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Home My WebLink About08-5539Melissa Kuhn, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Bryan Kuhn, Defendant : NO. 08- S5 3 q CIVIL TERM 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 in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common 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 the court. You must attend the scheduled conference or hearing. Melissa Kuhn, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW : IN DIVORCE Bryan Kuhn' Defendant :NO. 08- SS3 [ CIVIL TERM DIVORCE COMPLAINT The plaintiff, Melissa Kuhn, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. 3301 c AND 3301 d OF THE DIVORCE CODE 1. Plaintiff is Melissa Kuhn , who currently resides at 46 East Penn Street 2. Carlisle, Cumberland County, PA 17013, since September 2008. 3. Defendant is Bryan Kuhn, who currently resides at 413 Chestnut Street, Apt. B Mt. Holly Springs Cumberland County, PA, 17065 since July 2007. 4. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 5. Plaintiff and Defendant were married on August 31, 2007 at Mt. Holly Springs, Cumberland County, Pennsylvania. 6. Plaintiff and Defendant have lived separate and apart since March 7, 2008. 7. There have been no prior actions for divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has 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. WHEREFORE, plaintiff requests the court to enter a decree of divorce. '?& "14-? Rebecca Faul er Certified Legal Intern Iv1EYER MEGAN ES Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date q -1 `5 -C6 N C? ?°, C7 C.? Q ? J C7i Melissa Kuhn, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : IN DIVORCE Bryan Matthew Kuhn ; NO. 08- 5539 CIVIL TERM Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Ms. Melissa Kuhn, Plaintiff, to proceed in forma paupers. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date So.n 19, r77U Rebecca Faul er Certified Legal Intern MEG RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Cm c3 fi ' ? sJ CZ) Gi '?' • Melissa Kuhn, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Bryan Matthew Kuhn, Defendant NO. 08 -5539 CIVIL TERM CERTIFICATE OF SERVICE I, Rebecca Faulkner, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Bryan Matthew Kuhn, residing at 413 Chestnut Street, Apartment B, Mt. Holly Springs, Pennsylvania, 17065 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Bryan Matthew Kuhn, on the 20th day of September, 2008 as evidenced by the attached green card. g. ?i -) AQ12r? ?) Rebecca Faulkn r Certified Legal Intern Anne d-Fox, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C C H ° y ?_ zz ) ? Melissa Kuhn, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Bryan Kuhn, Defendant : NO. 08-5539 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on September 19, 2008. The Complaint was served on Defendant on September 20, 2008. 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 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 /?-/9 N ? fs' `rt ?? r-, i Zr r ? ? "C Melissa Kuhn, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Bryan Kuhn, Defendant : NO. 08-5539 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on September 19, 2008. The Complaint was served on Defendant on September 20, 2008. 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 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. BryK efendant r_ r.? C=) CD 4'317; F + i cn Melissa Kuhn, Plaintiff V. Bryan Kuhn, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 08-5539 CIVIL TERM 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 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 unsworn falsification to authorities. Date lob-/i?t? C? C3 r (1 6 ?? ?-. wp r f L ? Melissa Kuhn, Plaintiff V. Bryan Kuhn, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 08-5539 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER -43301(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 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 Bry K e 'Defendant C? ? :.?? C. ? `+? cxa Y { __ _.. FI ? '/ 7 ? '. P ? 4 ...... ?? .fi Melissa Kuhn, Plaintiff V. Bryan Matthew Kuhn, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE No. 08 -5539 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce 2. Date and manner of service of the complaint: Served on Defendant at 413 Chestnut Street, Apartment B, Mt. Holly Springs, Pennsylvania, 17065 on September 20, 2008 by United States mail, certified, restricted delivery, return receipt requested. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff December 19, 2008; by Defendant December 19, 2008. 4. Related claims pending: None. 5. Date plaintiff s Waiver of Notice was filed with the Prothonotary: December 19, 2008. Date defendant's Waiver of Notice was filed with the Prothonotary: December .19, 2008. Date jv 42a? Rebecca Faulkner' Certified Legal Intern 0117 1 &M-Ok 46ge-0-t&, Megan esmeyer, Esquire Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 kil s k. W ? s ? v C? Melissa Kuhn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Bryan Matthew Kuhn No 08-5539 DIVORCE DECREE AND NOW, Z , '?IJD 1 it is ordered and decreed that Melissa Kuhn Bryan Matthew Kuhn bonds of matrimony. plaintiff, and defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By t Court, f 11F1 Attest: J. i Prothonotary 4,2 -/kV Melissa Kuhn, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Bryan Matthew Kuhn, Defendant NO, 08-5539 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that I served true and correct copies of the Plaintiff's Affidavit of Consent, Plaintiff's Waiver of Notice, and Praecipe to Transmit Record on Bryan Matthew Kuhn by depositing a copy of the same in the United States mail addressed to 413 Chestnut Street, Apartment B, Mount Holly Springs, Pennsylvania 17065 on December 22, 2008. Nicole Berman Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639