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HomeMy WebLinkAbout01-5040STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O! -- ~'~(~ CIVIL ACTION - LAW 1N 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 maybe entered against you by the court. A judgment may also be entered against you for anyother 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 at the Cumberland County Courthouse, Main Street, 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. Dated: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 By ' KI~IN ~. PROS~ER, ESQUIRE~'-~'-''~ 227 North High Street P.O. Box 116 Duncannon, PA 17020 (717) 834-3087 Attorney for Plaintiff STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above captioned action in Divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling, please advise in writing promptly by replying to: Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. Deputy Prothonotary STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 0[~ ~0 CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiffis Staci N. Kavanaugh, who currently resides at 801 Walnut Street, Apt 8, Lemoyne, Cumberland County, Pennsylvania. 2. Defendant is Jesse M. Kavanaugh, who currently resides at 124 Sunbury St., Apt B, Minersville, Schuylkill County, Pennsylvania. 3. Plaintiffand defendant have been bona fide residents m the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on August 26, 2000 at Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. The plamt~ffhas been adwsed of that counseling ~s available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. Plaintiffrequests the court to enter a decree of divorce. 9. The parties have no children. WHEREFORE, Plaintiff requests that This Honorable Court enter a decree in divorce. Dated: August 23, 2001 Respectfully submitted, Supreme Court ID #77227 227 No. High Street, PO Box 116 Duncannon, PA 17020 717-834-3087 Verification I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. Staci N: Kavanaugh ' -- ~'-(~ © r~ I Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees · Complete items 1, 2, and 3. Also complete item 4 if Restricted Deliveryis desired. ·, '.gzij;~. r nam~ and address on the reverse - - ~'th-~-we can return the card to you. · Attach this card to the back of the mailpisoe, or on the front if space pemfits. 1. Article Addressed to: 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Retum Receipt A. Received by {P/ease Print Clearly) ';;~ [] Agent [] Addressee D. I,~delive~yaddrsesdifferectfmmiteml? r-lyse If YES, enter dellve~'y address below: r-I No 3. ~Type ~]~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C,O.D. 4. Rsetrlcted Delivery? ~ Fee) [] Yes 102595-99-M-1789 STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUt413E RI.AIID COIJN'FY ~ NO. 01-5040 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce unde'r § 3301(c) of the Divorce Code was filed on August 28, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 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: St~ i4. Kavanaugh ..... STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF NO. 01-5040 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 unswom falsification to authorities. Date: /~/~9-o~ Staci N. Kavanaugh STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CI1}fBIgRL/dltD COUNTY, ~ENNSlrLV~NI~ NO. 01-5040 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on. 2. The marriage o fplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 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 unswom falsification to authorities. JESSE M. KAVANAUGH STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF ~IJI~iBlgRT, A~[D C~OUI'~.T y NO. 01-5040 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 o fproperty, 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 bythe 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 unswom falsification to authorities. Date: JESSE M. KAVANAUGH STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 01-5040 CIVIL ACTION - LAW IN DIVORCE SOCIAL SECURITY NUMBERS The Plaintiffs Social Security number is 586-46-9583 The Defendant's Social Security number is 197-54-4251. STACI N. KAVANAUGH, Plaintiff VS. JESSE M. KAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 01-5040 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: on September 10, 2001 via certified mail #7000 1670 0000 0385 1905, see attached. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff December 10, 2001; by the defendant December 10, 2001. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code. N/A Kevin E. Frosser, Esquire Attorney for Plaintiff IN The COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF .~.. PENNA. STACI N. KAVANAUGHf Plaintiff VERSUS JESSE M. KAVANAUGH, Defendant NO. 01-5040 DECREE IN DIVORCE AND NOW, , ~ / , IT iS ORDERED AND DECREED THAT STACI N. KAVANAUGH AND JESSE M. KAVANAUGH ARE DIVORCED FROM THE BONDS OF MaTRiMONY. , PLAINTIFF, , DEFENDANT, 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 BY THE COU~T: / PROTHONOTARY