HomeMy WebLinkAbout05-5859
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. Of; - $;n?
C;Ll~L~l-->\
v.
CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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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
A V AILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, I
COURTHOUSE SQUARE, CARLISLE, PA 17013.
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 LAWYER AT ONCE. IFYOU 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 LAWYER REFERRAL SERVICE
2 LIBERTY A VENUE
CARLISLE, PA 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. OS- -5t-!,''l
Ct'u,L 7&~
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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COMPLAINT
COUNT I - DIVORCE UNDER !i3301(c) or &3301(d) OF THE DIVORCE CODE
L The Plaintiff is Jennifer L. Kellison, who currently resides at Lot 108, Walmar Manor,
DiIlsburg, Pennsylvania, 17019,
2. The Defendant is Scott A. Kellison, Jr., who currently resides at 302 West Siddonsburg Road,
Dillsburg, Pennsylvania, 17019.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on July 3, 2004 in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Neither party is presently a member of the Armed Forces on active duty.
7. The parties have not entered into a written agreement as to alimony, counsel fees, costs, or
property division.
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8. Plaintiff has been advised that counseling is available and that she may have the right to
request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not
request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued.
9. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are:
(a) S3301(c). The marriage of the parties is irretrievably broken; and
(B) S330 I (d). The marriage ofthe parties is irretrievably broken and, at the appropriate time,
Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at
least two (2) years.
11. Plaintiff requests This Honorable Court enter a Decree of Divorce.
WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the
marriage between Plaintiff and Defendant.
Respectfully submitted,
Dated:
/ -----
fhomas M. Clark, Esquire
130 West Church Street
Dillsburg, P A 17019
(717) 432-9666
LD. # 85211
11-17' or
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VERIFICA TION
!, Jennifer L. Kellison, verify that the statements made in this Complaint are true and correct to
the best of my knowledge, information, and belief. ! understand that false statements herein are made
subject to the penalties of 18 Pa. CS. '4904, relating to unsworn falsification to authorities.
Date:
\1~05
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JE IFER r.; ELLISON
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
SCOTT A. KELLISON. JR..
Defendant
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ACCEPTANCE OF SERVICE
I accept service of Plaintiffs Complaint in Divorce in the above-captioned matter, which
service satisfies the requirements of the Pennsylvania Rules of Civil Procedure.
Datej;Jj/~
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cott A. Kellison, Jr.
302 West Siddonsburg
Dillsburg, P A 17019
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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AMENDED ACCEPTANCE OF SERVICE
I acknowledge that I accepted service and was on notice of the filing of the Plaintiffs
Complaint in Divorce in the above-captioned matter within thirty (30) days from the date of it being
filed, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure.
o",J/fa
cott A. Kellison,1r.
302 West Siddonsburg Road
Dillsburg, PAl 7019
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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AFFIDAVIT OF CONSENT
1. A complaint in Divorce under 9330I(c) of the Divorce Code was filed on
November 10, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry ofa 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
understand that false statements made herein are subject to the penalties of 18 Pa. C.S.
94904 relating to unsworn falsification to authorities.
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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AFFIDAVIT OF CONSENT
I. A complaint in Divorce under 93301(c) of the Divorce Code was filed on
November 10, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the 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
understand that false statements made herein are subject to the penalties of 18 Pa. C.S.
94904 relating to unsworn falsification to authorities.
,,;Yj6v
colt A. Kellison, Jr.
Defendant
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
]. ] consent to the entry of a final decree of divorce without notice.
2. I understand that] may lose rights concerning alimony, division of property.
lawyer's fees, or expenses if! do not claim them before a divorce is granted.
3. (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 made herein are subject to the penalties of ] 8 Pa. C.S. 94904 relating to
unsworn falsillcation to authorities.
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Date
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR.,
Defendant
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WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 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 made herein are subject to the penalties of 18 Pa. C.S. 94904 relating to
unsworn falsification to authorities.
Dat?l1/ttt;
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
JENNIFER L. KELLISON,
Plaintiff
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NO. 05-5859 CIVIL TERM
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v.
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CIVIL ACTION - LAW IN DIVORCE
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SCOTT A. KELLISON, JR..
Defendant
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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. Grounds for Divorce: Irretrievable breakdown under Section 3301(c).
2. Date and manner of service of the Complaint:
The Defendant Accepted Service of the Complaint on March 7.2006. evidencin1\
in the Amended Acceptance of Service that he was served within the thirtv(30)
da s from the date of the Com laint bein filed said Amended A.cce tance of
Service was filed with this Honorable Court on March 13.2006.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of
the Divorce Code: By Plaintiff: March 7.2006; By Defendant: March 7.2006.
(b) (I) Date of execution of the Affidavit required by Section 3301(d) of the
Divorce Code: N/A (2) Date of filing and service of the Plaintiffs Affidavit
upon the Respondent: N/A.
4. Related claims pending:
There are no related claims pendin2 with this Honorable Court.
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5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is attached:_
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce wasfiledwith
the Prothonotary: March 13.2006: Date Defendant's Waiver of Notice in
Section 3301(c) Divorce wasfiledwith the Prothonotary: March 13.2006.
Date:
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By:
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Thomas M. Clark, Esquire
Supreme Court LD. #85211
130 West Church Street, Suite 100
Dillsburg, P A 17019
(717) 432-9666
(Attorney for Plaintiff)
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF
PENNA.
JENNIFER L. KELLISON,
Plaintiff
No.
05-5859 CIVIL TERM
VERSUS
SCOTT A KELLISON, JR ,
Defendant
DECREE IN
DIVORCE
AND NOW, M..?l'1
DECREED THAT JENNIFER L. KELLISON
, ~b, IT IS ORDERED AND
, PLAI NTI FF,
AND
SCOTT A. KELLISON, JR.
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT
YET BEEN ENTERED;
A
PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
:Jeon \-+e ( L, ~f{ (~VYJ :
Plaintiff .
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File No.
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IN DIVORCE
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Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
or V' after the entry of a Final Decree in Divorce dated~,
hereby elects to resume the prior surname of -- r ~~s this
written notice avowing his / her intention pursuant to the provisions of 54 P .S. 704.
Date:~ ~e>>V\,1:A. L~
1 Slgn~e
COMMONWEALTH OF PENNSYLVANIA )
COUNTYOF0JMPul~ .
On the ~ day of ~ ' 200.k-, before me, the Prothonotary or the
notary public, personally appeared the above affiant mown to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
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