The URL can be used to link to this page

Home My WebLink About09-8915Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclay(a,dzmmglaw. com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK F. KISSINGER, Plaintiff V. LAURI A. KISSINGER, Defendant No. OR - 8915 0'1v!( J elm CIVIL ACTION - LAW (In Divorce) NOTICE 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 the 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 Court House, One Courthouse Square, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Date: 12 `31 I D? By: n say Gi ch clay, Esq ' e upreme Co ID # 87954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Attorneys for Plaintiff Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclayQ-)dzmm g-law. com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK F. KISSINGER, :M Plaintiff No. - g` q s C ??' V. CIVIL ACTION - LAW LAURI A. KISSINGER, Defendant (In Divorce) COMPLAINT UNDER & 3301(c) OR 4 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mark F. Kissinger, who currently resides at 55 South 396 Street, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Lauri A. Kissinger, whose last known address was 55 South 391' Street, Camp Hill, Cumberland County, Pennsylvania. Defendant's current whereabouts are unknown. 3. 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. 4. Plaintiff and Defendant were married on February 25, 1999, in Tampa, Florida. 5. Two children were born of this marriage, namely: Caleb Landon Kissinger, whose date of birth is October 24, 2000, and Sydney Joy Kissinger, whose date of birth is February 3, 2004. Defendant's son, Austin Tyler Kissinger, whose date of birth is May 29, 1998, was adopted by Plaintiff. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have been advised of the availability of marriage counseling and their ability to request that the Court require the parties to participate in counseling. They have been further advised that they can obtain a list of counselors from the Cumberland County Prothonotary's Office. Having been so advised Plaintiff does not desire the Court to order counseling. See Plaintiff's Affidavit attached hereto as Exhibit "A" and incorporated herein by reference. 8. Plaintiff and Defendant are members of the United States Air Force- Pennsylvania Air National Guard. 9. The cause(s) of action and section(s) of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file and Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on or about December 26, 2009. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC ju-L Date: 12(311 ? By: f 4Ld ay G in M y, Esquir eme Co # 87954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Attorneys for Plaintiff' EXhlbit (04 p 4) AFFIDAVIT I, Mark F. Kissinger, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Dated: 3/ ?? o?oOT Mark F. Kissinger, Plaintiff VERIFICATION I, Mark F. Kissinger, verify that the statements made in this 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. Section 4904, relating to unsworn falsification to authorities. Dated: 3i Q ??of ?----- - - i--? Mark F. Kissinger, Plaintiff E tM 00 Lindsay Gingrich Maclay, Esquire DALEY ZUCKER MBILTON MINER & GINGRTCH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (7l7}657-4795 Ilt]$CI$ynQ dZ1111ngta~9 COtlI ,~ FiCE~..~ =t,~ rGE T ~~- ~.,,,..~, ZOtO J~t'~ t 5 ~ t0~ 30 ~~°! t~V~) ~..1r~r., A~r ~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK F. KISSINGER, Plaintiff No. 2009-8915 v. . CIVIL ACTION -LAW LAURI A. KISSINGER, . Defendant (In Divorce) ACCEPTANCE OF SERVICE I, Marlin L. Markley, Jr., Esquire, do hereby accept service of the tnie and correct copy of the Complaint in Divorce on behalf of my client, Lauri A. Kissinger, the Defendant in the above-captioned case, and I certify that I am authorized to do so. RespectfiTlly submitted, Date: ~ " ~ - Z ~ r J IOtarlin L. ley, Jr., EsgYtfi Attorney .D. o. 84745 3920 Market Street, Suite 303 Camp Hi11, PA 17011 David 1D. Buell v. e Renee X Simpson Prothonotary , 1s' Deputy Prothonotary Zs � v �irkS. SoIionage, ESQ Irene E. 14orrow Solicitor 1750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania 69 mews 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'az(717)240-6573