HomeMy WebLinkAbout01-1326STEPHANIE SLATES,
Plaintiff
VS.
KEVIN J. SLATES,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
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 divome 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 Courthouse, One Courthouse Square, Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS'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 CONNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
2 Liberty Street
Carlisle, Pennsylvania 17013
(717) 249-3166
STEPHANIE SLATES,
Plaintiff
KEVIN J. SLATES,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
/3.2',,
CIVIL ACTION - LAW
DIVORCE COMPLAINT
1. Plaintiff is Stephanie Slates, an adult individual, who currently resides in
Cumberland County, Pennsylvania.
2. Defendant is Kevin J. Slates, an adult individual, who currently resides at 1420
Idaville Road, Gardners, Adams County, Pennsylvania.
3. The Plaintiff and Defendant have been bona fide residents in 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 May 31, 1997 in New Cumberland,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Pla'mtfff in this action is not a member of the Armed Forces.
7. The Plaintiff and Defendant are both cit/zens of the United States.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised of the availability of marriage counseling and that
she may have the right to request the court to require the parties to participate in such counseling.
Being so advised, Plaintiff does not request that the court require the parties to participate in
counseling prior to the divome decree being handed down by the Court.
WHEREFORE, the Plaintiff requests the court to enter a Decree of Divorce.
Date: March 6, 2001
Respectfully submitted,
ABOM & KUTULAKIS
Jason ?. Kutulakis, Esquire
Attomgy I.D. No. 80411
Suite 204
8 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff
VERI£IC~?ION
I hereby verify that the statements of fact made in the foregoing Divorce
Complaint are true and correct to the best of my knowledge, information and belief.
I understand that any false statements therein are subject to the crim/nai penalties
contained in 18 Pa.C.S. §4904, relating to un.sworn falsification to authorities.
Date:
STEPHANIE SLATES,
Plaintiff
KEVIN J. SLATES,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under 53301(c) of the Divorce Code was fried
on NLarch 8, 2201.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of tiling and service of the Complaint.
3. I consent to the entry of a final decree of clivorce after service of notice
of intention to request entry of the decree.
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. 54904 relating to unswom falsification to authorities.
STEPHANIE SLATES, :
Plaintiff :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2001- 01326
KEVIN J. SLATES, :
Defendant. : CML ACTION - LAW
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under 93301(c) of the Divorce Code was fried
on March 8, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of friing and service of the Complaint.
3. I consent to the 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 are true and correct. 1
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. 94904 relating to unswom falsificatio~to authorities.
Stephanie Slates
Plaintiff
STEPHANIE SLATES,
vs.
KEVIN J. SLATES,
Plaintiff
Defendant.:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-01326
CIVIL ACTION - LAW
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(C) OF THE DIVORCE CODE
1. I consent to the entry of a f'mal 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 a_re 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:
Steph'anie~,Slates TM
omplete items 1, 2, and 3. Also complete · A~ P~t C~)~t/y) r B, Date of ,De,very
dnt your name and address on the mv~e ~ ~ ~ ~ ....... I
so that we can return the ca~ to you. ~ ~gnatu~ -- ~ /
· A~ach this ca~ to the back of the mailpiece, ~ ~ ~ u Age~
or on the ~ont if space ~its. ~ ~ ~ ~ Aed~
D. Is delivery address different from item 1 ? [] Yes
If YES, enter delivery address D~low: [] Nc
3. Service Type
[] Express Mail
[] Return Receipt for Merchandise
L [] Insured Mail [] C.O.D.
4. Restricted Delivery? (Extra Fee) [] yes)
/
2. i¢ieNomber(Copyfs~{~be/)~,¢~O00 15.=~ 5573
PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952
STEPHANIE SLATES, :
Plaintiff :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2001- 01326
.-
.
KEVlN J. SLATES, :
Defendant. : CIVIL ACTION - LAW
PRAECIPE TO TRANSMIT THE RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
Ground for divorce: irretrievable breakdown under §(3301(c))
(3301 (d)(1)) of the Divorce Code
Date and manner of service of the complaint:
Return Receipt Reauested 3/15/01
(Complete either paragraph (a) or (b):
(a) Date of execution of the affidavit of consent required by
§3301 (c) of the Divorce Code:
by plaintiff ~/10/02
by defendant 1/8/02
Related claims pending: NONE
Certified US Mail,
5. Complete either paragraph (a) or (b):
(b)
Dote plaintiff's Waiver of Notice in §3301(c) Divorce was filed
with
the Prothonotary: 2/6/02
Date Defendant's Waiver of Notice in §3301 (c) Divorce was
filed
with the Prothonotary: 3/4/02
Respectfully submitted,
ABOM & KUTUI. AKIS, L.L.P.
Date:
_March 4, 2002
Jas/bn P. Kutulakis, Esquire
Attorney I,D. No: 80411
Suite 204
8 South Hanover Street
Carlisle, PA 17013
(717)24940900
Attorney for Plaintiff
STEPHANIE SLATES,
vs.
KEVIN J. SLATES,
Plaintiff
Defendanf.:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-01326
CIVIL ACTION - LAW
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 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 alhnony, 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. § 4904 relating to unsworn
falsification to authorities.
Date:
/Kcvin J./Slates
IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
STATE OF
STEPItANIE SLATES,
PLAINTIFF
VERSUS
KEVIN J. SLATES,
DEFENDANT
PENNA.
NO.
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
STEPHANIE SLATES
AND
KEVIN J. SLATES
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
2001-01326
20o
~-~Ir IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
BY THE COURT: //~) ~ /'
~ ' ~ PROTHONOTARY