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Home My WebLink About05-1628 MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ; NO. 05-1\:;16 CIVIL TERM DAVID KLING, 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 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 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 32 Bedford Street Carlisle, P A 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. MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE · " ).. 1, : NO. 05-' CIVIL TERM DA VID KLING, Defendant COMPLAINT UNDER 23 Pa.C.S. ~~ 3301(c) and Cd) OF THE DIVORCE CODE The Plaintiff, Monica Kling, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE 1. Plaintiff is Monica Kling, who currently resides at 1610 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is David Kling, who currently resides at 205 Oak Drive, Mount Holly Springs, Cumberland County, Pennsylvania, 17065. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on July 30, 2001, in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff and Defendant have lived separate and apart since January 25, 2005. 7. The marriage is irretrievably broken. 8. 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, the Plaintiff requests that the Court enter a decree of divorce. Respectfully Submitted, Date L3! Uj&~C) "~~ ,~<-<-i:tL STON- WALSH Sup ising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 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 unsworn falsification to authorities. Date f-) (:~ f"-.' (<.'"':'; -~....') ~~?t ?;: :;;...; ",) \J:) '-/ ~, --- :2 0 r-' ,--' -n -fj -- ...~... ...- - MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ; NO. 05-,,,-:BcIVIL TERM DAVID KLING, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Monica Kling, Plaintiff, to proceed in forma pauperis. 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. Date ~/2r/o)- ~. e.s . ct. fully. SUbmitted., ~ ' .0Zt4Jc1 <'1Zi4c BRENDA COP DE -- Certified Legal Intern 24icv1 VtJ?~ -GJcJ~)( LUC~STON-WALSH Supe- sing Attorney F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 r-' C'-c-: C...' <:.1" :3.;' _.--" 7') 1" ...0 ~ ::~;:. -- .' - o MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DA VID KLING, Defendant : NO. 05-1628 CIVIL TERM CERTIFICATION OF SERVICE I, Brenda Coppede, Certified Legal Intern, Family Law Clinic, hereby certifY that I have served a true and correct copy ofthe Complaint for Divorce on David Kling, residing at 205 Oak Drive, Cumberland County, Mount Holly, Pennsylvania, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by David Kling on April 1, 2005, as evidenced by the attached green card with the article number 70033110 000457742211. ~~1,' .' ~.-/c_ I~DA COPP Certified Legal Intern F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 . ';::? '~ - r'..... ~- ------ <.:) "--n ....\ -::,:: -1-, ',-~ f"'- ~- ::l ---:: r;:' ~ '.~, r..;: - UNITEO STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Please print your name. address. and ZIP+4 in this box. r),J ('It.-{ lJ_'iSfi ~r)(t/Y!L).j{.! L..l.:~u (il!I_~'-'Z_<~ Cf C; '71 ifu)tI, PU:! J, t"u.7 .1.;-1" /<-, .//'7.../: CL_ ( <A. r/_. ~ --- .. ( ) , V2..2 L;;:'Pip :PI .-' -/0 3 , "':~ i,,,II!,,,\i\, ,,,,' j., :'\ 1'1'1" MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID KLING, Defendant : NO, 05-1628 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301(c) of the Divorce Code was filed on March 29, 2005. 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. S4904, relating to unsworn falsification to authorities. Date Wle30JW5 \. ' V (') ,':, , ~~ (:S CJ. (.- c.~:: ,_. CD -0 ~. () " .-1 fti p~ ~G~~'; ;-::-:,'~ ~~.J" f:;:1 o w ;~---~ ~"~~~ ;::~ :')":J ~.o::... MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID KLING, Defendant : NO. 05-1628 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~13301(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 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 , fie 30 J(JJ5 <-' c::> c::5., oJ" (~--: t.~:": ('--' - c;J ~ o -() 1~"n (t"'lF"-:' ~a\:S\ '.-''-_/ - -),(:~ ." -(", .....:~. :)-i_:;~' .-:~~\ri i ~~;:J .....r.;:. -.: r:-/ C) (..;-:. - MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID KLING, Defendant : NO. 05-1628 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 29, 2005. 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 7~ {. C', Defendant p~ / ~-4 David Kling (') .-..' 0 = ~~:: c;:::> -n .:::...f' c_ c:'., ~'''<'. CD ~ r:--? 0 w ------ - MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID KLING, Defendant : NO. 05-1628 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST 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 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. 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. s4904 relating to unsworn falsification to authorities. Date :2_-1- of .e~L' ~-4- David Kling, Plaintiff (") ~:;;. ~ c,:::::l ..~.-. (;~~-: I~;:::' ,--' ~{1 CC.l -',:' ~. - r~:' C1 ~> - --- MONICA KLING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID KLING, Defendant : NO. 05-1628 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: 1. Ground for divorce: irretrievable breakdown under S 330I(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 1, 2005 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the plaintiff, June 30, 2005; by the defendant, July 1,2005. 4. Related claims pending: none. 5. Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: July 18,2005. Date defendant's Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: July 18,2005. Date: ~J I~ <97 Brenda Coppede Certified Le a1 Intern ~~ aSTON-WALSH A MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 "", C-::_1 = <en t: C'-' c:) -c:' N C) .l:;'- . . . . . IN THE COURT OF COMMON PLEAS . . . OFCUMBERLANDCOUNTY STATE OF MONICA KLING, . . . Plaintiff . VERSUS . DAVID KLING, Defendant . . . . . . . . . . . AND NOW, . . . DECREED THAT . . . AND . . . PENNA. NO. 1628 2005 DECREE IN DIVORCE 1'"'1 (i' z~.~ IT IS ORDERED AND , , MONICA KLING PLAINTIFF, DAVID KLING 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; . . . . . . . . . . '. .' 'v . ~ - -... ..... -.. .........../ "-" - . > .... 'r,~ ..-.-- ~ '- ." , , / . - '........ - .... . . . ..~ - - ~. . . . . -- '. ....-,,/. .'~.: ./'. .-.,..... .. ,...... ..-....- .. ~<O ;:...~~\: .~~.~~ "'-""'...... . NONE ( OURTd . J. . . . . . . . . . .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (7~ ~ ~.?J _# p~ ~JL. 5r?(l(! -L ~ ~ ~ ~ _p) 5r/.(fr>-[ . . - .. . ' -