The URL can be used to link to this page

Home My WebLink About06-0578 . MICHAEL B. SCHULKINS, Plaintiff v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA ;NO, 010- f1P Ciu~L'--r~ AMELIA M, SCHULKINS Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 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 at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania, 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 Avenue Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 - I [i Courtney L Kis 1, Esquire Attorney for Plai iff MICHAEL B, SCHULKINS, Plaintiff v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 0 (p - 5'?f (!;;J -! h- AMELIA M, SCHULKINS Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary MICHAEL B. SCHULKINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, :NO. Dlo - 51? C!/U'tL't-f/Lw,,- AMELIA M, SCHULKINS Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE I. Plaintiffis Michael B. Schulkins, social security no, 168-36-6706, who currently resides at 14 Eastwood Drive, Carlisle, Cumberland County, Pennsylvania, 17013, 2, Defendant is Amelia M, Schulkins, social security no. 175-40-6441, who currently resides at 4 Stoney Run Road, Unit 10, DilIsburg, York County, Pennsylvania, 17109. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on June 14, 1969, in Cumberland County, Pennsylvania, 5, There have been no prior actions for divorce or annulment between the parties. 6, The Plaintiff is a citizen of the United States of America, 7, The Defendant is not a member of the Armed Services of the United States of America or its Allies, 8, The marriage is irretrievably broken, 9, The Plaintiff has been advised of the availability of counseling and that the Plaintiff . may have the right to request that the Court require the parties to participate in counseling, The parties to this action have been separated since December 26, 2005. 10, Plaintiff requests the Court to enter a Decree in Divorce, I L This action is not collusive, WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant JAMES, SMITH, DlETTERICK & CONNELLY Date \ ' clli Olt By: Courtney L ishel Attorney for Plainti ,Michael B. Schulkins Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA LD, No, 81509 . VERIFICATION I verifY that the statements made in this Complaint 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. Date: /,- ~ r; --(..){; /)tR~l J ffiI1 Michael B. Schulkins, Plaintiff P "9- - -p \. ..0 \l \:) V( ~ v ~ :!2 -+-- -L. (") ~ --CJ;-<~ S:l~:: ?';' <"'_.. ; :,~, c ::.L ':'.' .)..^ ~ \. ..~~ -<: ....., = C;:) C--' ~ o -Tl "i'!-n ~~~~: ~:3~~ -~f~:S t~j in -..::,~ ~,-, ::.:~ L. :r~ ::z N -.J -n :Jr. <:1 CJc o v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTI, PENNSYLVANIA : NO, 0 Co - c; 1 ~ MICHAEL R SCHULKINS, Plaintiff AMELIA M, SCHULKINS Defendant : CIVIL ACTION - LAW : IN DIVORCE ORIGINAL AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ss, COUNTI OF DAUPHIN AND NOW, this 7'" day of February, 2006, personally appeared before me, a Notary Public in and for the State and County aforementioned, Courtney L Kishel, Esquire, who, being duly sworn according to law, deposes and says that a copy of the Divorce Complaint was served on the Defendant, Amelia M, Schulkins, on January 31, 2006, by certified mail number 7004 1160 0002 1106 0988, as evidenced by the return receipt card attached hereto and made a part hereof. ourtney L Kisli, ' Esquire Sworn to and subscribejl before me this '/ f:::}I.. day of February, 2006, ~~A.~~.~f~ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria 8, laRue, Notary PubUc Derry Twp" Daup/1ln County My Commission Expires Nov, 8, 2009 Member. Pennsylvania Association of Notaries . Complete ttems 1, 2, and 3, Also complete Item 4 ~ Restricted Delivery I. desired. . Print your name and address on the reverse 10 thet we can return the can:! to you. . Attach this can:! to the back of the mailplece, or on the front ~ space pennlts, 1. ArtIcle~~ to: vl1'fe6c<- 7P &h<</h/? 7"<[ zf-r:Y r/U/z ~4'd ~.?)~/O Lh/~dV/ /'4/7/09 3, SeMce1VPe Ill'6Ortmod Mall C El<pMo Mall C RegIsl8f8d C -'m ReceIpt for MOIChondl8e e_MaIl C 0.0,0, 4, R_ Do/lwIy'I (Extra Fee) 7004 1160 0002 1106 D9&& 2.ArtIcIo_ (IIonaIiorllom_w.J PS Form 3811, February 2004 DcrmoUc Relum RocoIpt 10258&-02-M-1540 (") '? i ~\ I '-',\ -::.~ --\"'1 r-i r::;-- \ c:: - ~- c' \-:., MICHAEL B. SCHULKINS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-578 AMELIA M. SCHULKINS Defendant : CML ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 27, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(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 in 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.s.A. 94904, relating to unsworn falsification to authorities. Date: '$/'1/ p~ ;t/~y ~~. Michael B. Schulkins, Plaintiff (") ...., = ~ c ~ ;;: -ow, >- ~:D ~~n c: "L' C") zc- ITi C/) 1> I ~~ -/'--;.' -.J f<l:; ~C -a ~! _.~ ( , :x z )>C - ~ Z .. ~ s:- ~ w i :I I l , , ,I MICHAEL B. SCHULKINS, Plaintiff : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-578 AMELIA M. SCHULKINS, Defendant : CIVIL ACTION - LAW : IN DNORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 27,2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the 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. 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 ifI 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904, relating to unsworn falsification to authorities. Date: f! t/- <7" ~ y" - ,J;hdp~7 Amelia M. Schulkills, Defendant ~ ;%rn ~~- ~,..: ~c zC _U J" C: ~ ! i ~ ~ ~ ~i 63:3 ;i z~ - ~ ~ ~ <.W . 4. MICHAEL B. SCHULKINS, Plaintiff : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-578 AMELIA M. SCHULKINS, Defendant : CML ACTION - LAW : 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 (XX) 3301(c) ( ) 3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on January 31, 2006, as evidenced by the Affidavit of Service filed on record on February 8, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: by Plaintiff: August 4, 2006; by Defendant: August 4, 2006. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: . .. 4. Related claims pending: All claims have been settled pursuant to a Marital Settlement Agreement dated August 4, 2006. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: 6, Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301 (c) of the Divorce Code: by Plaintiff: August 4,2006; by Defendant: August 4, 2006. and, date of filing of the Waiver of Notice ofIntention to Request Entry of a Divorce Decree: Both Plaintiff's and Defendant's Waivers are being filed simultaneously with this Praecipe. JAMES, SMITH, DIETTERICK & CONNELLY, LLP 0- .Lj -0/2 Date: 0 Courtney L. Kishe Esquire Attorney for Plain Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA I.D. No. 81509 , . 2 ..... => ~ => .... "'" -or;; ~ ~ S2n" ':1' G") i zt',,--:, (/) l> I ~e:' -J 2;0 -0 -0 :a:: 9-~ J>c - ~ ~ .. &" ~ c...:> -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . PEN NA. . . MICHAEL B. SCHULKINS, No. 06-578 Plaintiff VERSUS AMELIA M. SCHULKINS, Defendant DECREE IN DIVORCE AND NOW, fi\.... (l~* ~ 2006 , IT IS ORDERED AND DECREED THAT Michael B. Schulkins , PLAINTIFF, AND Amelia M. Schulkins , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . BY THE COURT: . . . . . . \ . . -h 2- ~~ '1(J-QI.B r~'fI-~ 7:,~ ~,~ tI)(J. a/-j!,