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Home My WebLink About10-28901F . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010 APR 30 AN 9; 4 f Family Court Division Cu Im ?qtr 1' Jesse James Kell Action in Divorce vs. t o - a8go C? ?? ? Gerw? Susan Dawn Kell (Jubb) NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against these 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 on the first floor of the Courthouse: 1 South Court House Avenue, Carlisle, PA 17013-3323 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. MidPenn Legal Services 401 E. Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 (800) 822-5288 4 35oi . oo Po PLFF tt Mo* c2U(P3(0086 2# Iglael IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Family Court Division Jesse James Kell Action in Divorce VS. Susan Dawn Kell (Jubb) COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE Plaintiff is Jesse Kell, who currently resides at 130 Yorkshire Drive, Mechanicsburg, Cumberland County, PA, 17055 since November 2005. 2. Defendant is Susan Dawn Kell, who currently resides at 12305 W. Sunridge Drive, Nine Mile Falls, Spokane County WA, 99026 since 2010. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 8, 2001 in Serb Park, Eisenhower Boulevard, Harrisburg, Dauphin County PA, 1711. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and the plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: Ml- ? J'5oPlaintiff Gillian A. Woodward, Esquire ID# 206952 1968 Church Road York, PA 17408 717-771-9204 . Vii' k 1 I ?.f :Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND tC)'UNT`Y, PENNSYLVANIA 2010 APR 30 AM 9: 41 Family Court Division Jesse James Kell Action in Divorce vs. 10 -gyp IVi Susan Dawn Kell (Jubb) NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in September 2003, 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 that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. Date: Plaintiff/De ndant ignature r Plai f Defendant Print name Fi1 Ff - r} 2010 APR 30 Ali 9: 41 CUM-:r_. __ :.?NTY IN THE COURT OF COMMON PLEAS OF CUMBERLA1NP,1 Q'U llt, PENNSYLVANIA Family Court Division !D aggp 016 i t T rw Jesse James Kell Action in Divorce vs. Susan Dawn Kell (Jubb) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not clam 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: 3/)',7/1b ,-- - ? 7- -?, -?/? P ' if fend ignature Plai ' f/Defendant print name IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Family Court Division Jesse James Kell VS. Susan Dawn Kell (Jubb) Action in Divorce (~ ,~;!_ ~- ~C.~~~ ~ :_ -~ ~~ r, ~. N Q N ~, -c ~~ "T~ 4 t'a r:_. ~,~-, ." :~ .~:. PRAECIPE TO TRANSMIT RECORD ~ To the Prothonotary: c,~ Transmit the record, together with the following information, to the court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(d)1 of the Divorce Code. 2. Date an ma er o service of the complaint: ~ I `b Id ~ ~ ~( C.\a5 `~ '~ ~ Y G~ 3. (1)Date of execution of the affidavit required by § 3301(d) of the Divorce Code: ~~oTl • f0; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: ~ - ~ ~- t O 4. Related claims pending: ]/~ (~ I/l 5. Date plaintiff s Waiver of Notice was filed with the prothonotary: 7 (V. 6. Date defendant's Waiver of Notice was filed with the prothonotary: S-a~7•tli. n .. ~ . ~ 1 ~ Gillian A. Woodward, Esquire ID# 206952 1968 Church Road York, PA 17408 717-771-9204 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY a PENNSYLVANIA c ~, ~ { -~, -. Family Court Division `` =~ ~~ ~-; ~¢_ ..~.~ Jesse James Kell ~" ~-" `-' . ~~ ~. Action in Divorce '~=`- -c r, 10 - 2890 ~-- . `~'' Susan Dawn Kell (Jubb) Civil Term ~ ~. AFFIDAVIT OF SERVICE I certify that on this day I served a true and correct copy of: COMPLAINT IN DNORCE, NOTICE TO DEFEND AND CLAIM RIGHTS, and COUNSELING NOTICE upon Susan Dawn Kell, defendant in the above-captioned matter, by mailing a true and correct copy of same by U.S. Certified Mail, return receipt requested, postage prepaid, onrj - Co -1(y to the following address: Susan Dawn Kell 12305 W. Sunridge Drive Nine Mile Falls, WA 99026 Defendant personally received said documents on `j - \ `~- l0 , as evidenced by her signature on the certified mail return receipt card, which is attached to this paper. ~ as~r ~ Gillian A. Woodward, Esquire ID# 206952 1968 Church Road York, PA 17408 717-771-9204 C-t_ (~Do ~~y~ Print name ^ Complete Rams 1, 2, and 3. Also complete item 4 H Restricted DeNvery >a desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailplece, or on the front H space permits. 1. Article~//(A`ddressed to:/~~\\\~~.~~~ \ y ,/~ t -~~C' a X by ~ Agent ~. ~ L~ \ D. is delivery address d rent ~~ m 1? ^ Yes ~ ~., H YES, errter address ^ No ~: l~ N ~ `~~l~ '0s ~ -- n .. _ ., c a service type ~certinod ~ o n~au Registered ^ Return Receipt for tiAen~errdtee ^ insured Mail ^ c.o.D. a. Restricted oemreyr ~xaa r-ee) D Yes z. Article Number 7flfl9 2820 Oflfl1 8902 1483 (liaresfer tram servke Rebel) PS Form 3$11, February 2004 Domestic Return Receipt ta2:i~oz~M-t5ao IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTS r ,'; PENNSYLVANIA ~= `~ -' Family Court Division ~~~'y ~~''M ''~~~-• _.., . -:< N s-' ~~, - Jesse James Kell ~~ Action in Divorce ~: ~ ~ ~ ~. t^ ~.... "'yy Susan Dawn Kell (Jubb) ~ ~ ~ NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in September 2003, 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 that the statements made in this Affidavit are true and correct. understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: laintif t Signature Nil ~~ ~~ Plaintiff D t Print name N ~ , O " rf~~-, '~_-'l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN',F~, n3 -r; PENNSYLVANIA == • ~'~ " ~ ~= ~~. Family Court Division _=~ ~_ ~~_ • • 7 __ ~~ Jesse James Kell ; `~ `il ~'' Action in Divorce ~== ~` vs. : (~ ' ~~~ ~ Susan Dawn Kell (Jubb) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not clam 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: Z oQ Plaintif efenda Signature '~~.~ ~ ~- Plaintiff e t print name