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Home My WebLink About10-3777IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff : File No. /0 ' 37 7 ? c W. Vs TIMOTHY CHARLES KLINGENSMITH Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS c-- <P ; Grp a? .. N i -ra 4 hJ C..i Y y f'T; 3 YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PS 17013 1-800-990-9108 717-249-3166 g 3 ,-'2 G0 0, ( P/p-, M6 At 6 s9 y6 ?-? Af143366 IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff File No. _ Vs IN DIVORCE TIMOTHY CHARLES KLINGENSMITH Defendant COMPLAINT IN DIVORCE COUNT 1 AND NOW comes the Plaintiff, BETH ANN KLINGENSMITH, pro se who files the within Complaint in Divorce and avers as follows: 1. Plaintiff is BETH ANN KLINGENSMITH, an adult individual currently residing at: 14 Hunt Meet Lane, Garnet Valley, Delaware County, Pennsylvania. 2. Defendant is TIMOTHY CHARLES KLINGENSMITH, an adult individual currently residing at: 3131 Meetinghouse Road, Apartment E 10, Boothwyn, Delaware County, Pennsylvania. 3. Plaintiff and Defendant are sui juris, and have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on the 17th day of June, 1989, in New Berlin, Union County, Pennsylvania. Attached hereto and marked Exhibit "A" is a certified copy of the marriage certificate. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The parties have entered into a written agreement as to child support, child custody and property division. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the commencement and service of this action, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the commencement and service of this action, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, Date: (P 7 /0 BETH ANN KLINGENSMITH, AINTIF , PRO SE EXHIBIT A: Marriage Certificate 4 A I A, 0 .rS; hereby certify that on the day of:- n one thou- at sand nine hundred and Timothy Chaxles Klingensmith Beth Ann Egli and I, Were by Me anifteb Ins fKarriage in accordance with license issued by the Clerk of the Orphans' Court of Union County, Pennsylvania, numbered 21058 Q 0 VERIFICATION I, BETH ANN KLINGENSMITH, Plaintiff, verify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: BETH ANN KLINGENSMIT' 1161A SE IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff Vs TIMOTHY CHARLES KLINGENSMITH Defendant File No. 10-3777 IN DIVORCE ACCEPTANCE OF SERVICE BY DEFENDANT To the Prothonotary: 0 N fV tom. cn ,.Y' ', ~~I I i I, TIMOTHY CHARLES KLINGENSMITH, Defendant in the above- captioned matter, hereby accept service of the Divorce Complaint. This Affidavit is made subject to the penalties of 18 PA.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: ~ G h By: TIMO C S KLINGENSMITH, EFENDANT, PRO SE Sworn to and subscribed before me on this /(o day of ~(~~'1 >° , 2010 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Letlde Melon, Notary Public Gly of CMaMr, Delarvars County CarwrMalon June 2, 2011 Aaodatlon of Notaries ~ ~. NOTARY FILED-OFFICE 2010 SEP 27 Pty 2: 27 "UMSERLANIO COIJUT%' REflNSYLVANIA IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff File No. 10-3777 Vs IN DIVORCE TIMOTHY CHARLES KLINGENSMITH Defendant AFFIDAVIT OF CONSENT A Complaint in Divorce under 3301 (c) of the Divorce Code was filed on .Lune 7" 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. 1. I consent to entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit of Consent are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE: 11-6 BETH ANN KLINGENSMITH PL INTIFF. P O SL CF THE P90 TMONTAR".- 2010 SEP 27 PH 2.2 7 CUMBERLAND COUNi?PENNSYLVANIA IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff File No. 10-3777 Vs IN DIVORCE TIMOTHY CHARLES KLINGENSMITH Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 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. 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.A. 4904 relating to unsworn falsification to authorities. Date: 017 _ ?0 6( BETH ANN KLINGENSMITH TIFF. PRO ~y rt~Fi~.~~-CFi/PC ~Ql~ 1r1~ ~ °~ ~'~~~ l~: ~1~~~~s~ ~ ~, IN THE COURT OF Cd~ yam, ~. ,,~~L OF CUMBERLAND COUNTY, PENN ~VANIA BETH ANN KLINGENSMITH Plaintiff File No. 10-3777 Vs IN DIVORCE '1"IMO~I'HY CHARLES KLINGENSMITH Defendant AFFIDA VIT OF f'ONSENT A Complaint in Divorce under 3301 (c) of the Divorce Code was filed on .tune 7°i X010. 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 entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit of Consent are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § x904 relating to unsworn falsification to authorities. DA"1'E: ~ 1 ~ Y (~ TIMOTHY CHARLES LINGENSMITH DEF' , DAN"i', PRO SF, ~!~ ~I~-G~'~ICc 2~J~~ OCi -~I ~~ G~ ~ 3 IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA C3f~ I'H ANN KLINGENSMITH Plaintiff File No. ] 0-3777 Vs IN DIVORCE "TIMOTHY CHARLES KLINGENSMITH ____. Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF' A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 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. 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. 1 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 l 8 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: ~ (~ ref 4~i'r.G~~ - TI OTHY CHA S KLINGENSMITH, t;H'f;Nt>ANl'. TKO si: IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff File No. 10-3777 Vs IN DIVORCE TIMOTHY CHARLES KLINGENSMITH ,_, ~ `=' .-~ T,:`:e Defendant .~~ ;~, ~ .»~ ; w , -~. ter,; PRAECIPE TO TRANSMIT RECORD `~:'~ ' n ~;' To the Prothonotary: ~~~' ~'= ~ `~ ~' „ • ~J ..-... *. Ids together with the following information to the court for entry e Transmit the record a -~? , divorce decree: _,; ~~, ~`' 1. Grounds for divorce: Irretrievable breakdown under 3301 (c ) 3301 (d) (1) of the Divorce Code (Strike out inapplicable section) 2. Date and Manner of service of the complaint: June 11, 2010, BY US MAIL. 3. Complete either paragraph (a). a. Date of execution of the affidavit required by 3301 (c) of the Divorce code: By plaintiff 9/24110: by defendant 9!29/10 4. Related claims pending: NONE 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothontary: September 27, 2010 Date defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: September 29, 2010 Date: ~~ ' 1 r ~ ~~ k H ANN KLINGENSMITH PLA TIFF, PRO SE IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BETH ANN KLINGENSMITH Plaintiff Vs TIMOTHY CHARLES KLINGENSMITH Defendant To the Prothonotary: File No. 10-3777 IN DIVORCE PRAECIPE TO TRANSMIT RECORD ;~a <<-- ... ,r.r.~ cra rr- ~~ -~. ~,~ ,...-. _~ Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Grounds for divorce: ~ti Irretrievable breakdown under 3301 (c ) 3301 (d) (1) of the Divorce Code (Strike out inapplicable section) 2. Date and Manner of service of the complaint: June 11, 2010, BY US MAIL. 3. Complete either paragraph (a). a. Date of execution of the affidavit required by 3301 (c) of the Divorce code: By plaintiff 9124/10: by defendant 9/29J10 4. Related claims pending: NONE 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothontary: September 27, 2010 Date defendant's Waiver of Notice in 3341 (c) Divorce was filed with the Prothonotary: September 29, 2010 ;- --~c.~ -~- --~ ~7 :xs ~.~ Date: `~ ~ / / " /~ TH ANN KLINGENSMITH PLA IFF, PRO SE BETH ANN KLINGENSMITH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TIMOTHY CHARLES KLINGENSMITH NO 10-3777 DIVORCE DECREE AND NOW, N 3 , ~~~ , it is ordered and decreed that BETH ANN KLINGENSMITH plaintiff, and TIMOTHY CHARLES KLINGENSMITH ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The property settlement agreement between the parties dated May 21, 2010 and attached to this Decree is hereby incorporated by reference as fully as though the same were set forth herein at length. Said agreement shall not merge with but shall survive this Decree. By t ourt, Attest: J. Prothonotary Date Certified Copy Issued: ~,~,,,tl e~ .~' Pi4~ N Court of Common Pleas, Cumberland County - Pennsylvania DEC 202010 Re: Beth A. Klingensmith V. K/ v • (0 - _3 `7 ? .3. Timothy C. Klingensmith RETIREMENT BENEFITS COURT ORDER THIS MATTER having come before the court on motion, and the court, after reviewing the motion, considered the requirements and standard terminology provided in part 838 of Title 5, Code of Federal Regulations, and being otherwise fully advised of the matter: ORDERED: Timothy C. Klingensmith (employee) will be eligible for retirement benefits under the Federal Employee Retirement System based on employment with the United States Government. Beth A. Klingensmith (former spouse) is entitled to one thousand dollars ($1,000) per month from Federal Employee Retirement System retirement benefits. The Office of Personnel Management is directed to pay this amount of Timothy C. Klingensmith's benefits directly to Beth A. Klingensmith upon Timothy's retirement. 1. Employee is: Timothy C. Klingensmith 3131 Meetinghouse Rd -Apt E-10 Boothwyn, PA 19061 SSN 187-60-8110 ` --+ , 2. Former Spouse is: N f-' av Beth A. Klingensmith 14 Hunt Meet Lane c ca -cy o -n Z C13 Garnet Valley, PA 19060 v "-+'T' SSN 183-52-1515 3. A certified copy of this court order shall be sent to: Office of Personnel Management Retirement and Insurance Group P.O. Box 17 Washington DC 20044-0017 OR By Process servers, express carriers, or other forms of hand carried delivery to: Court-Ordered Benefits Section Allotments Branch Retirement and Insurance Group Office of Personnel Management 1900 E Street, NW Washington DC 20044 laintiff, Beth Ann Klingens fendante'imothy Charles Klingensmith Dated: 6*0W4 4'' , 2010 BY TI&Co??--: Judge, Court of Common Pleas - Cumberland County n cop I Court of Common Pleas, Cumberland County - Pennsylvania Re: Beth A. Klingensmith Timothy C. Klingensmith RETIREMENT BENEFITS COURT ORDER THIS MATTER having come before the court on motion, and the court, after reviewing the motion and being otherwise fully advised of the matter: ORDERED: Beth A. Klingensmith, Social Security Number 183-52-1515, 14 Hunt Meet Lane, Garnet Valley, PA 19060 is awarded one hundred fifty thousand dollars ($150,000) from the civilian Thrift Savings Plan account of Timothy C. Klingensmith, Social Security Number 187-60-8110, 3131 Meetinghouse Road - Apt E-10, Boothwyn, PA 19061. 1. A certified copy of this court order shall be sent to: TSP Legal Processing Unit CODIS P.O. Box 4390 Fairfax, VA 22038-4390 Fax: 1-703-592-0151 Plaintiff, Beth Ann Klingensmi by Charles Klingensmith Dated: 2010 BY Judge, Court of Common Pleas - Cumberland County h C MW MW ?r ?D DQ zo pc Na a 0 rat C"') N N -v s w C4 .t-- 0 n .nr M C) =0 i=' oF5 D Cp 9 £s .n?.t LE I