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HomeMy WebLinkAbout05-1915 , DEBORAH E. BUCKINGHAM, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL V ANI v. :CIVIL ACTION - LAW :IN DIVORCE ~NO. 0.5'- /9/s e-u~t-r-~ KEVIN V. BUCKINGHAM, Defendant NonCE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. lfyou wish to defend against the cJai s set forth in the following pages, you must take prompt action. You are warned that if y u fail to do so, the case may proceed without you and a decree of divorce or annulment m y be entered against you by the court. A judgment may also be entered against for y other claim or relief requested in these papers by the Plaintiff. You may lose money r property or other rights important to you, including custody or visitation of your childre . When the ground for the divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 0 PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 0 ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM AN OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. I YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO 0 TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YO CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A l7013 (717) 249-3l66 (800) 990-9108 ~ DEBORAH E. BUCKINGHAM, Plaintiff v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL V ANI :CIVIL ACTION - LAW :IN DIVORCE KEVIN V. BUCKINGHAM, Defendant :NO. O.5~ ;'11)../ COMPLAINT AND NOW comes the Plaintiff, Deborah E. Buckingham, who, by and throu her attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Becld y & Madden, of Counsel, files this Complaint, in which she avers thai: l. Plaintiff, Deborah E. Buckingham, is an adult individual residing at Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania l7055. 2. Defendant, Kevin V. Buckingham, is an adult individual residing at 6l East H Street, Brunswick, Frederick County, Maryland 217l6. 3. Plaintiff has been a bona fide resident of the Commonwealth 0 Pennsylvania for at least six months immediately prior to the filing of the orig' Complaint. 4. Plaintiff and Defendant were married on August 2, 1997, in Harrisburg, Pennsylvania. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. . 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and t Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs 1 through 7 of this Complaint e incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she m have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. SS330l(c) or (d), Plaintiff, Deborah Buckingham, respectfully requests the Court to enter a Decree of Divorce. DATED: 4----!~~) Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 171 08 (7l7) 233-7691 2 VERIFICATION I, Deborah E. Buckingham, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information nd belief. I understand that false statements herein are made subject to the penalties l8 a. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: 4~/Lf-(f) C;' -frV C) -{s. ~c-:~ 0 - ~ -0 II Q " ~ B \) ~ - -0 --C\ '--. ~ ?- f: ~ ~~~ rh .;,Jl "t~ ::;1..,- : <~~\~;, Q ;k '~~'\ \U (:.) -""I N :~ -J - DEBORAH E. BUCKINGHAM, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION - LAW : IN DIVORCE KEVIN V. BUCKINGHAM, : NO. 05--19l5 Defendant ACCEPTANCE OF SERVICE I, Kevin V. Buckingham, hereby accept service of the Divorce Complaint filed in the above-captioned action. DATED: I -J Lj IS; O.,r ~,ti/'.~ Kevin V. Buckingham o ~:::- ...., = c:> en , ~ i'.1 CJ -0 ,":-:1 en DEBORAH E. BUCKINGHAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE KEVIN W. BUCKINGHAM, Defendant : NO. 05-l915 PRAECIPE TO AMEND CAPTION TO THE PROTHONOTARY: Please amend the Caption on this case to reflect the Defendant's name as Kevin W. Buckingham and not as Kevin V. Buckingham as previously filed on the Divorce Complaint and Acceptance of Service. DATED: ?-11f -OS of Counsel Respectfully submitted, /~ BECKLEY & MADDEN 212 North Third Street P.O. Box Il998 Harrisburg, PA 17108 (7l7)233-769l ... (? ~-,. c; "'" c ~ ~\\ cJ' -, <..- ~ C.:: (-- 10 0 -;:1 -0" .---, ~:~- -;..-- r::? .~ <-" :v - DEBORAH E. BUCKINGHAM, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW : IN DIVORCE KEVIN W. BUCKINGHAM, Defendant :NO.05-l915 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 14, 2005. 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 l8 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: c;-'j-()) &-r.J_ E. ~~~ Deborah E. Buckingham If ;2 '" = = ""'" u> rrJ -0 o To -< :r: f'11:D r- ~gcrj ~jQ ~?~ ::-Sil.... .,:'1 "co ::< N ~ _""h = W co DEBORAH E. BUCKINGHAM, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW : IN DIVORCE KEVIN W. BUCKINGHAM, Defendant :NO.05-l9l5 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE l. 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 l8 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: C( (1- Cr)' lli~ t. l1_cl~ Deborah E. Buckingham o (~ ~ = (.:;::) c.n U? iT' -r..' o -n I ill W .1:.- CO , ~~ , , :::-1 ~b .< DEBORAH E. BUCKINGHAM, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW : IN DIVORCE KEVIN W. BUCKINGHAM, Defendant :NO.05-1915 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on Aprill4, 2005. 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. ~ 4904 relating to unsworn falsification to authorities. Dated: 1iS~O) ~~~~~ Kevin W. Bucki gham n ;:; ....> ,= 5'\ (/' rn -" N o -n :r."1J fl1r:;; :~~c:; C~Q; ~':~[.~j ::;(T\ ':.:-":, "-":..,. ,-~..., :<. ~,~-- ...-:''" ........ c;? (..0 CO DEBORAH E. BUCKINGHAM, Plaintiff ;IN THE COURT OF COMMON PLEAS OF ;CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW : IN DIVORCE KEVIN W. BUCKINGHAM, Defendant :NO.05-19l5 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE l. 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 i[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 veritY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: q-<g--()") ~r~, Kevin W. Buckin C) "', 0 = c C~ -n c.n V) :1:_ f','l ITI;:::::! -co iT: I ,_.,1 \.:0 .." , !~:. W 0. .r:- 0:> DEBORAH E. BUCKINGHAM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : CIVIL ACTION - LAW : IN DIVORCE KEVIN W. BUCKINGHAM, Defendant : NO. 05-19l5 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following infonnation, to the Court for the entry of a Decree of Divorce. I. Ground for divorce: irretrievable breakdown of the marriage under Section 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Kevin W. Buckingham, on Aprill5, 2005, by him accepting service of the same. 3. Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: by plaintiff on September 9, 2005; by defendant on September 8, 2005. 4. Related claims pending: No economic claims raised. 5. (a) Date plaintiff's Waiver of Notice September 9, 2005, and it is being filed contemporaneously herewith. (b) Date defendant's Waiver of Notice September 8, 2005, and it is being filed contemporaneously herewith. DATED: 1~ of Counsel Respectfully submitted, - .;7 BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A l7108 (7l7)233-769l , CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Kevin W. Buckingham 618 East H. Street Brunswick, MD 21716 DATED: q~'1J~ , - " (') "" 0 = C C':l " <on " c/O --I c- :c ., r'1 m p::..: I :-::;l~ CD >;~~, ~:.., ) (c) (,,_.J :-:3rT'i -, j-> .r.- :n --' .""-..