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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