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HomeMy WebLinkAbout06-2917 , 0, K. MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW ; NO. (){, - ,Jq '7 : IN DIVORCE CIVIL TERM DANIEL L. MCCLINTOCK, Defendant NOTICE 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. Ajudgment 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, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENTIS 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 32 South Bedford Street Carlisle, P A 17013 Phone: (717) 249-3166 .' K. MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. f!} I.. - .2 q 17 : IN DIVORCE CIVIL TERM DANIEL 1. MCCLINTOCK, Defendant COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE L Plaintiff is K, Michael McClintock, who currently resides at 930 Forest Court, Carlisle, Cumberland County, Pennsylvania 17013, since August 2005. 2. Defendant is DanielL. McClintock, who currently resides at 930 Forest Court, Carlisle, Cumberland County, Pennsylvania 17013, since August 2005. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 3, 2003 at Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. ~ -4 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. ~ 4904, relating to unsworn falsification to authorities. Date: ~t~((;t, ~~~Mt~ K. Michael McClintock, Plaintiff ANDREWS & JOHNSON Ronald E. J Attorneys Plaintiff 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 9~ 'J ..}.) c(\ t' -. ~ ~ t:>..J 'V-> -(:... ~ ~ C> Il:!;: () ~ -ot;; r-fit : -;~.. ~ U) ::( ,. ~\ ~'~~= :-\ -<. ,...., "'" <= "" ::; ~ N N ~ ""'" _'v -~ o -., %::!3 .-:; -Cf. ~ ..)0 ~"; , ':c., 0 '~l: :;~ c,"- .~,"-'"() <~rn q ~ N .' o CP . .. K. MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W DANIEL L. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NnW, this 25th day of May 2006, I, Ronald E. Johnson, Esquire, attorney for K. Michael McClintock, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at his residence at 930 Forest Court, Carlisle, P A 17013, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on May 24,2006, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: NOTARIAL SEAL SHELLY SEXTON, Notary Public Carlisle Boro, Cumberland County My Commission Expires April 26, 2007 "It . 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 mail piece, or on the front if space permits. 1. Article Addressed to: Mr. Dan~el L. McClintock 930 Forest Court Carlisle, PA 17013 2. Article Number (Tnmsfer from service label) PS Form 3811, February 2004 o Agent - 0 Addressee B. S ~e: Delivery D. Is delivery address different from Item 1? 0 Yes If YES. enter delivery address below: . 0 No x 3. Selvlce Type III Certified Mall 0 Express Mail o Registered . Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) )G" Yes 7005 2570 0000 3796 3547 102595-Q2-M-1540 Domestic Return Receipt Exhibit A ('") c r--..::> = = 0"'> <-- c: o " -l :C "Tl nlp. -"("'1 fT'~ :vy ~.~J ~-~: ':. ""1 '- .-:~ (~5 ')11'1 ~ -< -: ~" ....... W N K . MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL 1. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 I ( c) of the Divorce Code was filed on May 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. ~ 4904, relating to unsworn falsification to authorities. Date: f;/ JaIA/J/J{, I . tl~ DanielL. McClintock, Defendant 0 ....., 0 = c = " ?:: "'"' "T}rr: (/) :r! CO r'. Pl nl :JJ -0 r- L, CJ m (/] I ::-) 0 -. CJ1 '~;:;(:' '''-..,. -'r--I-- -0 C) -'n .2~ C ::JI: L:.J' Co:) j; l'5rn C (...) -~l -;;0' J> =2 :D -r -< , I I I i , ! .~ ! 1< . MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL L. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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 herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: i'J 50/~y I I ~~ () c s: -00-:"' a;q:' ~-;; ~.. ~~i~C.: pC z :<! " ,...., "'" g; en ,..., --0 I <.J1 :s ".l... ~ ~-n rnF -orii ::ely ~-:.~ ~i~)~ ~) (0:7) ~7' 1-0 9. S5 .< t!? -' K. MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL 1. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 ( c) of the Divorce Code was filed on May 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. ~ 4904, relating to unsworn falsification to authorities. Date: .;!rJ/;:>~! l~Qrn~ K. Michael McClintock, Plaintiff ~ ~'''' -o{;,~:' mr ~::,-.. ?~f) .~-' :.- r':::: < .>- , 'S-(. 5>C: 2; =< \ 'i , , ......, = = "'" (/) rt1 -0 I (.)1 o -n :II.,., mp -om ,ue;:; ;~~1 o -'~I ?D -< -0 3': t;-;) -.J K . MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL L. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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 herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: J'b(2tJt:J&' I ' ~ Daniel L. McClintock, Defendant (") c ?;': -om, ITlfi' 2"'" /:' 'jJ ~;:_, )>c -~7 :.::jc -< "-' = = "'" en f1"1 -0 I ()1 () -n -l :e-n mF~ -of'i1 :ny :)r). ::C.:fl (;,-;J('') onl --, ?b :< -0 3 ':? -.J K MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL 1. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following infonnation, to the Court for entry of a divorce decree: I, Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Mav 24. 2006 bv restricted. certified mail. return receiot reauested. 3. Date of execution of the affidavit of consent required by Section 330 I (c) of the Divorce Code: by the Plaintiff August 30. 2006; by Defendant August 30. 2006. 4. Related claims pending: None 5. Date Plaintiffs Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: .......l!lfst 39, J(,lg, 5'0/'" " 20IJIt, Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: :\ltetlat J9. :996 ~C'ul. r , -ZOPJ. . ANDREWS & JOHNSON Date: ,hpl!! 3e, 2006 f?Jf. ~ () c ~HfF ~~ ~' 2~ ~--o i " ~f :z: =< 1 \ ...., = = a- en 1""'rj v I U1 C) 'n :I!~ rn...!-J r- -OfT', "79 ~:-:~( () ~~~2;; '-m S 5:i -< ""t) :::1:: '::' co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . STATE OF PENNA. . . K. Michael McClintock No. 06-2917 Plaintiff . VERSUS Daniel L. McClintock Defendant DECREE IN DIVORCE AND NOW, s.. rl~"'1~(r '1 ,.1:.f:.Qk, IT IS ORDERED AND DECREED THAT K. Michael McClintock , PLAINTIFF, AND Daniel L. McClintock , 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 . J, ATT . . _#<J' ~ ~ 1'- L-u ~ r 'I' ~ /.(,;f1J 1'l- /'--b '. '., ..II."~ .. ~~ . .J . ....If...... ,~. "" K MICHAEL MCCLINTOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL L. MCCLINTOCK, Defendant : NO. 06-2917 : IN DIVORCE CIVIL TERM NOTICE OF ELECTION TO RETAKE PREVIOUS NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the ih day of September 2006, hereby elects to retake and hereafter use her previous name of K. Michael Spencer. -(~,~ K. Michael McClintock TO BE KNOWN AS: {~fY\ K. Michael Spencer COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On the J.1.!!2 day of September 2006, before me, a Notary Public, personally appeared K. Michael Spencer, 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 contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL SH~LL Y SEXTON, Notary Public Carlisle Boro, Cumberland C My Com . , ounty mISSIon Expires April 26, 2007 ~ ~~ ~~ d:) ~ -J ~ 0(\ , ~ ~ d -1 7'J ~ ~ r--- ~ r- ( L-\ ~ ? ~ 3 ~ ~ -' -- -~ . L'