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Home My WebLink About01-0278CONNIE L. JOHNSON, Plaintiff V KENNY R. JOHNSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001 ~ ~-~ CIVIL ACTION - LAW : : :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 Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 CONNIE L. JOHNSON, Plaintiff V KENNY R. JOHNSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001 - .~ 1 ?CIVIL ACTION - LAW : : : IN DIVORCE COMPLAINT Plaintiff, Connie L. Johnson, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: ! Plaintiff, Connie L. Johnson, is an adult individual residing at 256 West Ridge Street, Carlisle, Pennsylvania, Cumberland County, Pennsylvania. 2 Defendant, Kenny R. Johnson, is an adult individual residing at 144 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 5 The parties were married on June 4, 1995, in Cumberland County, Pennsylvania. There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. $ In accordance with Section 330! (c) of the Divorce Code, the marrlal~e between the parties is irretrievably broken. Plaintiff has been advised that counselinl~ is available and that Plaintiff may have the ri~,ht to request that the Court require the parties to participate in counselinl~. 7 Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROU]OS & GILROY, P.C. By Hubert X. Gilroy, Esqu~,~ Attorney for Plaintiff 4 North Hanover StrL, et Carlisle, PA 17013 7! 7-245-4.57~t I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904. reladng to unsworn falsification to authorities. Connie L. Johnson,/ BROUJOS & GILROY, p.c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARLISLE~ PENNSYLVANIA 17013 717-~4~-4~7,i 766-]690 CONNIE L. JOItNSON, Plaintiff V KENNY R. JOHNSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001 -278 CIVIL ACTION- LAW : IN DIVORCE To: Kenny R. Johnson NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on ~'a~ ._a~. ~//~ /Cg? and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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. I verify the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: CONNIE L. JOHNSON, Plaintiff V KENNY R. JOHNSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01 -278 CIVIL : : CIVIL ACTION - LAW : AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Kenny R. Johnson, by certified mail on January 16, 2001. A copy of the Certified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. DATE ub~e~ X. Gil~ Esquire 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before me this (J/~ '~ day of OC/~F.f ,2003 Notarial Seal Bridget Ann Corcoran, Nota~ Public Carlisle Boro, Cumberland Cotmty My Commission Expires June 10, 2006 Member, Pennsylvania Association of Notades · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name ar~ address on the reverse so tbat we can return the card to you. · Attach this card to the back of the mailpleca, or on the front if space permits. 1. Article A;:ldressed to: Kenny R. Johnson 144 North Middlsex Road Ca.isle, PA 17013 2. Article Number (Copy from service label) 7099 3400 0018 5046 3465 PS Form 3811, July 1999 + C. Signature , ., ~ D. Isdelive~yaddressdi~e~fmmit~ml? [] Y~ If YES, ent~ deliv~ add~ ~ow: ~ No Domestic Return Receipt CONNIE L. JOHNSON, Plaintiff KENNY R. JOHNSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01 -278 CIVIL : : CIVIL ACTION - LAW PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section ()3301(c) (X)3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: January 16, 2001, First Class Certified Mail, Return Receipt Requested, Restricted Delivery. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: ; Defendant:. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: July 7, 2003; (2) Date of service of the Plaintiff's affidavit upon the Defendant: July 9, 2003. 4. Related claims pending: None. 5. Complete either (a) (b) or (c) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: July 10, 2003 via First Class Certified Mail and Regular Mail. (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: (c) Date Defendant's Waiver of Notice in §3302(c) Divorce was filed with the Prothonotary: Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 I~ Complete items 1, 2, and 3. Also complete { A.'~I~, .ec~ved W {~Wease P~nt C/ea~) I I~ Date of D~ive~/ item 4 if Restricted Delivery is desired. '~'--~-,~ ~ { 1 ~-~"J/~_..L~ I ~) ~ la Pdnt your name and address on the reverse .. -, .... ~ ..... - r ,,, ~- . -- so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. A~icle Addressed to: Kenny R. Johnson 41 Regency Woods South Carlisle, PA 17013 ~C. atu /~ ~.Agent ~~, [] Addressee D, Is delive~ address d~-~ ~ ~ Yes If YES, ent~ delive~ add~ ~low: ~ No 3, Se~ice Type ,~ Certified Mail [] Express Mail [] Registered ~Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 3"/00 001 f694. 3O?0 PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 IN THE COURT Of COMMON PLEAS CONNIE L. JOHNSON PLAINTIFF OF CUMBERLAND COUNTY STATE OF PENNA. 200I~- 278 NO. VERSUS KENNY R. JOHNSON DEFENDANT AND NOW, DECREED THAT AND DECREE IN DIVORCE CONNIE L. JOHNSON KENNY R. JOHNSON , IT IS ORDERED AND ,PLAINTIFF, ,DEVENDANT, ARE DIVORCED fROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE SEEN rAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; CONNIE L. JOHNSON, Plaintiff V KENNY R. JOHNSON, · Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-278 CIVIL ACTION CO~TO~ER AND NOW, this !~_1~,, day of C C+. , 2;004, upon consideration of the attached Stipulation, it is ordered and directed as follows: 1. The father, Kenny R. Johnson, and the Mother, Connie L. Johnson, shall enjoy shared legal custody of Brielle A. Johnson, born July 31, 1996 and Jordana K. Johnson, born July 31, 1996. The Mother, Connie L. Johnson, shah enjoy primary physical custody of the minor children. The father, Kenny R. Johnson, shah enjoy liberal periods of physical custody with the minor children at such times as agreed upon by the parties. At a minimum, the Mother shah contact the Father whenever she is working and offer the Father the opportunity to care for the minor children during the time Mother is working. The parties shah also alternate or share holidays as they may agree, and the parties shall provide for reasonable vacation time with the minor children during the summer months. The Mother shall always have custody of the minor children on Mother's Day and the Father shall always have custody of the minor children on Father's Day. This Court Order is entered pursuant to a stipulation agreed to by the parties. In the event either party desires to modify this Order, that party may petition the Court to have the matter again reviewed for possible modification. BY THE COURT, ce'- ~l~ubert X. Gilroy, Esquire ..G~'~gory B. Abeln, Esquire,,i CONNIE L. JOHNSON, Plaintiff V KENNY R. JOHNSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 2'78 CIVIL ACTION STIPULATION We, Connie L. Johnson and Kenny R. Johnson, hereby agree that the attached Custody Order may be incorporated as an Order of Court without any further proceedings or personal appearance required by us. Witness ~tboern~eyX [oGr ~1~.~ .~quir e ~L'~nnie L.. ~h~soll Gr~o~-y~. Abeln, Esquire Attorney for Defendant Kenny R. Jah6son Date