HomeMy WebLinkAbout09-8065KEITH E. KENDALL,
Plaintiff
VS.
CYNTHIA K. KENDALL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
Civil Action No. 69-gCfPS 2009
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 grounds 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, Suite 100, Carlisle, PA 17013,
717.240.6195 (phone) /717.240.6573 (fax).
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. 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, PA 17013-3302
(717) 249-3166
KEITH E. KENDALL, IN THE COURT OF COMMON
Plaintiff PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
VS.
Civil Action No. O 'F- ?D 6 S' 2009
CYNTHIA K.. KENDALL,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
NOW COMES the Plaintiff, Keith E. Kendall, Esq., pro se, to file the following
complaint in divorce with related claims, and in support thereof, avers that:
1. The Plaintiff is Keith E. Kendall ("Plaintiff'), sui juris, currently residing at
6313 Auburn Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. The Defendant is Cynthia K. Kendall ("Defendant"), sui juris, currently
residing at 6313 Auburn Drive, Mechanicsburg, Cumberland County, Pennsylvania,
17050.
COUNT I - DIVORCE UNDER SECTION 3301(c)
3. Paragraphs 1 and 2 are incorporated herein by reference, as though set forth
in full.
4. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months immediately previous to the
filing of this Complaint.
5. The Plaintiff and Defendant were married on February 14, 2005, in
Harrisburg, Dauphin County, Pennsylvania, 17101.
6. There have been no prior actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
8. The Plaintiff is aware that counseling is available, and that Plaintiff may have
the right to request that the court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests that the court enter a decree of divorce.
COUNT II - EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
9. Paragraphs 1 through 8 are incorporated herein by reference, as though set
forth in full.
10. Plaintiff and Defendant have acquired property, both real and personal,
including pension benefits accruing during the marriage, from February 14, 2005, until
October 6, 2009, the date of their legal separation.
11. Plaintiff and Defendant have been unable to agree as to an equitable
division of said marital property.
2
WHEREFORE, Plaintiff requests the Court equitably divide the marital property
of the parties.
Date: November 20, 2009
Respect full s ed,
Keith E. Kendall, Esq.
Attorney for Plaintiff, Pro Se
2415 North Front Street
Harrisburg, PA 17110
(717) 236-9539
(717) 236-0483 (FAX)
Attorney ID No. 42910
3
VERIFICATION
I, Keith E Kendall, the Plaintiff, verify that the statements made in this
Complaint 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.
Date: v
Keith E. Kendall, Plaintiff
RLED-0 FICE
OF THE Pir)( 1" CNOTAR!
2009 NOV 20 PM 12: 31
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David D. Bueff
Prothonotary
KirkS. Sohonage, ESQ
Solicitor
&nee X Simpson
is, Deputy Prothonotary
Irene E. 31 orrow
2nd Deputy Prothonotary
Office of the Prothonotary
Cumberfand County, Pennsylvania
CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 30TH DAY OF OCTOBER, 2012, 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
(717) 240-6195 • Fax (717) 240-6573