 P.S. 704. Si at ure DATE: 2- Lnn Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA . : SS. COUNTY OF CUMBERLAND On the day of _,201 i before me, a Notary Public, personally appeared the above affian own to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official, seal. we 11.00 P A P LFr SH 91At,&528 yr' ?rttM ...:• ISA?