HomeMy WebLinkAbout01-3320 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRENDA K. BLESSING, )
Plaintiff ) NO. 2001-~ CIVIL TERM
)
v. )
)
STEVEN B. BLESSING, ) CIVIL ACTION - LAW
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, thc case
may proceed without you and a d~eree 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 thc Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
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 thc Office of
the Prothonotap7, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pcunsylvania
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717)240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Conunon Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before thc court. You must attend the scheduled conference or hearing.
6. There have been no prior actions for divorce or annulment ofthe marriage
instituted by either of the parties in this or any other jurisdiction.
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. The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests the court enter a Decree of Divorce
pursuant to §3301 of the Divorce Code.
Respectfully submitted,
I~ C WE'I T, IC SSII~ (] ER & CONLEY~, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff, Brenda K. Blessing
HOV~ETT. KISSINGER & CONLEY. P.C.
t 30 WALNUT ,qTREET
POST OFFICE BOX ~10
[]ARP ];Sat.'R(J, PI~ N~ISY'r,VANIA 1710~
VERIFICATION
I, Brcnda K. Blessing, hcrcby swear and affirnl that thc I'acts contained in the foregoing
Complaint: Tn Divorce are true and
correct to Ihe best of my knowledge, inlbmmtion and belief and arc made subject to the penalties
of 18 Pa.C.S. §4904 relating to unsworn falsi ficafion to authorities.
Brenda K. Blessing
IIIll I I Ill ll Ill Illll Il Il I Il IIIlllllll Il Il Ill II Ill lll Illll!lllllllllllllll~llllll Ill'Ifil IIIlllll Il lll
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRENDA K. BLESSING, )
Plaintiff ) NO. 2001-3320 CIVIL TERM
)
v. )
)
STEVEN B. BLESSING, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on May 31,
2001 and service was accepted on June 15, 2001.
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90)
days have elapsed fi'om the date of filing and service of the complaint.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE
DECREE UNDER ~3301(e) 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 ifl 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
prothonot~.,,.
4. 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 made herein are made subject to the penalties
of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Brenda K. Blessing/Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRENDA K. BLESSING, )
Plaintiff ) NO. 2001-3320 CIVIL TERM
)
v. )
)
STEVEN B. BLESSING, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divome under §3301(c) of the Divome Code was filed on May 31,
2001 and service was accepted on June 15, 2001.
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the complaint.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE
DECREE UNDER 83301(c~ OF THE DIVORCE CODE
1. I consent to the entry ora final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI 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.
4. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree. I veri~ that the statements made in this Affidavit are
true and correct. I understand that false statements made herein are made subject to the penalties
of 18 Pa.C.S. §4904 relating to unsworn falsification t authorities. ,
Date: _~__ ~
Kayer and Brown
A Professional Corporation
L)berty Loft ,, 4 E. Liberty Avehue · Carlisle. PA 17013
(717) 243-7922
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRENDA K. BLESSING, )
Plaintiff ) NO. 2001-3320 CIVIL TERM
)
v. )
)
STEVEN B. BLESSING, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
ACCEPTANCE OF SERVICE
I, James J. Kayer, Esquire, hereby accept service of the Complaint in Divorce on behalf
of Defendant, Stevcn B. Blessing.
/
Jam ~'L K~, ~quire
~iK~ SRqPRCWN
~¥ L~ - 4 East Liberty Avenue
,le, PA 17013
Tele ~hone: (717) 243-?922
Counsel for Defcnd~mt Steven B. Blessing
BRENDA K. BLESSING, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2001 - 3320 Civil Term
STEVEN B. BLESSING, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO WITHDRAW AND ENTER APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance for Defendant, Steven B. Blessing, in the
above-referenced matter.
By:
,4..
Ja. ,~J. Ka~er,'E~s/q~ire
2L ~Av~nue ~
I~, ~
(71'
Please enter my appearance for Defendant, Steven B. Blessing, in the
above-referenced matter.
Ja~e Adams, Esquire
~,._.~7 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
I.D. No. 79465
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRENDA K. BLESSING, )
Plaintiff ) NO. 2001-3320 CIVIL TERM
)
v. )
)
STEVEN B. BLESSING, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
PRAECIPE TO TRANSMIT 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 §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Complaint accepted by James .j. Kayer,
Esquire, attorney for Defendant Steven B. Blessing, on .June 15, 2001; Acceptance of
Service filed on June 21, 2001.
3. Date of execution ofthe affidavit of consent required by §3301(c) of the Divorce
Code: by plaintiff, October 4, 2001; by defendant, October 9, 2001.
4. Related claims pending: All claims resolved by Marital Settlement Agreement
executed by the parties on May 21, 2001
5. Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary:
October 10, 2001; date defendant's Waiver of Notice in §3301(c) Divorce was filed
with the prothonotary: contemporaneously herewith.
Date: //~)///~//~?
' ....-'l~arren J. HoI~, sq '
HOWETT, KISSINGER & CONLEY, P.C.
130 Walnut Street
P. O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Brenda K. Blessing
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE Of ~i~ PENNA.
BRENDA K. BLESSING,
Plaintiff N O. ~ TERM
VERSUS
DECREE IN
DIVORCE
AND NOW, Or.,~/~.,,- lB' , ~, it IS ORDERED AND
DECREED THAT BRENDA K. BLESSING , PLAI NTI FF,
STEVEN B. BLESSING , DEFENDANT,
AND
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,
It is further ORDERED, ADJUDGED and DECREED that the terms, provisions and conditions
of a certain Marital Settlement Agreement between the parties dated May 21, 2001, are
incorporated in this Decree in Divorce by reference as fully as if the same were set forth herein at
length. Said Agreement shall not merge with but shall survive this Decree in Divorce.
PROTHONOTARY