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HomeMy WebLinkAbout06-2801 () KATHERINE M. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW KENNY R. JOHNSON, Defendant ; NO. ()(p- J 801 : IN DIVORCE CIVIL TERM 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIA nON 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 KATHERINE M. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW KENNY R. JOHNSON, Defendant : NO. 01..- .=t 3'61 : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Katherine M. Johnson, an adult individual currently residing at 316 Forge Road, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Kenny R. Johnson, an adult individual currently residing at 131 Rex Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 5, 2004 in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, ffie, Esquire Jar Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: 5. 1I.0& ~~~ ~ Vol ""'\ - - ...j <::><:\ 0, ~ ~ o ~ ,...., "".. <g? ~ 0;" ...... C1 C 4 ?:}':' ~,- >,,- ~i~- 7;;':-:. ~;':..\ -;'"P--- "- ~ .- ...) Q. ~ ~~ -~J,q ,:-?q, \--'5-:'1 ~?~ (~~ ~ ~ .- -- .- ...) KATHERINE M. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW KENNY R. JOHNSON, : NO. DlP - ~8OJ Defendant : IN DIVORCE CIVIL TERM PRAECIPE TO THE PROTHONOTARY: Please reinstate the Divorce Complaint previously filed in the above captioned action. DATE:~().d--16 b . Gri , Esquire GRIFFIE & A SOCIA TES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 () "" 0 C-:::) r-- ~-:;:'> -q -- er' -I I-r. - fll;::;;:-: ]V tJ. '-,",' T'J () -0' '- -n <:''5 ;:::rn --) .:-,~.~~ 0 ~D "'-, I..C -< KATHERINE M. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW KENNY R. JOHNSON, ; NO. (/.J) - OBO \ Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE I confirm that I did this /(\ day of ---'JUL r ' 2006, hand deliver a true and attested copy of a Complaint in Divorce 0 Kenny R. Johnson at the following address: , (Constab e) S ((,lilYI'\. of- s:.0J j tJU b.wl -I (j ~ JDt! &9 ~ 94f I d~ WI5'1.tI'\\.t/I ~ (~~ IlOTMIlAL SEAl ""'J.80~~ ~~PIR{SAP1Il 7 lO01 [ -..-......,-, , .i;'-,:: L",.;\;':," 't!tI'C\~,\r,,:, ?'J',!:'it,tJ tt!'mt~ vr\l;"'~\";~: ~':'J~'''r.,:'t1.,.jli.,,; ~~" p. <.C'_,'" .1.,' ). "~!''''.... .,1....0."" ~);:"l\~~L)).":' ",.",qy.t??,\~,mtn!'! ...... ."<'1 !. -7 :'1 --,"'1 Wl l:: ... ,-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE M. JOHNSON, No. 06-2801 Plaintiff CIVIL ACTION - LA W v. KENNY R. JOHNSON, Defendant In Divorce PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Kenny R. Johnson, Defendant in the above. captioned matter. Date: 'i} /4J ~V Sean M. Shultz, lfe Attorney LD. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Defendant ~ ......... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE M. JOHNSON, No. 06-2801 Plaintiff CIVIL ACTION - LA W v. KENNY R. JOHNSON, Defendant In Divorce CERTIFICATE OF SERVICE AND NOW, this ~ day of September, 2006, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following with a copy of the foregoing Praecipe by first class, United States Mail, postage pre-paid, addressed as follows: Bradley L. Griffie, Esquire Griffie & Associates 200 North Hanover Street Carlisle, Pennsylvania 17013 Respectfully submitted, KNIGHT & ASSOCIATES, P.C. s~~~ Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Defendant FIUser Folder\Finn Doc.\Gend0cs200614002-1 praecipe,enler, wpd ,,-. -..t, ,../" - - -- C" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE M. JOHNSON, Plaintiff No. 06-2801 In Divorce v. Civil Action - Law KENNY R. JOHNSON, Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. 17,2006. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on May 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. 4. 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 prior to a Divorce Decree being handed down by the Court. 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. K!~n~ Date:~, 2007 ST[f1 to and sumbed before me this IAJ~ \71,~kJ Notary pUbhC'f COMMONWEALTH OF PENNSYLVANIA No\aIi8I Seal Dolly M. HouSel. NotarY PU~ Midd~T~.. cumbelland 24 2010 F:\User Folder\Firm Docs\Gendocs2007\4002-1affconsent,wpd My ComrniSSlOrl ElcpiI88 Sept. . Member, Pennsylvania AssoCiation of Notarl.' r-..:> = = -....I ~ ~ f11 :0 r :-R E:l ()(L - -I -.-' 'C'\'t /,,-n :::,~O om :::-t ~ C- :;tlzo z N W ::8 :JJ: N N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE M. JOHNSON, Plaintiff No. 06-2801 In Divorce v. Civil Action - Law KENNY R. JOHNSON, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER f3301(Q OF THE DIVORCE CODE 1. I 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 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: 111 ~ \ D l' KL~~~ F:\User Folder\Firm Docs\Gend0cs2007\4002-1 waiver,notice,wpd rc:; <.:;:;:> --' c.- ~ rv c....:> ~ ~~ ~ 1)9 Oc' -:,~.~. ...;f ~ >,t~::) ocfO '(5 fr." ...-\ ~ :tW'" ::::; - - rv {",J KATHERINE M. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W KENNY R. JOHNSON, Defendant : NO. 06-2801 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on May 17,2006 reinstated on June 22, 2006 and served on July 12,2006 as indicated in Acceptance of Service. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF J8 PaC.S. ~4904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. DATE: '7 SON, Plaintiff o c -'. ~ ~ = --J .., '-" -n L- ..._--" ,.'-'" -":"'" c,.) o w C) KATHERINEM. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W KENNY R. JOHNSON, Defendant : NO. 06-2801 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRVE AND CORRECT. I UNDERSTAND THAT FALSE S'i'ATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. DATE: --L/J~}Q7 icdL-JJ \ L-- KATHERINE M. j~SON ~ 0 = -n --' c.- :-~.:;:;,~ ~1~ 0-') o ??;': 0' Cl KATHERINE M. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW KENNY R. JOHNSON, Defendant : NO. 06-2801 : IN DIVORCE CIVIL TERM 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) 3301(d)(I) of the DiYoree Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on July 10, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code: by Plaintiff: 1/24/07 by Defendant: 1/18/07 (b) (1) Date of execution of the affidavit required by ~3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: (b) Date of plaintiffs Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: January, 30, 2007 Date defendant's Waiver of Notice In ~3301 (c) Divorce was filed with the Prothonotary: January 23, 2007 ~ (;:? ::..J ...-n \"':. cP \ - ~ .-' -.:t:.:!:1 f\'\ f::: ~.d1 q !~}(i\ (f~~~ ".......... ~ -0 :;i.::' - .- (,..) v=> :t: :t: '" '" '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Katherine M. Johnson No. 06-2801 Plaintiff VERSUS Kenny R. Johnson Defendant DECREE IN DIVORCE AND NOW, r~~"- ~ ~ ~ J () : 0'1 e..."f'J · /007 , IT IS ORDERED AND DECREED THAT Katherine M. Johnson , PLAI NTI FF, AND Kenny R. Johnson , 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; f{{}^l- ,.; PROTHONOTARY ATTEST: ,r' '" '" '" '" ,.; "''''''' ,.;'" ~ '" "'''' ~~ ~~~ ~ ~ J. ~ ~7 ~ k;' ~ ;4//...." ~Ji. L.O- L- 1;> ~ ~ ?-/f'~'" I4>.PO L(}- L' t' '. .. '.' ' ,. ..... ~. .