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HomeMy WebLinkAbout05-3908 VELVET J. KAUFFMAN, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No.05- j1.o9 Civil Term KEITH E. KAUFFMAN, Defendant ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 VELVET J. KAUFFMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. {},5- 3Cf 0'1; Civil Term KEITH E, KAUFFMAN, Defendant ACTION IN DIVORCE DIVORCE COMPLAINT AND NOW comes the Plaintiff, Velvet J.Kauffman, by and through her attorney, Jane Adams, Esquire, and files this Complaint in Divorce of which the following is a statement: COUNT I - DIVORCE 1. Plaintiff is Velvet 1. Kauffman, a competent adult individual, who resides at 151 Amy Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Keith E. Kauffman, a competent adult individual, who has resided in New Bloomfield, Perry County, Pennsylvania, 17068, since July 2004, 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 29, 1995 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - CUSTODY II. Paragraphs I - 10. are herein incorporated by reference. 12. Plaintiff seeks to confirm custody regarding the couple's child, Olivia A. Kauffman, date of birth, August 26, 1995, 13. A custody complaint has been filed contemporaneously with this divorce complaint under the above-captioned docket number. 14. Plaintiff believes the best interest of the child will be served by granting the relief requested. WHEREFORE, Plaintiff requests the court to enter an Order of Court confirming custody of the child. Respectfully submitted, Date:)' t 4 . DS- Jane dams, Esquire LD, .79465 64 So th Pitt Street Car isle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERlFICA nON 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, 94904 relating to unsworn falsification to authorities. Date: I' /If · os- J-C'\ - ~ ~ ~ ~ )-' ~ - ~ ~ -b ~ ~ ~ ~ .. ),j -....\ - ~ ""\'- ~ -.. 0 0\ \\d () t T"-.,') ~~:::; 0 <...n -;1 ..... --rY I';'"j -,-, r:3 c:) -~ VEL VET 1. KAUFFMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. ; No. 0:) - 3C(o't Civil Term KEITH E. KAUFFMAN, Defendant : ACTION IN DIVORCE PETITION FOR CUSTODY l. Plaintiff is Velvet J. Kauffman, who currently resides at 151 Amy Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Keith E. Kauffman, whose address is P.O. Box 636, New Bloomfield, Perry County, Pennsylvania, 17068. 3. Plaintiff seeks to confirm custody regarding the following child: NAME DOB ADDRESS Olivia Ann Kauffman 8/26/95 151 Amy Drive Carlisle, Pa. 17013 The child was born in wedlock. Mother currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Velvet 1. Kauffman 151 Amy Drive Carlisle, Pa. 17013 July 2004 - present Velvet J. Kauffman 75 Bonnybrook Rd. Carlisle, Pa. 17013 November 2004 - July 2004 Velvet 1. Kauffman 14 Creekview Drive Rebecca Wilson, Carlisle, Pa. 17013 maternal grandmother July 2003 - November 2003 Velvet J. Kauffman Keith E. Kauffman 151 Amy Drive Carlisle, Pa. 17013 1995 - July 2003 The mother of the child is: Velvet J. Kauffman, currently living at 151 Amy Drive, Carlisle, Pa. 17013. She is married to Keith E. Kauffman; however, a divorce is pending. The father of the child is: Keith E. Kauffman, who currently resides in New Bloomfield, Pa. 17068. He is married to Velvet 1. Kauffman; however, a divorce is pending. 4. The relationship of plaintiff to the child is that of MOTHER. The persons that the Plaintiff currently resides with are: the child. 5, The relationship of defendant to the child is that of FATHER. Plaintiff believes that the Defendant currently resides alone. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Mother believes that it will be in the best interest of the child to enter a custodv order confirming the current arran~ements of the parties; this will ensure stability for the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter an Order of Court granting custody of the child. Date:!' {S -0> 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. g4904 relating to unsworn falsification to authorities. Date:,. lL1. O~ ~~ 1',_) c'- /,,) .-:;.;;:) ,'~:::;' <:_'"1 (J ';-, c..., VELVET J. KAUFFMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-3908 CIVIL ACTION LA W KEITH E. KAUFFMAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Au!:ust 04, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. . the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 15, 2005 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or penn anent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: /s/ Jacqueline M. Verney, Esq. Custody Conciliator y The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of ] 990. For infonnation 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE AN ATTORNEY 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 South Bedford Street Carlisle, Pennsylvania I 7013 Telephone (717) 249-3166 -~~ b ~~4? -'7$; ~ ~ ~rrJ.-27IV ~ 505,,$ ~ .$P~ ~~".,w; ~..5.,$ ",r'l: c,nnz "". .~ 1\.1 s- c"I, .." Gi.) ''...0 ; ,',. :ql -!O .J\.......-. VELVET J. KAUFFMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : No. 05 - 3908 Civil Term KEITH E. KAUFFMAN, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE; AND NOW, this August 18,2005 I, Jane Adams, Esquire, hereby certify that on August 8, 2005, a certified true copy of the NOTICE TO DEFEND, COMPLAINT IN DIVORCE, and CUSTODY COMPLAINT was served, via cel1tified mail, restricted delivery, return receipt requested, addressed to: T Keith E. Kauffman P.O. Box 636 New Bloomfield, Pa. 17036 DEFENDANT . CornpIet& Items 1, 2, and 3. Also complete nem 4 W Restricted Delivery Is desired. . Print your name and address on tha revama so that we canretum the card to you. , . Attach this cerci to the back of the mallplace, or on the front W space permits. t. Artlele_to: B. ocelved by (Prlntod./NameJ - 1- f1. !L......., D.I.doIlveryaddrossd_tromItem1? W YES, enter delivery add.... belew: ONo t~~fi )<lJVff~!l", "P-D~i3ox ('3h ""fie! J I PA \70'1(, , o ExpIeos Moll o Return Receipt lor_... 2. Article 7005 0390 0003 2635 3853 label) PS Form 3811, Febru8ry 2004 Don_ -.n AoooIpt . .r11N: ---- Q ~~; so, --c l:~_: rp\.\: G?\~- ,.., ~ oJ' ~ ~ 9...,., nihj (; ~~ :.:~~, -0 9~ ::;t Q - "'I - ~ N ::::~ \- -,J>~ i-' ~-~~ t.::~. '?-; .-(. - RECEIVED orT 2 0 LOOS BY: <1 --- \ VELVET J. KAUFFMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05 - 3908 Civil Term KEITH E. KAUFFMAN, Defendant : ACTION IN DIVORCE ORDER AND NOW, this z. ,. day of ()thJ;w., ,2005, having reviewed the attached agreement between the parties dated October 17,2005, it is hereby ORDERED and DECREED that the agreement shall be entered as an ORDER of Court. cc: ~ Adams, Esquire, for mother r""I.F'"\ ' 1 t,_, ~. '.,,1 'j I ./ ", ,1 i VELVET J. KAUFFMAN, Plaintiff : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNSYL VANIA RECEIVED Bynr~Z005 V. : NO. 2005-3908 CIVIL ACTION-LAW KEITH E. KAUFFMAN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 21st day of October, 2005, the Conciliator having been advised that the parties have reached an agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, onciliator n <_.~ '-"" G'. VELVET J. KAUFFMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 3908 Civil Term KEITH E. KAUFFMAN, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under section 3301(c) of the Divorce Code was filed on August 1, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service ofthe 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 also wlderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 1/. J- 3 . OS- .~~ Keith E. Kauffinan, 0 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(0) AND 63301(<1) OF THE DIVORCE CODE I. I consent to 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 th:nalties of 18 Pa.C.S. ~4904 relating ~ unJorn falsification to au 'ties. Date: r j. ;}.. ") .0 '; ~ Keith E. Kauffinan t (", c,> C:::;) " "~I r."., r,,) u:' - . VELVET 1. KAUFFMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA vs. No. 05 - 3908 Civil Term KEITH E. KAUFFMAN, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under section 3301(c) of the Divorce Code was filed on August 3, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3, [consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verifjr that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa,C.S. 4904, relating to unsworn falsification to authorities. Date: S ,\'-l / ~c)~ Velvet J. Kauf , Plaintiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(0) AND 63301(d) OF THE DIVORCE CODE I. [consent to 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. [ verifjr 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. -3./.{, \:D~W.'~ (') "" = 0 c: = '''' -'n f~r'. :x ~-:J > ..-'- :;0 rl1~l r_:- ~ (..11 ;:::;::::-C-'i ::r ;?~ PC SY an; :2.: --< --j .....'0,. --< c:> 5.:1 co .< ~~ -. VELVET J. KAUFFMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 05 - 3908 Civil Term KEITH E. KAUFFMAN, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under &3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, delivered on: AUlrust 8. 2005. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: March 1,2006. By Defendant: November 23, 2005. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: November 29,2005. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: March 14,2006. Date:?( f 4 ( ~ e Adams, Esquire . No. 79465 '. 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff --- o i;~ l'~ n" ~~..:> c;:,;, CJ c.~, :::P.: ;:.:,.. ::u () oJ ::-J Fii21 "'Or; ~nO .~:1 (~ ;c}F;~: \;;1 '-:;:1 -< UI ~ -.I:.. w C) 'f'''''''' ;+:'f 'f't;;+:Of . . . . . . . . . . . . . . .. . . . :t;+: :+;'f.'t';+:0+'f.;+:0+ 0+ ;+: ;+:;ti'+i ;+:;+:'f:+' ;+::+. 'H . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Velvet J. Kauffman, Plaintiff PENNA. STATE OF . . . . . No. No. 05 - 3908 Civil Term . . . . . . . VERSUS . . . . . . Keith E. Kauffman, Defendant . . . . . . , . . . . DECREE IN DIVORCE ~~ -:z...t.bc, , IT IS ORDERED AND . . . . . . . AND NOW, Velvet J. Kauffman , PLAINTIFF, DECREED THAT . . . . . . . . . . Keith E. Kauffman , DEFENDANT, AND 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; None. ~ ..... - . . . . , . . , . . . . . . . . . . . . ATTEST; PROTHONOTARY . . . . . 'f ;+:;+: ;ti;+:'l';+:0+'f.O+ ;ti:++:;+:;!' :+;f:t'''' . 'to 4' 4' '+;!':+. + +: +: 'l' 'l' +: Of ++: +4'4' H. . . . . . . , . > > . > > . > . . . . , . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . 'H h? $ ~!~ ??-~u c,"'!:?/V f:!/' % r~ .(~;? /~;p . ". . . '~'t;7 [~ ,!. 'J(/. [t"' c: