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HomeMy WebLinkAbout05-3141 .J v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.yS - J J c.f J c;;.J. ,J~ CIVIL ACTION - LAW KATHRYN E. KEGRIS, Plaintiff GALEN J. KEGRIS, 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, 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 at the Dauphin County Court House, Front and Market Streets, Harrisburg, PA 17101. 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 1 7013 Telephone: (717) 249-3166 or (800) 990-9108 By: Dated: ) -/b-t1S- Dennis . Sh ffer, Esquire Attorney 1.0. #39165 111 North F rant Street P.O. Box 889 Harrisburg, PA 17108-0889 ATTORNEYS FOR PLAINTIFF 1 KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Os- .31'-1/ CIVIL ACTION - LAW GALEN J. KEGRIS, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kathryn E. Kegris, an adult individual, who currently resides at 12 Louis Lane, Enola, Cumberland County, Pennsylvania, since October 1999. 2. Defendant is Galen J. Kegris, an adult individual, who currently resides at 612 Range End Road, Lot 93, Dillsburg, York County, Pennsylvania, since May 1995. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 14, 1982 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The parties have lived separate and apart since 1984. 1 9. The Plaintiff avers that the grounds on which the action is based is that that the parties hereto have lived separate and apart for a period of at least two years, and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce. Respectfully submitted, By: rpl{ ~ Dennis W She r, Esquire Attorney J.D. # 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 Telephone: (717) 234-4121 Attorneys for Plaintiff 2 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. Section 4904. relating to unsworn falsification to authorities. ~~e~"A athryn . Kegris, Pia . Dated: u.;ft>4~ ..e;- 1 KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. v. CIVIL ACTION - LAW GALEN J. KEGRIS, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. The parties to this action separated on June, 1984, and have continued to live separate and apart for a period in excess of twenty-one (21) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. 94904 relating to unsworn falsification to authorities. Dated:~P.c2 /OJ- 1~r"t:~~:. ryn E. Ke ris aintiff 1 KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. v. CIVIL ACTION - LAW GALEN J. KEGRIS, Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301/d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request 1 Divorce Decree, the Divorce Decee may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: Galen J. Kegris, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. 2 ~ Jt ~(\ -. ()' ~ W G' ~ 0. \ 1...& ...l ...l\ -.. ~ () "'\ U 0 '"" 0 c':::) c.. C::;l ." "-" 'c< ,- =:l rr c:: _.l-::IJ ..~ nll'~ -0\.:2'1 ~ -.J :py t::-? (!-.) ='" ~:~} ~f~ - ':":[11 J> ,-- (':4 , ~v-i 1'0 :rJ -< CO -< ~ KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3141 CIVIL TERM v. CIVIL ACTION - LAW GALEN J. KEGRIS, Defendant IN DIVORCE CERTIFICATE OF SERVICE I do hereby certify that on the 20th day of June, 2005, I served a true and correct copy of the Complaint in Divorce; Plaintiffs Affidavit Under Section 3301 (d); and a blank Counter-Affidavit, on the Defendant, Galen J. Kegris, by U.S. mail, certified, return receipt requested, restricted delivery, as evidenced by the attached return receipt card, addressed as follows: Mr. GalenJ. Kegris 612 Range End Road Lot 93 Dillsburg, PA 17019 By: @/(4/~ , Dennis R. Sheaffer, Esquire Attorney 1.0. #39182 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 ATTORNEYS FOR PLAINTIFF Dated: November 1, 2005 . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpleoe, or on the front if space permits. 1. Article Addressed to: (~/(0,j "(?'~II_S. : i ~ K<'/~) t (:Jvt !{d ,:l (t'?, . ~/' -j ).) }/ !~)"'}LII:j' I I, / /, - L' / (I 3. SaNies Type l.f(Certified Mail o Regl$tered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. De\\\/ery? (Extra Fee) -Yes 2_ Article Number ,"r,a.'lsfer from service label) 7005 0390 0002 9074 0901 .______n___ f-orm 3811, February 2004 Domestic Return Receipt 10',S9S.0N" ~.;) ,.~.., C:.:") C.,r1 (j -IJ ::;:! i''i111 ,- :;,:In'! ~;.)C... , --:j(t, ~{~ :iJ: -< 5 -.;;;:; o -0 -- -,~" ry en co '. (,.-) ." KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3141 CIVIL TERM v. CIVIL ACTION - LAW GALEN J. KEGRIS, 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 Section 3301 (d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Defendant was served with the Complaint in Divorce: Plaintiffs Affidavit Under Section 3301 (d): and a blank Counter-Affidavit. on June 20. 2005. by certified mail, restricted deliverv. return receipt requested. (See Certificate of Service filed to the above term and number.) 3. the Divorce Code: (b)(1) Date of execution of the affidavit required by section 3301 (d) of June 12, 2005 respondent: 20. 2005. (b)(2) Date of filing and service of the plaintiffs affidavit under the Affidavit filed on June 17. 2005 and served on the Defendant on June 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 hereto: September 30. 2005 By: Dated: November 1,2005 Dennis . Shea r, Esquire Attorneyl.D. #39182 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 ATTORNEYS FOR PLAINTIFF 1 n i-:~ '" c-;;) "-'" "" o -n =t filiI! ;7~3 '::::j() ''-., ~~~ <:.n :< ~- C) -.;: .c.- -,:;; w w .. ' TUCKER ARENSBERG Attorneys September 30, 2005 Mr. Galen J. Kegris 612 Range End Road Lot 93 Dillsburg, PA 17019 Re: Kathryn E. Kegris v. Galen J. Kegris Docket No. 05-3141 Civil Term (In Divorce) Dear Mr. Kegris: As you know, this office represents the interests of your wife, Kathryn E. Kegris, with regard to the above-referenced matter. In order to finalize your divorce, I am enclosing a Notice of Intention to Request Entry of as 3301(d) Divorce Decree. You need not take any action in this matter. On or about October 24, 2005, I will file the necessary papers with the Court in order to have a final decree in divorce issued. Once the final decree in divorce is signed, I will forward a copy to you. If you have any questions regarding this matter, please do not hesitate to contact me. Very truly yours, @.;W~-- Dennis R. Sheaffer DRSjcak Enclosure cc: Kathryn E. Kegris (w jenc.) Tucker Arensberg, P.C. 111 N. Front Street PO. Box 889 Harrisburg, PA 17108 p.717.234.4121 f. 717.232.6802 www.tuckerlaw.com 1500 One PPG Piace Pittsburgh, PA 15222 p.412.566.1212 f.412.594.5619 " ~.. , KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3141 CIVIL TERM v. CIVIL ACTION - LAW GALEN J. KEGRIS, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF A !l3301 (d) DIVORCE DECREE TO: Galen J. Kegris 612 Range End Road Lot 93 Dillsburg, PA 17019 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the ~ 3301 (d) affidavit. Therefore, on or after October 24, 2005, the other party can request the court to enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 2 Liberty Avenue Carlisle, PA 1 7013 Telephone: (717) 249-3166 or (800) 990-9108 " A , 1/1. 1/, Il ' d By: Dated: September 30,2005 Dennis " Saffer, Esquire Attorney I.D. #39165 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 ATTORNEYS FOR PLAINTIFF 1 '. ,.. KATHRYN E. KEGRIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. v. CIVIL ACTION - LAW GALEN J. KEGRIS, Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request 1 ". Divorce Decree, the Divorce Decee may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Date: Galen J. Kegris, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. 2 --- --~~.-- (') ...., (') = f~ = " en % X C) --n -:: nl roc..: -a 1"""1'1 :c C~'} +' ('-'\ (,) \,. '-:-:'j ~ {':;j <:: (5 ,"0 ."... ;is -., L.) -< -< .' .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,. . '. . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~~~~ ~ ~~~ ~ ~ ~~~~~~~. ~..~ . .. ..~~ . ~ ........++..+++++++++~ . IN THE COURT OF COMMON PLEAS : . OF CUMBERLAND COUNTY : . . STATE OF PI=:NNA. KATHRYN E. KEGRIS, Plaintiff No. CIVIL TERM 05-3l41 VERSUS IN DIVORCE GALEN J. KEGRIS, Defendant DECREE IN DIVORCE AND NOW, De-G, 200S IT IS ORDERED AND ~-~, DECREED THAT KATHRYN E. KEGRIS , PLAINTIFF, AND GALEN J. KEGRIS , 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; ATTES /r)( C;) t~ ,: ~,. :1'_ ~ ..~..~.... PROTHONOTARY . +++ + ++ +++++ ++++ + +++++++++++++++++++++++++? . ~++++++++++++++++ + + ++++++ . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . #;/ r ~. ~,;/.. ;;0 "}. '" . ;}L (' //T1 //?';17 cO 1- e/ W"rJIfY ;i/'l :? /1;1' ?7~' ';#.J~! - '~/ Y' .