Loading...
HomeMy WebLinkAbout06-1523 In the Court of Common Pleas of Cumberland County, Pennsylvania BONNIE K. CLARK, ) Plaintiff, ) No. {)(P . /sc ~.23 vs. ) twJ ) KENNETH D. CLARK, ) CIVIL TERM Defendant. ) 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 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 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: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 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 LA WYER 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania BONNIE K. CLARK, ) Plaintiff, ) /<;;;3 vs. ) No. Of. ) KENNETH D. CLARK, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF A V AILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in 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 being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, 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 days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Michael S. Travis Attorney at Law ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717)731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania BONNIE K. CLARK, ) Plaintiff, ) ,>L-J{.l3 vs. ) No. ) KENNETH D. CLARK, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintift~ by her attorney, Michael S. Travis, respectfully represents: I. Plaintiff is Bonnie K. Clark, who resides at 210 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since August, 2005. 2. Defendant is Kenneth D. Clark, who resides at 816 S. 6th Street, Lebanon, Lebanon County, Pennsylvania, 17042, for an unknown period of time. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 4,2000, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Neither party is in the Military Service in the United States. 10. Plaintiff requests the court to enter a decree of divorce. 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. S 4904, relating to unsworn falsification to authorities. Date: 3//(,/ 0 ~ , , ~h~ j( ~ Bonnie K. Clark, Plaintiff /c,r /~// /~ el . Travis Attorney for Plaintiff J.D. # 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 \t~ ~ ~. ~ L ......... .-J '^, ~, "-. ~ ~ ~ 'b " ...... ~ 2 ,;;\' ""01'1':, ~~j }7. {. i:-:, y r~ ::;? ~-1. "-.. , "'" \.1', v..... " ' , ' \::')' ",,\1\ ',,> <:::::' \'0 ''<., " ""'- t ,... ~ ~, ~~ ~ ....... "'" c;.? cr :::I" ~- ':;0 - 0" -0 -;$. o o N '~ In thl: Court of Common PIcas of Cumberland County, Pennsylvania BONNIE K. CLARK, ) Pllliutiff, ) VS. I No. 1-06-1523 ) KENNETH D. CLARK, ) CIVIL TERM Defendant. ) IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint on behalf of Kenneth D. Clark, and certifY that I WIl authorized to do so. .~.. y, {~- Megan~tor, Esquire address: '-S 1.. 6 S. fjfus+~+- ~~~<Y\( ~r+ J!oY2 Date: (\\GJC~ dd 200~ I LO[0 U.LV S IWlf.L f\: rrS6 reI. I.!L XV,f oo.rr 90..Z;;;C(1 ~ r-",) G) o .. w " ~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-01523 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLARK BONNIE K VS CLARK KENNETH D R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CLARK KENNETH D but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania, to serve the within COMPLAINT - DIVORCE On March 29th , 2006 , this office was in receipt of the attached return from LEBANON Sheriff's Costs: Docketing Out of County Surcharge Dep Lebanon County Postage 18.00 9.00 10.00 39.73 .78 77.51 03/29/2006 MICHAEL TRAVIS ~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this jq'E: )cor., day of ~ A.D. Prothonotary ). . "-,. In The 'Court of Common Pleas of Cumberland County, Pennsylvania Bonnie K. Clark VS. Kenneth D. Clark No. 06-1523 civil Now, Mi'lrr.h 17. 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Lebanon County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . r~~~~ Sheriff of Cumberland County, P A Affidavit of Service Now, ,20 ,at o'clock M. served the within upon at by handing to a copy of the original and made mown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ .. . -.. DIVORCE COMPLAINT BONNIE K. CLARK Michael S. Travis, Esquire 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 CASE NO. 06-1523 Vs. (Return to Cumberland Co. Sheriff) KENNETH D. CLARK Docket Page 23424 STATE OF PENNSYLVANIA } COUNTY OF LEBANON } 55: Basil E. Achey, Deputy Sheriff, being dUly sworn according to law, deposes and says that he served the within DIVORCE COMPLAINT upon KENNETH D. CLARK, the within named DEFENDANT, by handing a true and attested copy thereof, personally to him on March 22, 2006 at 2:26 P.M., at 816 South 61t1 Street, Lebanon (Lebanon City), Lebanon County, Pennsylvania, and by making known to him the contents of the same. And that the person upon whom service was made as aforesaid is the DEFENDANT named in the within COMPLAINT, Deponent deriving his information from KENNETH D. CLARK, the within named DEFENDANT. Sworn to and subscribed before me this 241t1 day of March, 2006 SO ANSWERS, Notary Public {J~ <:. O-t:.."ell r DEPUTY SHERIFF Cl<,fu 1f~'" fd~iL SHERIFF (~ N 1ARL~L SEAL KIMBcR'Lv , O"n'''-Q '" 0.' I <:'.1 I !..., ;f'i'~'t'iC.I'. !\nary rUb/Ie City Ii l,)a:lia, Lecal"" Couoty, Pa, My C.mmlssion t'plres D"'~ler 17, 2006 SHERIFF'S COSTS IN ABOVE PROCEEDINGS Advanced Costs paid on 03/22/06 Check No. 53366 Costs Incurred: Refund: Check No. 18498 Amount $100.00 Amount $ 39.73 Amount $ 60.27 All Sheriffs Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make retum thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 Michael S. Travis 10 No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 KENNETH D. CLARK, Defendant. In the Court of Common Pleas of Cumberland County, Pennsylvania ) ) ) ) ) ) No. 06-1523 BONNIE K. CLARK, Plaintiff, vs. CIVIL TERM 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 ~ 3301(c)(I) of the Divorce Code. \ 2. Date and manner of service of the complaint: Service accepted by Megan Castor, Esquire, on March 22, 2006. 3. Date ofexe~on of the affidavit of consent required)0 ~ 3301(c) of the Divorce Code: by Plaintiff on V '1 ' 2006; by Defendant on ~ <; , 2006. , 4. Related claims pending: No economic claims were raised. 5. prothonotary: Date Plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the ,2006. prothonotary: Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the '2~~ ~. Travis Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-FAMILY DIVISION BONNIE K. CLARK, Plaintiff KENNETH D. CLARK, Defendant NO. 2006-01523 AFFIDAVIT Affiant, having been duly sworn on oath (or having affirmed) states as follows: 1. I am Kenneth D. Clark, spouse of Bonnie K. Clark. 2. She has asked me about a doll collection, and I do not know what collection she is referencing. 3. I do not know the location of any doll collection belonging LO Bonnie K. Clark. 4. In the event that I learn of the location of a doll collection belonging to Bonnie K. Clark, I will promptly inform her. J!.D~ Sworn and subscribed to before me this <r;"\-tI day o f _~~ ~ I\. \. , 2 006 . '~-L-;~ .t ~~y b"1.ic 11I Of PmlS'Il_' MlJlARIAl SEAL EllICA D. WEAVER, lot\RY PUlIIC CITY OF LEBNlOI, LEIlAIlOII COUIl1Y II\' COMMISSIOII DPtRES 0CIll8EIl1D. - l~feA_ t (J.7: , ". -......-'" (~) ':"11 .-1 -C"T} h1:r::- -" C::" :< C" .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BONNIE K. CLARK, Plaintiff, KENNETH D. CLARK, Defendant. ) ) ) ) ) ) No. 06-1523 CIVIL TERM IN DIVORCE VS. AFFIDAVIT OF CONSENT I. A complaint in divorce under S 3301(c) of the Divorce Code was filed on March 16,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 ofthe decree. 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. S 4904 relating to unsworn falsification to authorities. DATED: & ~ J<l-ot .,8~ K d~ Bonnie K. Clark, Plaintiff fO\~Q\ \.fL1\W2J[tk- ~:0 n r', c-: ::"f1 ~,~i- ~ l~' , (.,) -,". "._..J (::-:: (;.'> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KENNETH D. CLARK, Defendant. ) ) ) ) ) ) No. 06-1523 CIVIL TERM IN DIVORCE BONNIE K. CLARK, Plaintiff, VS. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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 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 in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: d, - / 7- b t ~~I(d~ Bonnie K. Clark, Plaintiff . -;:-;-.." ...) "n .-j ~ <- C" ,.....- ; c.rJ ::r:~" <;_:':' (:;~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BONNIE K. CLARK, Plaintiff, ) ) ) ) ) ) No. 06-1523 CIVIL TERM IN DIVORCE vs. KENNETH D. CLARK, Defendant. AFFIDAVIT OF CONSENT I. A complaint in divorce under S 3301(c) of the Divorce Code was filed on March 16, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. DATED: C~fjG . , L~D(P: r\\ r-~ <:;.',) (~:::1 ,;.i'-' ';.--:fl .-1 :r: rn '- C ,-' \ W "'\':l''' '-'- C' C" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BONNIE K. CLARK, Plaintiff, KENNETH D. CLARK, Defendant. ) ) ) ) ) ) No. 06-1523 CIVIL TERM IN DIVORCE VS. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 6 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 in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: iP~h , ~ft, ,:.;;:':;> '""C\ r," ..~ ~!. ,..;.r' :::l '-- C' (..,) 9 co c;.' Of. Of. Of. Of. Of. Of. ;t; 0f.0f. ;t; Of. IN THE COURT OF COMMON PLEAS STATE OF Ba\lNIE K. CLARK, ;t; ;t; Of. ;t; ot; Plaintiff, VERSUS KmNEIH D. CLARK, Defendant. AND NOW, OFCUMBERLANDCOUNTY PENNA. No. 2006-1523 DECREE IN DIVORCE </~ S-. , :Joo~ ,IT IS ORDERED AND DECREED THAT Bonnie K. Clark AND Kenneth D. Clark , PLAI NTI FF, , 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; None. No econanic claims were raised. ot; ot; ot; ot; ot; 0;9)1. ST:~ ex~ K- ~..k. ~ PROTHONOTARY J. ~j~A Of. ;t; ot; Of. ot; Of. 0f.0f. Of. Of. Of. Of. ""'+; ;t; Of. '+' ;t; '+' '+' '+' Of. ;t; Of. it; it; Of. it; ;t; it; ;t; '+' ;t; ;t; Of. ;t; Of. ;t; ;t; '+' '+' Of. ;t; Of. ;t; '+' '+' ot; ot; it; ot; '+' '+' '+' '+' '+' Of. '" Of. ot; '" '+' '" '" '" '" '+' Of.'li ~ b :Z ~ ~~ 'Jc?-~-t. ~-P+ ~~~-~ ?(/-~'c..