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Home My WebLink About05-5879 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF STEVEN W. BLOCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2005 - 5879 CIVIL TERM KELLY L. BLOCH, Defendant : IN DIVORCE NOTICE 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 in 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 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 17013, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717.249-3166 . , : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA STEVEN W. BLOCH Plaintiff v. : CIVIL ACTION. LAW : NO. 2005 - 5879 CIVIL TERM KELLY L. BLOCH, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 ~ OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is STEVEN W. BLOCH, an adult individual residing at 19 Timber Lane, Mt. Holly Springs, Cumberland County, Pennsylvania 17065, 2. The defendant is KELLY L. BLOCH, an adult individual who desires to keep her residence address confidential, but who is a resident of Cumberland County, Pennsylvania. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on May 22, 1999, in Carlisle, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken, 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. November 10, 2005 ~ t-V~ STEVEN W. BLOCH, Plaintiff HAROLD S. IRWIN, II Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 " , STEVEN W. BLOCH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTI5~ - LfW : NO. 2005 - 7 CIVIL TERM KELL'/I'Y L. BLOCH, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. November 10, 2005 ~ t-/~ STEVEN W. BLOCH, Plaintiff ~~~ ~J o<!~ ~' ~, . or--;. ~' --- ~ "'" d 0 r-' 0 c:::> \"- , , -n ~."" ,--\ '> cS. fYi JJ -0 01 ; .<-- , ) , - ?.;'": -::r::: ,...., ) t(~ - _.~ . ;:.~ ~~ -< ,.n HAROLD S. IRWIN, III ESQ. ATTORNEY ID NO. 82585 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-8090 ATTORNEY FOR PLAINTIFF STEVEN W. BLOCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. : CIVIL ACTION - LAW : NO. 2005 - 5879 CIVIL TERM KELLY L. BLOCH, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (!tl{!}ffi NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce, 2. That a certified copy of the complaint in divorce was served upon the defendant on November 16, 2005, by certified mail addressed to her at 924 Rockledge Drive, Carlisle, PA 17013, certified mail No. 7004 1350000372884950. 3. A copy of the sender's and return receipts are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. / i November 17, 2005 , I (/ / / ~) ".11)' .I \. L(l __,....A_ (/ Ii Harold S. Irwin, III Attorney for plaintiff ) , D LIl IT' ;:r- u.s. Postal Service," CERTIFIED M-.A:IL~f.RECEIPT (Domestic Mail Only; No Insurance Coverage Pro"ided) <0 <0 n.J l'- m D D D ~v ('i Po"",e $ 0 ~ Certified Fee <- Postmark Return Reciept Fee Here (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ D LIl m .-'l ;:r- D D l'- SENDER: COMPLETE THIS SECTION . . . . . . Complete items 1, 2, ,ancf3. Also complete item 4 if Restricted Delivery is desired. . Print your 'name and address on the reverse 50 that wii can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. t. Article Addressed to: D. Is delivery address different from item 1? If YES, enter delivery address below: 'f=-b ~\.. '-\ L ~ \e::c, '" <=\2U. ~oc.\<-'-~~'t;)" Q.~ ,YA- L"LDl3, 3. Service Type .:s:c.rtlfled Mall o Registered o Insured Mall o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra FeE~ ~es 2. Article Number (Transfer from service label)i . " . 'PS Form 3811, February 2004 7004 1350 pIJ03 7.2:88" q<f5:[]". Domestic Return Receipt 102595.02.M.1540 EXHIBIT ..A.. ~o c: ~ ~, C::~ ~':~~, ,:....'1 ~ .~~ o ~n ::;J --'--;; '~,:r~, ~~ (~; ;<~J -~:' , . ,4'1 C,) ,~ STEVEN W. BLOCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2005 - 5879 CIVIL TERM KELLY L. BLOCH, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about November 14, 2005. Service of the complaint was made by certified mail on November 16, 2005 (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. February~, 2006 .~u~ STEVEN W. BLOCH WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 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 herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. February)l2 ,2006 ~ t./ /Z~ STEVEN W. BLOCH r.....1 1""':) G._ :'--' r,-- Ii STEVEN W. BLOCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2005 - 5879 CIVIL TERM KELLY L. BLOCH, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about November 14, 2005. Service of the complaint was made by certified mail on November 16, 2005 (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. Jl~~. KE L Y L. H - February ~, ~06 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 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 immediateiy after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. herein are made subject to the penalties of 18 Pa.C.S. Section 4 authorities. February ~,2P06 I understand that false statements relating to unsworn falsification to -~U r'-' .:," " :-:J i:: rr-' c_.: ''','', L<; t",:' C~:- HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-11090 ATTORNEY FOR DEFENDANT STEVEN W. BLOCH Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION. LAW = NO. 2005 - 5879 CIVIL TERM KELLY L. BLOCH, 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 (c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about November 16, 2005, defendant was served with a copy of the divorce complaint by certified mail (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: FEBRUARY : v., 2006 By the defendant: FEBRUARY l- i ,2006 (b)(l) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 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: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301 (c) divorce was filed with the 0"7 Prothonotary: FEBRUARY ~, 2006 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: FEBRUARY 1 3 ,2006 February 2';, 2006 Id~/1 ~AROLD s. IRWIN, III Attorney for Plaintiff , ;-'-~) 'J ., ,-. ",j ;'",) c.- ,,' . . . " . . . . . , " . . . . . . . . . . . . , . . . . . Of.:f.'f.:1':f.:f.;f.+<+:'t;1!i .. . +;f.+++++++++'f.++++++++++++++++++++++++++++'++++++++++++++++++++ . . . . . . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + " " " + + + " + + + " " + + + + + " + " " + " + " + + + + " " + + " + " + + " + + + " " + + " " + " " + " + + + " + " + " + " " " + +++.++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++t IN THE COURT OF COMMON OFCUMBERLANDCOUNTY PENNA. STATE OF STEVEN W. BLOCH No. 2005 Plaintiff VERSUS KELLY L. BLOCH . " " + " " " . " . + + " " + " " " " " " " + + " " + , " " + " " . . . . . . . Defendant DECREE IN DIVORCE AND NOW. M2> J-1 LOOh, IT IS ORDERED AND DECREED THAT STEVEN W. BLOCH AND KELLY L. BLOCH ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLEAS 5879 CIVIL TERM , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . . NONE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . . . . . . . " " . . ATTE 'tJ4, . . . . . . . . . . ++ + +. +. '+' + . .. PROTHONOTARY J ~r:? ;7 /"?~ ~ v;I:? C C --'T~ ..fr z qr;#/ ,(~;> .;V?} ~j ~ - 7.- -.,