HomeMy WebLinkAbout06-29166
KEVIN L. KAUFFMAN IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
COUNTY, PENNSYLVANIA
v. ) CIVIL DIVISION
CHRISTINE A. KAUFFMAN ) NO. ! e r m
DEFENDANT )
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIM 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 GROUNDS FOR THE DIVORCE ARE 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.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY, LAWYERS
FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE
THE RIGHT TO CLAIM ANY OF THEM. . A /I
Address: 706 LOUISA WE
MECHANICSBURG, PA 17050
Telephone: (717) 805-2487
KEVIN L. KAUFFMAN IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
COUNTY, PENNSYLVANIA
V. ) CIVIL DIVISION
CHRISTINE A. KAUFFMAN ) NO. e)6-2111,
DEFENDANT )
COMPLAINT IN DIVORCE
COMES, the Plaintiff, KEVIN L. KAUFFMAN, by FILING PRO SE, who files this
Complaint in Divorce a statement of which is as follow:
The Plaintiff is KEVIN L. KAUFFMAN, an adult individual currently residing at
706 Louisa Lane, Mechanicsburg, Pennsylvania 17050.
2. The Defendant is CHRISTINE A. KAUFFMAN, an adult individual currently
residing at 1016 Country Club Road, Camp Hill, Pennsylvania 17011.
3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania
for at least six (6) months previous to the filing of this Complaint.
4. The Plaintiff and Respondent were married on February 1, 1997, in the State of
Pennsylvania.
5. There have been no children bom of this marriage and wife is not now pregnant.
6. There have been no prior actions of divorce or for annulment between the parties.
Neither party is a member of any branch of military.
8. The marriage is irretrievably broken.
9. 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.
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10. The Plaintiff, KEVIN L. KAUFFMAN, respectfully requests that this Court grant
this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce
Code and that a Decree of Divorce be entered.
I verify that the statements made in the Complaint are true and correct. I understand that
false statements made herein are subject to penalties of 18 Pa. C.S.A Section 4904, relating to
unswom falsification to authorities.
Respectfully submitted,
Signature of Plaintiff
Name: KEVIN L. KAUFFMA
Dated: $-- ' (y - Z d d 6
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
}ss.
County of r C )
B ore e, hte subscriber, a Notary Public in and for said Commonwealth and
_??Y71Pdr County, personally appeared KEVIN L. KAUFFMAN, who, being
duly sworn according to law, deposes and says that the facts contained within the foregoing
Complaint in Divorce are true and correct to the best of his knowledge, information, and belief,
and that he is authorized to make this Affidavit.
2 z? / - I
Signature
n Name_ KEVIN L. KAUFFMAN
d subsc ' d before me this , ,,,?
of p A 4- /J 20 OU .
IA
TH OF PNNSYLVAN
NOTARIAL SpublE M. DEDERERNoy
Hill Boro, Crf20 0009
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KEVIN L. KAUFFMAN IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
)C.m6crl COUNTY, PENNSYLVANIA
V. ) CIVIL DIVISION
CHRISTINE A. KAUITMAN ) NO. M ND
DEFENDANT )
ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE
PLEASE take notice that ],CHRISTINE A. KAUFFMAN, Defendant, was provided with
a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept
service of same. I further enter my appearance in this action for It purposed.
Defendant
Address: 1016 COUNTRY C ROAD
23 MAY 2006
CAMP HILL, PA 17011
Telephone: (717) 612-9771
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PROPERTY SETTLEMENT AGREEMENT
Dated I q M1J , 2006
between
KEVIN L. KAUFFMAN
and
CHRISTINE A. KAUFFMAN
-A 0?-,2.916 0 V-1 I Term
I Separate Residences
2 The Marital Residence
3 Personal Property
4 Debts
5 Maintenance and Support
6 Pension Plans
7 Claims in Estates
8 General Claims
9 Legal Representation
10 Full Disclosure
11 Merger and Survival
12 Notices
13 General Provisions
PROPERTY SETTTLEMENT AGREEMENT
AGREEMENT. made this 17 day of May , 2006, between KEVIN L.
KAUFFMAN, residing at 706 LOUISA LANE, MECHANICSBURG, PENNSYLVANIA
17050 (hereinafter referred to as the "Husband"), and CHRISTINE A. KAUFFMAN, residing at
1016 COUNTRY CLUB ROAD, CAMP HILL, PENNSYLVANIA 17011 (hereinafter referred
to as the "Wife").
WITNESSETH:
WHEREAS, the parties hereto were duly marred in HARRISBURG,
PENNSYLVANIA, on February 1,1997; and
WHEREAS, there are no children of the marriage, and none are expected; and
WHEREAS, the parties, in consequence of disputes and irreconcilable
differences, have separated and are now living separate and apart from each other, and have
voluntarily and mutually agreed to continue to live separate and apart; and
WHEREAS, each party has been advised of their rights to obtain full disclosure
of the other party's financial condition, including income, expenses, assets, liabilities and assets
transferred, and have obtained full and satisfactory disclosure of such; and
WHEREAS, the parties desire to settle their financial, property and other rights
and obligations arising out of the marriage and otherwise.
NOW, THEREFORE, in consideration of the mutual promises and agreements
herein contained, the parries hereto agree as follows:
1. Separate Residences. The Husband and Wife shall continue to live separate
and apart from each other. Each may reside from time to time at such place or places as each
may determine in his or her sole discretion.
Each shall be free from harassment, interference, molestation, authority and
control, direct and indirect, by the other, as fully as if he or she were single and unmarried.
Neither of the parties hereto shall interfere with the other in his or her respective liberty of action
or conduct, and each agrees that the other, at any and all times, may reside and be in such place
and with such relatives, friends and acquaintances as he or she may choose.
2. The Marital Residence. The Wife is to be the owner of premises located at
1016 COUNTRY CLUB ROAD, CAMP HILL, PENNSYLVANIA 17011 (hereinafter referred
to as the "House"). The Wife shall continue to be the sole owner of the House, free of any right
or claim of the Husband. The Wife is solely responsible for payment of the mortgage of
$1,282.82 per month.
3. Personal Properly. The parties acknowledge that they previously have made
a division and settlement of their personal property and personal effects, and that each is and
shall be the owner of all personal property now in his or her possession. Each party shall own,
have and enjoy, free of any right or claim of the other party, all property hereafter acquired by
such party.
4. Responsibility For Debts. Each party represents and warrants that he or she,
as the case may be, has not incurred or contracted any debts or obligations for which the other or
any property of the other may be liable, either individually or jointly. Each party agrees that he
or she shall be solely responsible for the payment and performance of all debts and obligations
presently in his or her respective name and he or she hereafter shall not incur any debts or
obligations for which the other may be liable. Each party shall indemnify and hold the other
harmless from and against any costs and expenses resulting from a breach or violation by such
party of any representation, warranty or covenant contained in this Article 4.
5. Waiver of Maintenance and Support. Each party represents that he or she is
in good health and is self-supporting, and that his or her resources and income are sufficient to
provide for his or her own proper maintenance and support, now and in the future, in accordance
with the standard of living he or she now enjoys. Each of the parties hereby declares that each
does not desire or require any maintenance or support from the other party. Each party hereby
waives any claim which he or she may have against the other for alimony, maintenance or
support, and agrees that their respective duties to support and maintain the other are extinguished
in consideration of the provisions of this Agreement. Each party recognizes that this waiver
includes rights that he or she otherwise might have or acquire under 23 Pennsylvania Statutes
Section 3701 et seq., any amendment thereof or any successor statute. Neither party under any
circumstances, ordinary or extraordinary, shall hereafter seek or require from the other any
alimony, maintenance, support or similar payment. This waiver by the parties of maintenance
and support shall survive, and not be merged in, any judgment, decree or order of any court.
6. Waiver of Claims to Pension Plans. Each of the parties hereto hereby waives
and releases any and all claims or rights with respect to any pension or retirement plans of the
other party.
7. Mutual Release and Discharge of Claims in Estates. Each party shall have
the right to dispose of the property of such party by last will and testament in such manner as
such party may deem proper in the sole discretion of such party, with the same force and effect
as if the other party had died. Each party, individually and for his or her heirs, executors,
administrators, successors and assigns, hereby waives, releases and relinquishes any and all
claims, rights or interests as a surviving spouse in or to any property, real or personal, which the
other party owns or possesses at death, or to which the other party or his or her estate may be
entitled. Each party expressly waives all rights which he or she now or may hereafter have
pursuant to any provisions of the laws of any State or country which may have jurisdiction over
2
the estate of either party hereto on his or her death, as now or hereafter in effect, to elect to take
in contravention of the terms of any will of the other party, whether now or hereafter executed.
Each party recognizes that this waiver includes rights that he or she otherwise might have or
acquire under 20 Pennsylvania Statutes Section 2203 et seq., any amendment thereof or any
successor statute.
8. Mutual Release of General Claims. Except as expressly provided in this
Agreement, each party hereby waives, releases, renounces and forever discharges all rights of
dower, curtesy, statutory election and all other similar rights under the laws of Pennsylvania or
any other State, and all other claims, causes of action, rights or demands, known or unknown,
past, present or future, which lie or she now or hereafter has, might have. or could claim to have
against the other or any present or future property of the other by reason of the marital
relationship or any matter, thing or cause whatsoever. Nothing in this Article 8 shall be deemed
to prevent either party from enforcing the terms of this Agreement or from asserting any rights or
claims expressly reserved to either party in this Agreement.
Nothing herein shall impair or waive any cause of action which either party may
have against the other for a dissolution of the marriage or any defenses either may have to any
such cause of action.
The parties, by execution of this Agreement, have provided for a fair and
equitable distribution of all property belonging to the parties. Any reference or allocation with
regard to property, whether real or personal, is made for the purpose of settling all claims to such
property by the parties and for the purpose of effectuating an equitable distribution of all
property between the parties. The distribution of property provided for herein shall be binding
on both parties, now and in the firture. Each party hereby waives, releases, renounces and
forever discharges all claims or rights to any property owned by the other or allocated to the
other under this Agreement, and all claims or rights for maintenance, support, counsel fees, suit
money, or any similar claim, except as expressly provided herein.
9. Legal Representation. In connection with this Agreement, the parties are
represented Pro Se.
Each party acknowledges that all of the matters embodied in this Agreement,
including all terms, covenants, conditions, waivers, releases and other provisions contained
herein, are fully understood by him or her; that he or she is entering into this Agreement freely,
voluntarily and after due consideration of the consequences of doing so; and that this Agreement
is valid and binding upon him or her.
10. Full Disclosure. Each party has made independent inquiry into the complete
financial circumstances of the other, and acknowledges that he or she is fully informed of the
income, assets and financial prospects of the other, and is satisfied that full disclosure has been
made.
11. Merger and Survival. In the event that either party obtains a judgment,
order or decree of divorce against the other, the provisions of this Agreement expressly shall be
3
incorporated in the text thereof with such specificity as the court shall permit and by reference as
may be appropriate under law and the rules of the court. All of the provisions of this Agreement
shall be incorporated in any judgment or decree of divorce. This Agreement shall survive, and
not be merged in, any judgment, decree or order, and the parties hereto shall remain bound to the
performance of this Agreement in accordance with the terms hereof.
12. Notices. Any notice, demand or other communication required or permitted
under this Agreement shall be in writing and shall be delivered by hand or by Federal Express
courier or by certified or registered mail, return receipt requested, with postage prepaid, to the
parties at their addresses first above written or at such other addresses as they may designate by
notice hereunder.
13. General Provisions. This Agreement is entire and complete and embodies
all understandings and agreements between the parties. No representation, warranty, agreement
or undertaking of any kind or nature has been made to either party to induce the making of this
Agreement, except as is expressly set forth herein. The parties acknowledge that there is no
other agreement, oral or written; existing between them. No oral statement or prior written
matter outside of this Agreement shall have any force or effect.
This Agreement shall not be amended, modified, discharged or terminated except
by a writing executed and acknowledged by the party sought to be bound. Any waiver by either
party of any provision of this Agreement, or of any right or option hereby, shall not be deemed a
continuing waiver and shall not prevent such party from thereafter insisting upon the strict
performance or enforcement of such provision, right or option.
The parties agree that each of them, upon request of the other party or the legal
representatives of the other party, shall execute and deliver such other and further instruments as
may be necessary or desirable for the purpose of giving full force and effect to the provisions of
this Agreement, without charge therefore.
Each party shall notify the other, by registered or certified mail, of any change of
address or telephone number within five days of such change.
This Agreement and all rights and obligations of the parties hereunder shall be
construed according to the laws of the Commonwealth of Pennsylvania. If any provision of this
Agreement should be held to be invalid or unenforceable under the laws of any State, country or
other jurisdiction, the remainder of this Agreement shall continue in full force and effect.
This Agreement shall be binding upon the parties hereto, and their respective
heirs, executors, administrators, successors and assigns.
4
IN WITNESS WHEREOF, the parties hereto have executed this Agreement on the date first
above written.
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CHRISTRM A. KAUFFM N
COMMONWEALTH OF PENNSYLVANIA, COUNTY OF0,)WI A ss.
On this (Aay of 2006, before me, the undersigned officer, personally
appeared KEVIN L. KAUFFMAN, n to me (or satisfactorily proven) to be the person
whose name is subscribed to the within agreement, and acknowledged that he executed the same
for the uses and purposes therein contained.
IN WITNESS WHEREOF I hereunto s4fny hand and official seal.
otary Public
mission mission expires on
COMMONWEALTH OF PENNSYLVANIA, COUNTY O jobs.
On this ?vl day of 006, before me, the undersigned officer, personally
appeared CHRISTINE A. KAUFFMA k own to me (or satisfactorily proven) to be the person
whose name is subscribed to the within agreement, and acknowledged that she executed the
same for the uses and purposes therein contained.
IN WITNESS WHEREOF I hereunto seVrrfy hand and official seal.
?
Public a??f _1r?aCJ ?^7
>n expires on 1
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
F M. DEDERER, Notary Public
l Boro, Cumberland County
iccion Exoires Aug. 20, 2009
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KEVIN L. KAUFFMAN IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
m4 P,f Gi COUNTY, PENNSYLVANIA
V. ) CIVIL DIVISION
CHRISTINE A. KAUFFMAN ) NO. O ? -2, q C `t Y t Term
DEFENDANT )
AFFIDAVIT OF CONSENT
I . A complaint in Divorce under Section 330I(c) of the Divorce Code was filed on
5--1q-Z-06 (date:).
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and 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 REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I . I consent to the entry of a final decree of Divorce without notice.
2. 1 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unswom falsification to authorities.
Date:
Defendant
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KEVIN L. KAUFFMAN
v.
PLAINTIFF, )
)
IN THE COURT OF COMMON PLEAS
&t?be r(o'
COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHRISTINE A. KAUFFMAN ) NO. - v io
DEFENDANT )
AFFIDAVIT OF CONSENT
I . A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:)
.5 -19 - 2006
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and Complaint.
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 REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of Divorce without notice.
2. 1 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 r ti to
unswom falsification to authorities.
Dater
Plaintiff --N
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KEVIN L. KAUFFMAN IN T1-1E COURT OF COMMON PLEAS
PLAINTIFF, )
COUNTY, PENNSYLVANIA
V. ) CIVIL DIVISION
CHRISTINE A. KAUFFMAN ) NO. 2004- O21I6 Cl J1I -1 /rlA
DEFENDANT )
MILITARY AFFIDAVIT
I, CHRISTINE A. KAUFFMAN, Defendant, being sworn, certify that the
following information is true: [Mark all that apply]
I am not on active duty in the armed services of the United States.
I understand that I am swearing or affirming under oath to the truthfulness of the
claims made in this affidavit and that the punishment for knowingly making a false
statement includes fines and/or imprisonment. 1
DATED: -/Q ?G
Signature of Defendanf '
Name: CHRISTINE A. KAUF AN
Address: 1016 COUNTRY CLUB ROAD
City, State, Zip: CAMP HILL, PA 17011
Telephone Number: 717-612-9774
Fax Number:
STATE OF PE?
COUNTY Of t A PAM 10
On the day of 20-6-?-, before me, a Notary
Public, personally appeared CHRIS A. KAUFFMAN, known to me to be the person
whose name is subscribed to the within document and acknowledged that she executed the
foregoing for the purpose therein container
IN WITNESS WHEREOF, I have
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
SUZANNE M. DEOERER, Notary Public
Camp Hill Borg, Cumberland County
My Commission Expires Aug. 20, 2009
vo
KEVIN L. KAUFFMAN
v.
CHRISTINE A. KAUFFMAN
PLAINTIFF,
IN THE COURT OF COMMON PLEAS
Cuffi rkll COUNTY, PENNSYLVANIA
} CIVIL DIVISION
}
NO. 2006 - 027/6 Givl1 le??`
DEFENDANT )
ACKNOWLEDGEMENT
A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
. I agree that the marriage of the Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the Complaint. All information
contained within the attached documentation is true and correct to the best of my knowledge,
information, and belief
It is my desire to file with the lxe'e?41i County Court of Common
Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely
by the terms and conditions as set forth within said Marital Property Settlement Agreement
documentation.
IN WITNESS WHEREOF I set my hand and seal this day of
320644
SIGNATURE
NAME: KEVIN L. KAUFFMAN
On this day of _ , 20& before me, a Notary Public, the
undersigned officer, personally appe d KEVIN L. KAUFFMAN, known to me to be the person
whose name is subscribed to the written instrument, and acknowledged that he executed the
same for the purposes therein contained.
IN WITNESS WHEREOF I hereunto set my
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL Public
SUZANNE M. DEDERER, Nots
Camp Hill Boro, Cumberland County
My Commissi?^? on Expires Aug. 20, 2009
?? ° girt
KEVIN L. KAUFFMAN IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
C+?M6cr?A?J COUNTY, PENNSYLVANIA
V. ) CIVIL DIVISION
CHRISTINE A. KAUFFMAN ) NO. 2- 00 6 - 029 ??n G iqs I /erm
DEFENDANT )
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly Transmit the Record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: irretrievable breakdown under Section N 3301 (e) or ? 3301 (d)
of the Divorce Code. (Check applicable section.)
Date and manner of service of the Complaint: on or about (GIVE DATE):
via (check one) ? Personal Service or ? Certified Mail.
(Complete either paragraph (a) or (b).)
(a) Date of execution of the Afdavit of Consent/Consent Waiver required by Section 3301
(c) of the Divorce Code: by Plaintiff ( ---)by Defendant( (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the
Divorce Code:
(2) Date of service of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce
Code:
4. Related claims pending: None.
I ? Z"-) , 2-? . Z ? - - - ?
Plain off
Address: 706 LOUISA LANE
MECHANICSBURG, PA 17050
Phone: (717) 805-2487
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.
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Office of the Prothonotary
Cumberland County
Curtis R. Long
Prothonotary
Mr. Kevin L. Kauffman
706 Louisa Lane
Mechanicsburg, PA 17050
April 25, 2007
To: Kevin L. Kauffinan;
Your divorce papers were sent up to the Judge for his approval and he sent it
back not signed with the following note:
This is incorrect. There are several mistakes in it.
Please review your paperwork and correct the mistakes.
Sincerely,
CURTIS R. LONG
Prothonotary
Q `PIESr''F
Cumberland County
One Courthouse Square CJIO / co , ?,.?:.?
Carlisle, PA 17013 pTNiY wn?n.
02 1A $ 00.;
0004631 598 APR 25
MAILED FROM ZIP CODE 1
Mr. Kevin L. Kauffman
706 Louisa Lane
Mechanic;
rORWARD TIME
V7 NEE 1 IEXIM RTNOTO SEND4j r1
MAUrFMAN O XMvIN L
2223 BRIGADE Ro
ENOL.A PA 47025-1471
RETURN TO SENDER
+• •swV.•+r....ww ...«..:?.lI?IIIIIIIiliill 11 ! Ill fi7 ii fi! 4441#it
=_ 4 1 j/1 i ] j 11 I I) l 1 # #I fl IJ iiiiI 13i#!ii # 1
Kevin L. Kauffman
PLAINTIFF IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL DIVISION
Christine A. Kauffman
DEFENDANT NO 06-2916 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)
(Strike out inapplicable section).
2. Date and manner of service of the complaint: 5-23-2006, Personal Service
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 4-t,0&? ; by defendant 4-19-2007
(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 plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: _4-1-r9-2007
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 4-1--90n7
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AtteFmey to Plaintiff /
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KEVIN L. KAUFFMAN
v.
CHRISTINE A. KAUFFMAN
PLAINTIFF,
DEFENDANT )
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 06-2916 CIVIL TERM
AFFIDAVIT OF CONSENT
I . A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:)
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and 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 REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
I . I consent to the entry of a final decree of Divorce without notice.
2. 1 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unworn falsification to authorities.
Date: 2A jUNE M9-'---- `
Plaintiff
rya
tr.? . N
L N J
c;?
KEVIN L. KAUFFMAN IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
CUMBERLAND COUNTY, PENNSYLVANIA
V. ) CIVIL DIVISION
)
NO. 06-2916 CIVIL TERM
CHRISTINE A. KAUFFMAN )
DEFENDANT )
AFFIDAVIT OF CONSENT
I A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
22 MAY 2006 (date:).
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and 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 REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
Defendant
ppy
Cal
Kevin L. Kauffman
PLAINTIFF IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL DIVISION
Christine A. Kauffman
DEFENDANT NO 06-2916 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)
8801(d)(1) of the 94yeFee Gew-e.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: 5-23- 2()()6, Personal Service
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 2 I JUNE 2007 • by defendant 20 JUNE 2007
(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:
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 plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 4-1-9-2007
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: A-10 ,nn-7
McFmey-!@ Plaintiff / PelemdaAt
t'a
d
C-"S "a
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
KEVIN L. KAUFFMAN iI
PLAINTIFF
VERSUS
CHRISTINE A. KAUFFMAN
DEFENDANT
No. 2006-02916 Civil Term
DECREE IN
DIVORCE
AND NOW, S? Z z --A , Lao? IT IS ORDERED AND
DECREED THAT KEVIN L A TFFMAN , PLAINTIFF,
CHRISTINE A. KAUFFMAN
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
,DEFENDANT,
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;
/VO Al tr
BY THE CDURT:
ATT f : J.
PROTHONOTARY
?K
??- Le
?Q. te-,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION — LAW
Kevin L.Kauffman
Plaintiff
: FILE NO, 2006-02916
June 22 20 07
VS. IN DIVORCE
Christine A. Kauffman
Defendant
NOTICE TO RESUME PRIOR SURNAME
›.c:
Notice is hereby given that the Plaintiff/Defendant in the above matter, havin
been granted a Final Decree in Divorce on the June 22 day of 2007
hereby elects to resume the prior surname of Christine A. Russell
and gives this written notice pursuant to the provisions of 54 P. . 704.
DATE:
Signature of name being resume
COMMONWEALTH OF PENNSYLVANIA .
: SS.
COUNTY OF CUMBERLAND
On the d) -L4-11 day of ,L(,_14r , 20 1.3 , before me, a
Notary Public, personally appeared the above affiant known to me to be the person whose name
is subscribed to the within document and acknowledged that he/she executed the foregoing for the
purpose therein contained.
In Witness Whereof, I have hereunto set my hand and official seal.
OP
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
LINDA SAWYER, Notary Public
Camp Hill Boro, Cumberland County
My Commission Expires April 8, 2017
CD