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Home My WebLink About05-5583IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Matthew Aaron Pergar Plaintiff vs. No. Andrea Lynn Kendi Defendant 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 Plaintiff. You may lose money, property or other rights important to you, including the right to demand marriage counseling. When the ground for divorce is indignities of irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary for Cumberland County: ONE COURTHoUBE SG, J^Pr C.AQL15Li PA 170)3 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service Allegheny County, Pittsburgh: (412) 261-0518 Beaver County, Beaver: (412) 728-4888 Berks County, Reading: (610) 375-4591 Blair County, Hollidaysburg: (814) 693-3090 Bucks County, Doylestown: (215) 348-9413, (800) 479-8585 Chester County, West Chester: (610) 429-1500 Cumberland County, Carlisle: (717) 249-3166 Dauphin County, Harrisburg,: (717) 232-7536 Delaware County, Media: (610) 566-6625 Erie County, Erie: (814) 459-4411 Lackawanna County, Scranton: (570) 969-9600 Lancaster County, Lancaster: (717) 393-0737 Lehigh County, Allentown: (610) 433-7094 Luzerne County, Wilkes-Barre: (717) 822-6712 Mercer County, Mercer: (724) 342-3111 Monroe County, Stroudsburg: (570) 424-7288 Montgomery County, Norristown: (610) 279-9660 Northampton County, Easton: (610) 258-6333 Philadelphia County, Philadelphia: (215) 238-1701 Washington County, Washington: (724) 225-6710 Westmoreland County, Greensburg: (724) 834-8490 York County, York: (717) 854-8755 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Matthew Aaron Pergar Plaintiff vs. No. 0,.r- SSF3 Andrea Lynn Kendi Defendant DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Matthew Aaron Pergar , who currently resides at 1713 English Dr Mechanicsburg, Pennsylvania 17055. He has resided at this address at least since May 2005. 2. Defendant is Andrea Lynn Kendi, who currently resides at 206 Fourth St, Scotdale, Pennsylvania 15683. She has resided at this address at least since September 2005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 26, 2001 , at Paradise United Methodist Church, Mount Pleasant, Pennsylvania, County of Westmoreland. 5. The Plaintiff is in the military or naval service of the United States or its allies within the provisions of the Servicemember's Civil Relief Act of 2003 and its amendments. The Defendant is not in the military or naval service. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. Date: a oc m? Q o oS PL-- Plaintiff (Pro Se) COUNSELING NOTICE UNDER Pa.R.C.P. RULE 1920.45(a)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6) Indignities Section 3301 (c) Irretrievable Breakdown Mutual Consent Section 3301(d) Irretrievable Breakdown Two-Year Separation where the court determines that there is not a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the Prothonotary Office of the Cumberland County court. OWC Goy IT-)AOUJS SQUARE _ C/?2LISt G ?A 7 0),3 Case Duration of Marriage Years Married 5- 10- 20- 25- 29 Check Appropriate Box Below X Unknown IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Matthew Aaron Pergar Plaintiff vs. No. Andrea Lynn Kendi Defendant DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Matthew Aaron Pergar, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his or her own knowledge that the Defendant Andrea Lynn Kendi herein is not in the military service as defined in the Servicemember's Civil Relief Act of 2003 and its Amendments thereto, for the following reasons: At no time during our marriage have I ever witnessed my spouse report to or make contact with military personnel. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. Plaintiff IN WITNESS THEREOF, I have hereunto set my hand and seal. Dated: 0??' 0 c1nhH- COMMONWEALTH OF PENNSYLVANIA Notarial Sea; Joseph L. Grove. Notary Public Silver Sprang Tvar., Cumber and County My Commission Ezp'.rrs June 18, 2009 Member. Pennsywa^i,, n.=rnq,atinn al Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Matthew Aaron Pergar Plaintiff Andrea Lynn Kendi Defendant FAMILY DIVISION vs. No. DIVORCE VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA. C.S., §4094, relating to unsworn falsification to authorities. &1ahi2p '4" ?w Plaintiff Date: d $ GrTO _P1C-P aOOS l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Matthew Aaron Pergar Plaintiff vs. No. C[Ut???fL"'1 Andrea Lynn Kendi Defendant DIVORCE Divorce Information Sheet PLAINTIFF INFORMATION Name: Matthew Aaron Pergar Address: 1713 English Dr Mechanicsburg, Pennsylvania 17055 Social Security No: 201-62-9009 DEFENDANT INFORMATION Name: Andrea Lynn Kendi Address: 206 Fourth St Scottdale, Pennsylvania 15683 Social Security No: 175-68-0949 Curtis R. Long Prothonotary Office of the i3rotbonotarp ?umberrar?b ?outttp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor p5" - SSW CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573