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Home My WebLink About01-2189 i J r i ! i BETHANY ADKINS, ' IN THE COURT OF COMMON PLEAS OF Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA · VS. · a,vv · DONALD LEE ADKINS, · Defendant. · CIVIL ACTION - LAW 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 You may lose money or property orrelief requested in these papers by the Plaintiff. or visitation of your children, other fights important to you, including custody When the ground for 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 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 BETHANY ADKINS, ' IN THE COURT OF COMMON PLEAS Plaintiff . vs. ' CUMBERLAND COUNTY, PENNSYLVANIA 'NO: DONALD LEE ADKINS, JR. . Defendant ' CIVIL ACTION-LAW J COMPLAINT 1. Plaintiff is Bethany Adkins, who currently resides at 286 North Baltimore Avenue, Apartment 7, Mount Holly Springs, Pennsylvania, 17065. 2. Defendant is Donald Lee Adkins, Jr., is an adult individual, who currently resides at 9348 Otterbein Church Road, Newburg, Pennsylvania 17240. 3. The Plaintiff has been a bona fide resident(s)in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 18, 1999, In Shippensburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff in this action is not a member of the Armed forces. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to I participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to the divorce decree being handed down by the court. 9. The Plaintiff is irretrievably broken. WHEREFORE: The Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, Aborn & Kutulakis B~: ~squJre ~/ Attorney for Plaintiff ID 80411 8 South Hanover Street Suite 204 Carlisle, PA 17013 (717) 249-0900 % I BETHANY ADKINS, ' IN THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA v. 'NO: DONALD LEE ADKINS, JR., · Defendant · CIVIL ACTION-LAW VERIFICATION I verify that the statements made Jn t~e foregoing complaint and divorce are true and correct. I understand that false statements herein are made subject to the penalties 18pa. c. s. §4904, relating to unsworn falsifications to authorities. DATE:__~Z~-- 0 1 .. BETHANY AD.NS, · IN THE COURT OF COMMON PLEAS OF Plaintiff, · CUMBERLAND COUNTY, PENNSYLVANIA vs. · NO. 01-2189 CIVIL TERM DONALD LEE ADKINS, · Defendant · CIVIL ACTION - LAW AFFIDA~T OF SERVICE I, Jason p. Kutulakis, hereby certify that I served a true and correct copy of the Complaint Under Section 3301(c) of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached receipt card. Respectfully submitted, AB OM & KUTULAKIS, LLP Date: April 24, 2001 ~ J as4n P. Kutulakis, Esquire Attbmey I.D. No: 80411 Suite 204 8 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff , · Complete items 1, 2, and 3. Also complete A. Received by (Please Print Clearly) 1 B. D. ~ate of Delivery item 4 if Restricted Delivery is desired. ~-~'~-~1~ L ~c~ Jo,', .5 ~-~! ~I..j~-,~-O ( · Print your name and address on the reverse so that we can return the card to you. C. Signature · Attach this card to the back of the mailpiece, X ~,~/ ~t ~J~ ~.~ F'I ~ent or on the front if space permits. ' I-I Addressee 1. Article Addressed to: D. Is delivery address different from item 17 I-I Yes If YES, enter delivery address below: r-I No ~t~ ~r-5 ~ I"~ ~'(.~ o. Service'Type ,~1_! Rertified Mail I"! Express Mail egistered I-I Return Receipt for Merchandise r-! Insured Mail 1-1 C.O.D. 4. Restricted Delivery? (Extra Fee) !-I Yes 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 '1"~ Postage $ ~1..~ .. ~ Certified Fee.: Ir" Return Receipt Fee " ~3 (Endorsement Required) ~ Restricted Delivery Fee 0::::3(Endorsement Required) · I~ Total Postage & Fees ri-1 ,. BETHANY ADKINS, · IN THE COURT OF COMMON PLEAS OF Plaintiff, ' CUMBERLAND COUNTY, PENNSYLV~IA vs. · N O. 01-2189 CIVIL TERM DONALD LEE ADKINS, ' Defendant ' CIVIL ACTION - LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under [3301(c) of the Divorce Code was fried on April 12, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. [4904 relating to unswom falsification to authorities. Bethan~dkins ~~8~mmmmmmmmmmmmmmmmmm lI r BETHANY ADKINS, · IN THE COURT OF COMMON PLEAS Plaintiff ' · CUMBERI_,AND COUNTY, PENNSYLVANIA VS. · NO' 01-0189 CIVIL TERM DONALD LEE ADKINS, JR. ' 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: 1. Ground for divorce: irretrievable breakdown under §0301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: April 24, 2001 by first class mail remm receipt requested. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code' by plaintiff August 10, 2001; by defendant August 16, 2001. 4. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached' August 23, 2001. Respectfully submitted, 1~ & KI/ITU~S, L.L.P. Date: August 23. 2001 .~~'~L-~~/''''/~'' "~ J asofP. Kutulakis, Es~'~re Attc~ey ID No. 77961 8 Sohth Hanover Street Suite 204 Carlisle, PA 17013 Attorney for Bethany Adkins ~,.. C_-_ ......... ~ ] ~ .. _.. ~"T. 7 C ..... · .... !-~ i t: . - ~) '"=! -=.-~' ~ · :.:.. = ?-" r '," ~ q'"! .... ~., ('".-' ~ mZ.; , 7'~ -' ' '-" ..... I .,,., {, ..... , ~, ...... : .. .- -~ .... .., ) 7-;: ".-- -" ' . ~. ) ..... ...'= ~_· · _'... £~ -,_'... _, ( .0 BETHANY ADKINS, · IN THE COURT OF COMMON PLEAS OF Plaintiff, ' CUMBERLAND COUNTY, PENNSYLVANIA vs. · NO. 01-2189 CIVILTERM o DONALD LEE ADKINS, ' Defendant ' CIVIL ACTION - LAW W,~IVER 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 fights concerning alimony, division of property, laxwer'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 fil. ed with the Prothonotary. I verify that the statements made in this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. ' Bethan~A~~s · · ,, BETHANY ADKINs, · .... IN THE COURT OF COMMON PLEAS OF Plaintiff, · "''~'CUMBERLAND COUNTY, PENNSYLV~IA vs. · NO. 01-2189 CIVIL TERM DONALD LEE ADKINS, · Defendant ' CIVIL ACTION - LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under $3301(c) of the Divorce Code was fried on April 12, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. $4904 relating to unswom falsification to authorities. Date: ~-1~'01 ~~X ~ Z, _ ! Donald Lee Adkins BETHANY ADKINS, · IN THE COURT OF COMMON PLEAS OF Plaintiff, ' CUMBERLAND COUNTY, PENNSYLVANIA vs. · NO. 01-2189 CIVIL TERM · DONALD LEE ADKINS, ' Defendant ' CIVIL ACTION - LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER [ aa0x(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 fights 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 P a.C.S. 4904 relating to unswom falsification to authorities. Date: 5t-/(o'0' ~)~ ff 0_.._.~'~ ..Zo Donald Lee Adkins IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF PENNA. BETHANY M. ADKINS Plaintiff NO. VERSUS DONALD LEE ADKINS, JR. Defendant DEC tee IN DIVORCE AND NOW, . /3~;~ ~ ' , ~~/, IT iS ORDERED AND ! BETHANY M. ADKINS DECREED THAT , PLAINTIFF, AND Donald Lee Adkins, jr. , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRimONY. 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; By The COUrt: PROTHONOTARY