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HomeMy WebLinkAbout05-5171 KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05- sJ71 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE I CUSTODY 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 right 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, LA WYER'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 LA WYER AT ONCE. IF YOU DO NOT HAVE LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON 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 32 South Bedford St. Carlisle, PA 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. KRISTIN MUNDORF, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. os- ~/11 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Kristin Mundorf, by her attorneys, the Family Law Clinic, sets forth the following causes of action in divorce and custody: COUNT I DIVORCE UNDER TITLE 23 Pa. C.S. &&330](c) and Cd) OF THE DIVORCE CODE 1. Plaintiff is Kristin Mundorf, who currently resides at 426 Market Street, New Cumberland, Cumberland County, Pennsylvania 17070 since February 2004. 2. Defendant is Douglas Mundorf, who currently resides at 436 Market Street, New Cumberland, Cumberland County, Pennsylvania 17070 since 2002. 3. Plaintiff and Defendant have been bona fide residents of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 14, 2000, in New Cumberland, Cumberland County, Pennsylvania. 's. Plaintiff and Defendant have lived separate and apart since February 1,2004. 6. There have been no prior actions of divorce or for annulment between the parties. 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, plaintiff requests the court to enter a decree of divorce dissolving the marriage. COUNT II CUSTODY 9. Plaintiff repeats and realleges paragraphs I through 8. 10. Plaintiff seeks shared legal and primary physical custody of the following child: Name Austin Mundorf Present Residence 426 Market Street New Cumberland, P A 17070 Age I Yz The child was born not out of wedlock. The child is presently in the custody of Plaintiff, Kristin Mundorf, who resides at 426 Market Street, New Cumberland, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Persons Address Dates Kristin Mundorf, Ken & Hazel Dupler 426 Market Street New Cumberland, P A Birth (7/13/04) to Present The mother of the child is Kristin Mundorf. She is married. The father of the child is Douglas Mundorf. He is married. II. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with the following persons: Name Austin Mundorf Ken & Hazel Dupler Relationshin son daughter's paternal grandparents 12. The relationship ofthe Defendant to the child is that of father. Defendant resides with the following persons: Name N/A Relationshiu 13. 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 children pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare ofthe children will be served by granting the relief requested because: a. Plaintiff would like to continue to share in the upbringing, care, and support ofthe child; b. Plaintiff is prepared to provide the child with a stable home environment with adequate moral, emotional, and physical surroundings as required to meet the child's needs; c. Plaintiff would like the child to have substantial contact with both his mother and father; d. Plaintiff is willing to accept custody of the child; e. Plaintiff continues to perform parental duties when the child is in her care and enjoys the love and affection of the child; f. Defendant has a seizure disorder that may prevent Defendant from caring for the child for extended periods oftime or transporting the child safely. 15. 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 grant her shared legal custody and primary physical custody of the child, including reasonable periods of physical custody to be determined by the parties. Respectfully submitted, Date Ie! -; les UI1C~ fJ.J ci lA-{- Angel R velant Certified Legal Intern n L1 ilL /tULiO' .' . RAINS TOM ACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-3696 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this Petition are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. !l4904, relating to unsworn falsification to authorities. Dated: (0 I ~1c5 y .'\\, '~ ------- "'" "~ ~;. <J' o C) .-. ...- C) \ 0,) ~ :-oJ J..-n r11 p: ___,"n _,-,\:;1 ;~~\ ~\ '.~~ (:.::, ~, en -~.... c:? 'c.J C< - KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. NO. 05- f/71 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE I CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Kristin Mundorf, 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. I 'j' -," ,/ Date 1(' <)j{"') ! I Respectfully submitted, Ul/t.?;f12 ;:ZtJ. d tZk,;f- Angel ReVelant Certified Legal Intern . << l '/ . .' ,/" (S.1z:l~/lfQtJt'-Ii'fJ -~ ROB. IE. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON- WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 C-., ~.... ~:~~; o -n -::l M-i;J;i ---Ill ~:]t': . '-T, :,~F1 ;::..;:;n\ ~ C) c; ..-..; I (..) ~ C;..? C) KRISTIN MUNDORF PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA V. 05-5171 CIVIL ACTION LA W DOUGLAS MUNDORF DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, October 07, 2005 , upon consideration of the attached Complaint, at 4tb Floor, Cumberland County Courthouse, Carlisle on Friday, November 04, 2005 , the conciliator, at 9:30 AM it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. for a Pre-Hearing Custody Conference. At such conference, an elfort will be made to resolve the issues in dispute; or if this cannot be accomplished, to deline 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 permanent order. The court hereby directs the parties to furnish any and all existing Proteetion from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl!. FOR THE COURT. By: Isl Hubert X Gilrov. Esq. I}~ Custody Conciliator r' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For inl'lemation 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 courl. 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 17013 Telephone (717) 249,3166 ~ ~)P -"~4&>J J?l.t?/w .~ :2 ~ ~Jt, Jt;? t?/ t?/ . 7;:T j!. "'P'3''V ~ -~ 5'0- 0/ 0/ "- ";,"JrI8 I 11 : 1I11V O! UO SuDZ "" "''',' ::"11:J0 Ab'I/L,ji:'ii, r.-,~il" :;>"1.1..,') ',--~ LJ' ilj .~;J,,_...-,~' _I. KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY CERTIFICATE OF SERVICE I, Angelica L. Revelant, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of Divorce and Custody Complaint on Mr. Douglas Mundorf, residing at 436 Market Street, New Cumberland, Pennsylvania 17070, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Douglas Mundorf, on the 4th day of October, 2005 as evidenced by the attached green card. (lr/t.?1l~[lrt l{{(/ttll- Angelica Revelant Certified Legal Intern ( "{ D:< //B-LtiL/~Qt Lucy J on- Walsh, Esquire Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 7013 (717) 243-2968 .c.. \". ;~',.;., . 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 mail piece, or on the front if space permits. 1. Article Addressed to: o Agent o Addressee C. Date of Delivery ()&.il~ ~~~ ^l36 c.n1~ ~ VJ!uu.U ~i2h.l4.~1 f74 17(71) 3. Service Type ';:I;2J Certified Mail o Registered o Insured Mail 4. Restricted Delivery? (Extra Fee) ':;:r:f Yes 2. Article Number (T"ransferfromservlcelabel) 7<."(15 ~39/) oOCJ3 ~03';;- ~ 8;?-, PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY CUSTODY AGREEMENT .J -- THIS AGREEMENT, made this l.t- day oUht .1.<.(., t'"'-, 2005, between Kristin Mundorf, hereinafter Mother, and Douglas Mundorf, hereinafter Father, concerns the custody of their child: Austin Mundorf, born on July 13,2004. Mother and Father desire to enter into an agreement as to the custody of the child. Mother and Father agree to the following. 1. Mother and Father shall share legal custody of the child. 2. Mother shall have primary physical custody of the child. :3. Father shall have periods of partial physical custody of the child as follows: a. Father shall have custody of the child on Tuesdays and Thursdays for two (2) hours. Specific times are to be determined by the mutual agreement of the parties. b. Father-shall have custody of the child on alternating weekends on ~... '--(94~ J c. Saturday from 10:00 a.m. to 6Jl0 fl.Hl. Ilmi en SUllO!\)' fFijin. 1 \)11111 ll..m~ /' I." :') - /,.,r---: ~rr1:7 liM./' 6:00 p.m. ,:'>vV\C><i1 ~jey I't:::t''- {f'- On the week that Father does not have his weekend custodial periods, Father shall have custody of the child on Friday for two (2) hours. 4. Mother is responsible for transportation to and from Father's residence. Father agrees not to drive while the child is in his custody unless a medical emergency arises. . ~ 5. The parties shall alternate custody on all major holidays, including Thanksgiving, Christmas, New Year's, Easter, Memorial Day and July 4th beginning as follows: a. Father shall have custody of the child from 9:00 a.m. to 3:00 p.m. on Thanksgiving Day; Mother shall have custody of the child after 3:00 p.m on Thanksgiving Day. b. Mother shall have custody of the child until 3:00 p.m. on Christmas Day Father shall have custody of the child from 3:00 p.m. to 8:00 p.m. on Christmas Day. c. Custodial time periods on all other holidays shall be determined by the mutual agreement of the parties. 6. At least twenty-four (24) hour notice shall be given by either party who desires to change a scheduled visitation. 7. Neither party shall remove the child from the Commonwealth of Pennsylvania without advance notice and consent of the other party. 8. Mother and Father will notifY each other of any and all medical care the child receives while in the other party's care. 9. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. .. , - ... 10. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. '7 ./ . &../ . {L(( ,vVl I~N.')__/ /.. 'f . U',/" Douglis Mundorf, Defendant O'~;f i -;&ft[AA f Angeli Revelant Certified Legal Intern Counsel for Plaintiff ~'.'.".~:..~;- _ .,'_-"-:':'... c i , , John Fenstermacher, Esquire \._Sounsel for Defendant ~4' ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON- WALSH Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Phone (717)243-2968 Fax (717)243-3639 ~,~>.-,-~' ,,' C:J -, C'-l C:J r> C) r" c:> (') -d ~T~ Z1 h1 '~ c-, .'i:, :1-' ( ) ill ~~ j',) (n . :" C') .-<.: ..--------~ DEe 2 0 Z005 (1 KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 05-5171 CIVIL ACTION - LAW DOUGLAS MUNDORF, Defendant IN CUSTODY ORDER t.t AND NOW, this /!~t day of December, 2005, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquiishes jurisdiction. Hubel~ X. roy, Esquire Custody onciliator (; S :01 H~ 2Z :)30 ~OOZ AUV.l.Ci'<') llC2d 3H1 :10 3:)U:1C).--o::nH J 0 ~ KRISTIN MUNDORF, Plaintiff v. DOUGLAS MUNDORF, Defendant. And now, this ?O ~ DEe 2 2 2005 ,,{\ (, \ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY : 0..'5":- : NO. 5171 CIVIL TERM ORDER OF COURT day of ~OPW( ,2005, the attached Agreement -... is approved and entered as an Order of the Court. /f( C(/ \........- <.~ I r KEVJt-J It). HSsS J. ~~.;s ~ ~. ~ , t ,-. \" ~ \ .'* ~ ~ c\ ~ ~ 1~ t c \.,' <:" ~ r ~, N' ",{ ') '" t. "\ t -f" , ~ ~ t, t- 61] :2 bid OS J30 SOUl lV'..!i{'",-",,,t"'~;,) ::::"1' -Il'\ hw'l._r....,j\~.1 ,~:_\..-c~,! ~..Ir 1 -ll..J :;8;,+~()-031H KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY AFFIDAVIT OF CONSENT I. A Complaint in Divorce under 99 3301(c) and (d) of the Divorce Code was filed on October 3, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe Complaint. 3. I consent to the entry of a tinal 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. 94904, relating to unsworn falsification to authorities. Date~b\6lo lIrei' \t/~ Kristin Mundorf Plaintiff r-..> f."':~::l C~ c,..... .,., 1'1 c::r I W o ~-n ~:r~ '-nl-~ -;)C;.. A~;f< --,', -rJ . (., 'c-'I'n ;~~ ~"~ .-,: ~ ('1".) f',' c::> - KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO.OS-SI?1 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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. 94904 relating to unsworn falsification to authorities. Date 8-[3 [00 (M'-6 Kristin Mundorf Plaintiff (') ,-, C;:-:J ,= c..... ..,., '" c;:; I GO C) -n ,-I ~t~, rn'j";;::-; [D, ::2 -- c:? i"-.) 0) ----~---- KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE I CUSTODY NOTICE TO DEFENDANT If you wish to deny any of the allegations 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. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I. The parties to this action separated February 1,2004, and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. 1 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. 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 :J/,~ ((iCO , J/ i / undorf, Plain 0 ,-> 0 r:~':':> l C~-:J -n '.;;.,---'" -n __I \": rc ::j.:....n CJ rni':;' fT"l I Y G) ,...~ ,::,-. -0 .~ ;;,:, 0.) -,.;~f1~ 1'-' J..' ''':.~ 0'0 -- KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE I CUSTODY CERTIFICATE OF SERVICE I, Angel Revelant, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Plaintiffs Affidavit Under ~ 3301(d) of the Divorce Code on counsel for Defendant, John Fenstermacher, by first class mail as follows: John Fenstermacher, Esq. 5115 East Trindle Road Mechanicsburg, P A 17055 Date v1 & .i'l:> {ftlX Ii: (, L{^-,A-.-I- Angeli' evelant Certified Legal Intern ~~,~~ Robert E. Rains, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas Place, Esquire Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 to} ..,., r~,'I C.J o -, KRISTIN MUNDORF, P lainti ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(d) OF THE DIVORCE CODE I. 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 ,(7\ ~3 ( (, I .. . ,// --:.. /'V _ &,,,,1 { '/ ( J-- ~ , Dougllls Mundorf ,Defendant --rj r'~l C i".:' -, '," ~ (,) C~; --I -'f- fll ( ;,'1 l .... KRISTIN MUNDORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5171 CIVIL TERM DOUGLAS MUNDORF, Defendant CIVIL ACTION-LAW DIVORCE / CUSTODY PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown and separation for two years under S 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Service on Defendant by certified, return receipt requested, restricted delivery on October 4,2005. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by S 3301 (c) of the Divorce Code: by PlaintiffN/A ; by Defendant N/A (b)(]) Date of execution of the affidavit required by S 330 I (d) of the Divorce Code: Februarv 3, 2006: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: Filed and served Februarv 3. 2006. 4. Related claims pending: None. . ~ 5. Complete either (a) or (b): (a) Date and manner of service of the Notice ofIntention to Request Entry of Divorce Decree, a copy of which is attached: N/A. (b) Date plaintiffs Waiver of Notice was filed with the Prothonotary: Februarv 3, 2006. Date defendant's Waiver of Notice was filed with the Prothonotary: February 27,2006. Date /'/;;.1 j{ib , I (J_f( i' II' !Y/ A--# i Angelica evelant Certified Legal Intem ~t~ Robe ains, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire William G. Martin, Esquire Supervising Attomeys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 (717) 243-3639 !"-,."') :-:-J r,,_,) -_J ; ',~: 1...:' ",:+'It';+;+.:f.;+; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0+:+ + '\' 'f +++:+' . 'tiif.++ +:+:+:F. ;+;;+:;+;:f. n. . .. n. ... . . :f.++.:+' ;+;;+;+;+;;+;+:+'++.+.;+;+:+'+;+;+~ . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. KRISTIN MUNDORF, No. 5171 plaintiff VERSUS T1nfT~T..nc; MTlJ\H)ORF' . n~fpn,4.::!nt- DECREE IN DIVORCE 7.005 AND NOW, ~ , ';zooc" , IT IS OROERED AND 7YI a..-u, DECREED THAT KRISTIN MUNDORF AND nnfT~fA~ MTlNTlnRF' ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISOICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL OROER HAS NOT YET BEEN ENTERED; NONE B' THE COU~ j Tc:~ . ;\:+:+:t'+':++:+':t'+ +.+:t';+;+ ++++:i:+;+:+:+',.+++++ ++:t'+0+:++++++++:+:+'+? . 'f+++;+: n. .n PROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~ fi.v -7- ~<{ r~+,H-, <v L r 7 ;:/ '7 ~ h/;p. /'?? t'J/ L I