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HomeMy WebLinkAbout05-6105 \ o LAW OFFICES OF DILS & DILS ARTHUR K. DILS, ESQUIRE Attorney I.D. No. 07056 10 17 North Front Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Kristine Marie Warner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KRISTINE MARIE WARNER, Plaintiff vs. No. 2005 - biDS Civil Term GEORGE ALBERT WARNER, Defendant CIVIL ACTION - LAW 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 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 available in the Office of the Prothonotary of Cumberland County, Cumberland County Courthouse, One Courthouse Square, 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 2 Liberty A venue Carlisle, PAl 70 13 (717) 249-3166 1-800-990-9108 KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - (",IDS CIVIL ACTION - LAW IN DIVORCE Civil Term GEORGE ALBERT WARNER, Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Kristine Marie Warner, an adult individual whose current address is 26 West Beale Avenue, Enola, Cumberland County, Pennsylvania 17025, and whose social security number is 169-16-9136. 2. The Defendant, George Albert Warner, is an adult individual, whose current address is 2192 Gleim Court, Eno1a, Cumberland County, Pennsylvania 17025, and whose social security number is 172-56-9603. 3. Plaintiff and Defendant were married on September 16,2000, in Ocean City, Maryland. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member ofthe Armed Services of the United States or its allies. -------------, . . 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children born of the marriage. 10. Plaintiff avers that the grounds on which this action IS based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, BY: CJL;( J9~ Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, P A 17102 (717) 232-9724 I.D. No. 07056 Date: ///0.2 / ), .J"' . \ , VERIFICATION I verify that the statements made in this Complaint in Divorce 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. Miu NanfViA- KRISTINE MARIE WAR/ R Date: /11/8/05 FJ \t- - ~ - .2::. ..:t (.) ~ \t Lv ~ (;-J I:. I le,;- d_\ I) l0 V -U Y- ~ +- .-,-- () ""'i\ , ~'," . (~ t"'.~~ ......1-1 ,") . ',~,"'" '-;? -- ()'l ... KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - 06105 Civil Term GEORGE ALBERT WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEAL TH OF PENNSYLVANIA COUNTY OF DAUPHIN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Arthur K. Dils, Esquire, who being duly sworn deposes and says that a true and correct copy of the Complaint in Divorce Under Section 3301(c) of the Divorce Code, has been served upon the Defendant, George Albert Warner, 2192 Gleim Court, Enola, Pennsylvania 17025, by First Class, United States Mail, Certified No. 7002 10000005 18768038. Attached hereto is the return receipt card executed by George Albert Warner dated December 12,2005, evidencing receipt of the s~me. .' {~flh/L::/tD 1/ ~rthur K. Dils, Esquire Sworn and subscribed to bd'ore rr;e this / 0L day ',/\ / . {,If I of -~.o-"7 L1.A.. ,2005. lila.0- (J V!J-/ Notary Public IlOWML SEAl lDRA~PU8IIC lmOf DMJP1tIIICG. !If COMM1SSlCJl ocr. 24. 20IIt .." SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY . 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 mailpiece, or on the front if space permits. 1. Article Addressed to: ~ O-~d-/.)~A-J e2/9oL ~~~~<L cz..-1L~/ ,f/ 4 I '70 oZ.J Ke..f77G:Lcreo -1d~ 2. Article Number (Transfer from service label) PS Form 3811 , February 2004 ~S~ B. Received by ( Printed Name) -"t;~U' D. Is delivery address different from Item 1? Yes If YES, enter delivery address below: 0 No 3. ~e lee Type Certified Mail egisrered o Insured Mail o Express Mail o Return Receipt for Merchandise !liI C,O.O. 4. Restricted Delivefl? (Extra Fee) , ~es 7002 1000 ODDS 1876 8038 10259S-02.M-1540 Domestic Return Receipt <] ....~ KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005-6105 Civil Term GEORGE ALBERT WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE A Fli'IDA VIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 29,2005. 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 in Divorce after service of notice of intention to request entry of the decree. I verify that t~le statementsm3de in this Affidavit are true and correct. r understand that false statements made herein are made subject to the penalties of Date: 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. ~ NafJG (jhYL- Kristine Marie Warner, Plaintiff 3 - 8..;)" - olp C',' ~>; "-<..~ ;i' KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 2005-6105 Civil Term GEORGE ALBERT WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 I (c) of the Divorcc Code was filed on November 29,2005. 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 in 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 made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: ,3 .;(& . o("s) ~-- George Albert Warner, Defendant , '. ~ "n ii-I,-- ., (; KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005-6105 Civil Term GEORGE ALBERT WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE WAlVER OF NOnCE OF INTENnON TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECnON 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree in 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 1 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. verify that the statements made in this Waiver are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: 3-~:A - D 0 fn~* IV ()J7e WCU"--:-- Kristine Marie Warner, Plaintiff .~ T .;, c:.~ --< KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005-6105 Civil Term GEORGE ALBERT WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree in 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. 1 verify that the statements made in this Waiver are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. Date: c.s. 94904 relating to unsworn falsification to authorities. ~iJ>' George Albert Warner, Defendant -3 'c2& . e>& (..', .._<, :.-J .;-1 -. C,.", ( -, -- -- KRISTINE MARIE WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA YS. No. 2005-6105 Civil Term GEORGE ALBER T WARNER, Defendant CIVIL ACTION - LA W IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the fOllowing infonnation, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievably broken under Section (X) 330 I (c) or ( ) 330 I (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By celiified mail on December 12,2005. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, March 22, 2006; by Defendant, March 26, 2006. (b) Date of execution of Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: N/A; Date of service of Plaintiffs affidavit upon Defendant: N/A. -~...,..."".-~.....----=-!>........""~.. _.~~N__"~ , . --- -- 4. Date of service of Notice of Intent to Finalize under Section 330 I (d) of the Divorce Code: N/A; 5. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff: March 22, 2006; by Defendant: March 26, 2006. 6. Related Claims Pending: None "'. , 1~ ,} " . /, (-P -c' ( . / .r"(/-'" BvC/t1. m/1 /~ '~_:I ' Arthur K. Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 Attorney for (x) Plaintiff ( ) Defendant ...... ~-,l c.' ..... ""..,,,,~,.de~'" -,."., . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~..:t:;f. ;!' . ~+++++++++++++ ++++++ +++++++ ++~"'+* .. ;f.'f;++ +;+;+. ;f+.+++'++'l'+ . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. KRISTINE MARIE WARNER, Plaintiff No. 2005-6105 Civil Term VERSUS GEORGE ALBERT WARNER, Defendant DECREE IN DIVORCE . . . . , , . , . . . , . . . . . . . . . . . . . . . . . . . . , . . . , , . . . , . . . , . . , . . . . . . . , , . , . ~ ..+~+++++++++++++~ AND NOW,~' '1.. ~ , IT IS ORDERED AND DECREED THAT KRISTINE MARIE WARNER , PLAINTIFF, AND GEORGE ALBERT WARNER . DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECO~~ IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; UDt-<2-- No claims have been raised. / . . . . . . . . . . . . . . . , . , . , . . . H /! .. PROTHONOTARY +++++ +"':t:+;t'++ '+' '+ +. +. +++++;!',.., .. . . . , . , . . . . . . . . . . . . . . . . . , . . . . . , . . . . . . . . . . J, "1 . 4f;:;.7 7' /fT-l7V>f r~,~ ~~?'7 <:~.-;p o-? ~""",.~) _y;;:;; (. ,i./ ..ifL' ..,r~ - ;;;Y ,'-' 7 /;/ . ;7c? [h 'VL.~