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HomeMy WebLinkAbout04-4188 F\FILES\DA TAFILE\General\ClIrrent\7122.170,coml/tde Created 7/16/042:24PM Revised, 8/231042:07PM 7122.170 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO 04- 41 l'Y' CNIL ACTION - LAW ALICE E. KUSKIN, v. NEDWIN J. KUSKIN, Defendant IN DNORCE 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Prothonotary's Office, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO 04- ..., I rr CIVIL ACTION - LAW ALICE E. KUSKIN, Plaintiff NEDWIN J. KUSKIN, Defendant IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Alice E. Kuskin, who currently resides at 1 South Baltimore A venue, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Nedwin J. Kuskin, who currently resides at 29 BuchnelI Drive, South Toms River, NJ. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 25, 1996, in Toms River, New Jersey. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. MARTS ON DEARDORFF WILLIAMS & OTTO By ,f\f\wOAD Carl c~s~: Esquire J.D. Number 75901 Jennifer L. Spears, Esquire J.D. Number 87445 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: Attorneys for Plaintiffs VERIFICATION I verify that the statements contained herein 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. ~~-~,~ Alice Kuskin ~ ~ ~ ~ ~ H -- j='1 , u.; '\ '" ~ fJ, "" ... "" ..... " "'" 0 '-- \:'.1 . F:\F1LESIDAT AFILE\GeneraIICllITentI7122_170,C0m2, wpd/tde Created: 7/16/04 2:24PM Revised: 9/14/04 2:02PM 7122,170 ALICE E. KUSKIN, Plaintiff IN THE COlJRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO 04-4188 CIVIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DIVORCE 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Prothonotary's Office, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'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 LA WYER 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ALICE E. KUSKIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO 04-4188 CNIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DNORCE AMENDED DNORCE COMPLAINT UNDER SECTION 3301rC) OF THE DNORCE CODE 1. Plaintiff is Alice E. Kuskin, who currently resides at 1 South Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Nedwin J. Kuskin, who currently resides at 29 Buchnell Drive, South Toms River, NJ. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 25, 1996, in Toms River, New Jersey. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. MARTS ON DEARDORFF WILLIAMS & OTTO ) By Carl C. Risch, Esquire I.D. Number 75901 Jennifer 1. Spears, Esquire J.D. Number 87445 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: September 14,2004 Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Date: <<1~ y ~~Y/ ALICE E. KUSKIN ( CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Amended Complaint was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. Nedwin J. Kuskin 29 Buchnell Drive South Toms River, NJ 08757 MARTS ON DEARDORFF WILLIAMS & OTTO ~~-/~~) ~rv j} ..... Tricia D. Eckenroad r Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: September 14,2004 C) C.:-:;: .._-1 -~ ...., '.;::.:1 C,:;' .r- "" pl "\J r; 'TI .-1 :L,., rne' ~i''1 -JQ o(~ :~,.J :I~ i'~~ f-n U1 ..,." r::' F:\FILES\DA TAFlLE\GeneraI\Currenl\7122-170affservice Created: 9/16/04 8:52AM Revised: 9/16/04 8:55AM ALICE E. KUSKIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO 04-4188 CIVIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Nedwin J. Kuskin at 29 Buchnell Drive, South Toms River, NJ 08757,on August 25, 2004, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signe "Nedwin Kuskin" and dated August 30, 2004. w Sworn to and subscribed before me this 16th day of September, 2004. ~tJ~~ otary Public NOTARIAL SEAL TRICIA D. ECKENROAD, Notary Public Carlisle Raro.. Cumberland County I!Ox~P~':: .. 04 ..D m f'- f'- '" '" ,.., ,.., U.S. Postal Service'M CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverag Provided) ,.., o o Return Reciept Fee Cl (Endorsement Required) Cl Restricted Delivery Fee n (Endorsement Required) o ,.., Certified Fee J Total Postage & Fees $ d- m o o f'- a.1 ill~i~7iO;;'='=1 1188 7736 ",.'''','' .... a;(', talst'..,17 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Df:ardorffWilIiams & Otto, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. Nedwin J. Kuskin 29 Buchnell Drive South Toms River, NJ 08757 MARTSON DEARDORFF WILLIAMS & OTTO ,.' , J~f/l$a{ ri ia D. Eckenroad Ten East High Slreet Carlisle, PA 17013 (717) 243-3341 Dated: September 16,2004 '. () "', () c::;> C~ =' .....1 .L- (/) :7 i": -~ Ct\ -~, ><:: .....-, , , ,-.'..- ~ ",... c: Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALICE E. KUSKIN, v. NO 04-4188 CNIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301(c) of the Divorce Code was filed on September 15, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service ofthe Complaint. 3. 1 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: ///':J"~o/ .r;::7 /. r ~/' r" ,c<..<"- . /" __~;~:."t.::..__ /" Alice E. Kuskin, Plaintiff {",'" ~<,~J ;:,:"J. '-' ...;..... "~-- .' c) ':i~>' c--' ,,} - ,.----- Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALICE E. KUSKIN, v. NO 04-4188 CIVIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~330l(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! 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 ofthe decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this waiver 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. /'"/,' ./ /' ',/"" /~L,( .~~.><~._...._...._.., Alice E. Kuskin, Plaintiff Date: .I //11, ju"l -------- \I- \ -.--, '-';' - F; \FILES\DATAFlLEIGeneraIICurrentl 7122, 170affidavitwaiver Cre'dted. 9i\N\14 gSlAM Revised: 11/24/04 J0'08AM Jennifer 1. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD.87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA ALICE E. KUSKIN, v. NO 04-4188 CIVIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301(c) of the Divorce Code was filed on September 15, 2004. 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 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. /'" Date: /J-j !nJ / Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALICE E. KUSKIN, v. NO 04-4188 CIVIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that Imay lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. Date: /)-~;; c.f FlFILESIDA T AF]LE\Genera!\Cun"enl\7122.] 70 praecipe/Ide Created: 9116104 8:52AM Revised: 12/]0104348PM 7122170 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALICE E. KUSKIN, v. NO 04-4188 CNIL ACTION - LAW NEDWIN J. KUSKIN, Defendant IN DNORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Via certified mail, restricted delivery on August 30, 2004. 3. Date of execution ofthe Plaintiffs affidavit of consent required by Section 3301 (c) of the Divorce Code; November 30, 2004; by the Defendant; December 1, 2004. 4. Related claims pending: No claims were raised 5. Date Plaintiffs Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: December 1, 2004. Date Defendant's Waiver of Notice III g3301(c) Divorce was filed with the Prothonotary: December 9,2004. MARTSON DEARDORFF WILLIAMS & OTTO By J enni er L. Spears, Esquire LD. No. 87445 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: December 10, 2004 ;+;'f. 'f.:+::+::+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+:++:+: :+:+: .. .. . . :+::+:+':+::+::+::+:+::+:+::+::+:+':+::+:+.+:+:+.+.:+::+::+:+:+.:++.+.:+:+:+.:+:+.:+:+.+:+++.:+:+.:+:+.:+:++.+.+.++++.+++.+.:+:++++. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;+.+.:+::+:+:++:+:+.:+:+++.+.+.:++.++.+:+:+++:+++.+++++++++++++.+++++++++++.++++++:+++ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. ALTCE F.. KUSKTN No. 04-4188 VERSUS NEDWIN J. KUSKIN DECREE IN DIVORCE AND NOW, 0c...l.-. , /OV1, IT IS ORDE,"IED AND 27 DECREED THAT ALICE E. KUSKIN PLAINTIFF, AND NEDWIN J. KUSKIN 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; NONE ~i4 J. PROTHONOTARY +. +. +.:+::+: +. ~d3 )tft/ Of- ('-:>0 f b II.: ~ ~ " ~7 'jE.. ./'?/T".;>>11 7.7~ .>(;>.>/ 17';:00 'S"'1/3d I d~ Ft8V -!>'l (~I ..