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Home My WebLink About10-1807FILED--C';='CE ?1' T- 'E PRLT'7 !- 10 ARY Karen W. Miller, Esquire 2410 MAR 12 Pill : 09 Attorney I.D. No. 200037 Caldwell & Kearns, P.C. CU"- U+wY 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorney for Maria T. Kauffman MARIA T. KAUFFMAN, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA vs. BRIAN P. KAUFFMAN, Defendant No. 1b - 180 Civil Term 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 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, 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, 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 17113 $35S1,0o Prs ATr( (717) 249-3166 C? 643PG d38837 MARIA T. KAUFFMAN, Plaintiff, VS. BRIAN P. KAUFFMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. Civil Term CIVIL ACTION -LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorney for Maria T. Kauffman MARIA T. KAUFFMAN, Plaintiff, vs. BRIAN P. KAUFFMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Term CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Maria T. Kauffman, an adult individual who resides at 614 Brisbain Lane, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant is Brian P. Kauffman, an adult individual who resides at 614 Brisbain Lane, Enola, Cumberland County, Pennsylvania, 17025. 3. 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. 4. The Plaintiff and Defendant were married on September 25, 2004, in Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Defendant is not a member of the armed forces of the United States or any of its allies. 7. The Plaintiff avers that the marriage is irretrievably broken. 8. 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 counseling. The Plaintiff does not desire counseling. 9. Plaintiff avers that there is one (1) child of the parties under the age of eighteen (18), to wit: Anna Teresa Kauffman. WHEREFORE, Plaintiff requests your Honorable Court, upon compliance with the provisions of 3301(c) or 3301(d) of the Divorce Code, to enter a decree in divorce. Date: V16 Ia D _ Respectfully submitted, 0?^ By aren W. Miller, Esquire Attorney I. D. # 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Plaintiff, Maria T. Kauffman 10061-001/160041 I, Maria T. Kauffman, verify that the averments 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. 4904, relating to unworn falsification to authorities. Date: Maria T. Kauffinad/ MARIA T. KAUFFMAN, Plaintiff, vs. BRIAN P. KAUFFMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 10-1807 Civil Term CIVIL ACTION - LAW IN DIVORCE C`3 c -° mw M -G ? mac. ?o v? cz? AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) OF THE DIVORCE CODE c ;a co 1. A Complaint in divorce under Section 3301(c) of' the Divorce Code was filed on March 12, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 without notice. 4. 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. 5. 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. Iunderstand that false statements h--rein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: . 3o , 20/1 Maria T. Kauffman, Plaintiff r-- C) c5 c=) 10061-0011172881