Loading...
HomeMy WebLinkAbout04-3507JOHN C. KESLER, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : No. V. CIVIL ACTION - LAW SHERRY L. KESLER, IN DIVORCE Defendant 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 page= you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and decree of divorce or annulment may be entered against you by the court. A judgment may also be entere against you for any other claim or relief requested in these pages by the Plaintiff. You may lose money 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 ma request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at th, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OF EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TI:: 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania ~7013 Telephone: (717) 249-3166 JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW SHERRY L. KESLER, : ; IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER .~3301(c) OR §3301(d~ OF THE DIVORCE CODE AND NOW, thisf'~O' day of July, 2004, comes the Plaintiff, JOHN C. KESLER, JR., and files thi,, Complaint for Divome, and in support thereof avers as follows: 1. The Plaintiff is JOHN C. KESLER, JR., an adult individual who currently resides at 5744 Union Deposit Road, Harrisburg, Cumberland County, Pennsylvania. Plaintiff's Social Security Number is 182-58-4636. 2, The Defendant is SHERRY L. KESLER, an adult individual who currently resides at 333 Mulberry Drive, Mechanicsburg, Cumberland County, Pennsylvania. Defendant's Social Security Number is 201-52-5008. 3. The Plaintiff and Defendant were married on March 1, 1990, in Annville, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six (6) months immediately pdor to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and she may hal the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorc, under §3301 (c) or §3301(d) of the Divorce Code. :230458 VERIFICATION I, JOHN C. KESLER, JR., verify that the statements made in this Complaint for Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S,A. {}4904, relating to unsworn falsification to authorities. JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff /-) ~/- $ 5'o ? : NO. Civil Term V. ; CIVIL ACTION - LAW SHERRY L. KESLER, : IN DIVORCE Defendant : ACCEPTANCE OF SERVICE I, SHERRY L. KESLER, hereby accept service of the Divorce Complaint. I certify that I am the Defendant in the above-captioned action and as such, am authorized to accept service of the Divorce Complaint. Sherry L. KeCr 230480 JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : NO. 3507 CIVIL ACTION - LAW SHERRY L. KESLER, : : IN DIVORCE Defendant : : AFFIDAVIT I, SHERRYL. KESLER, being duly sworn according to law, depose and say: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I to participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office which list is available to me upon request. 3. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce decree being handed down by the Court. I, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. SHERRY L. KE~LER :225256 JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : VS. : CIVIL ACTION - LAW SHERRY L. KESLER, : : IN DIVORCE Defendant : : AFFIDAVlT I, JOHN C. KESLER, JR., being duly swom according to law, depose and say: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I to participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office which list is available to me upon request. 3. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce decree being handed down by the Court. I, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are made subject to the 3f 18 Pa.C.S.A. {4904, relating to unsworn falsification to authorities. JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : NO. Oq~-.~S~7 CJ,t V. : : CIVIL ACTION - LAW SHERRY L. KESLER, : ' IN DIVORCE Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of mardage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling pdor to the divorce becoming final. 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. 9 relating to uns m falsification to authorities. Date: / dohnC~f~Jr., Plaintiff :236534 JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : NO. V. : CIVIL ACTION - LAW SHERRY L. KESLER, : : IN DIVORCE Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I veri~ 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: - Sher~.~ Ke'sler, Defendant---" :236534 JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : NO. V. : · ' CIVIL ACTION - LAW SHERRY L. KESLER, : : IN DIVORCE Defendant : WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECP~=~= UNDER SECTION 3301(c) OF THE DIVORCE CODF 1. I consent to the entry of a final Decree in 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 ia 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 unswom falsification to Date: / Jol~n C. Kbsl~r, J/Plaintiff :238534-2 JOHN C. KESLER, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : NO. V. : : CIVIL ACTION - LAW SHERRY L. KESLER, : IN DIVORCE Defendant : WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DEClaF.= UNDER SECTION 3301(c~ OF THE DIVORCE COC," 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights conceming 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. ~4904 relating to unswom falsification to authorities. Date: ~"~'~. ~'/'c..~,;.~/~z ~ ,...~. '~,'.~.,~/,~._~.. ..... '~ Sherry'[/. Kesler, D~fe{~am :236534-2 IN THE COURT OF CC~4GN PLEAS OF P~ECIPE TO T~NSMIT RECORD TO the p~tb~nota~: Transmit the ~co~, to~et~r ~th t~ foll~ing ~fo~tion, to the co~t for ent~ of a di~rce dec.e: 1. G~ for divorce: ~trievable brea~ ~der S~tion 3301 (c) ~ of the Divo~e C~e. (Strike ~t ~licable section) 2. ~te and ~nner of se~ice of the c~laint: ~~ ~ .~ 3. C~lete eit~r P~a~aph A. or B. A. ~te of execution of the aff~avit of consent ~ ~ ~ction 3301 (c) of t~ Divorce C~e: by the plaintiff by t~ defe~ant B. (1) ~te of execution of t~ plaintiff's affid~it re~ Section 3301 (d) of t~ Divorce ~e: (2) ~te of se~ice of t~ plaintiff'a affid~it ~n the defendant: 4. Related claims pending: k~ 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of aaid notice under Section 3301 (d)(1)(i) of the Divorce Code ~-& ~..~o~ ~H ~ IN THE COURT OF COMMON PLEAS Of CUM BERLAND COUNTY STATE Of ~ PENNA. NC). · · VERSUS DECREE IN DIVORCE t6.'~ 4.~. , IT IS ORDERED AND DECREED THAT .l¥.,~qin ~_ ~l~'t'~, lit. , PLAINTIFF, AND ~ ~.. I~le_~ , 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; Nolle ATrEST: J. ~ PROTHONOTARY