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Home My WebLink About06-3090KIMBERLY M. CALAMAN, Plaintiff vs. DAVID L. CALAMAN, Defendant : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PEN NO.2006- ?DQU t??,tyi : CIVIL ACTION -LAW : IN DIVORCE NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims set following pages, you must take action within (20) days after this Complaint an served by entering a written appearance personally or by attorney and filing in the Court your defenses or objections to the claims set forth against you. You are if you fail to do so, the case may proceed without you and a judgment may be enl you by the Court without further notice for any money claimed in the Complah other claim or relief requested by the Plaintiff. You may lose money or prop( rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 717-249-3166 OF ANIA urth in the Notice are vriting with varned that red against or for any iv or other KIMBERLY M. CALAMAN, : IN THE COURT OF COMMON PEAS OF Plaintiff : CUMBERLAND COUNTY, PENN YLVANIA VS. DAVID L. CALAMAN, Defendant NO. 2006- 3o 9d Cau?l emu_ CIVIL ACTION -LAW IN DIVORCE COMPLAINT Plaintiff, Kimberly M. Calaman, by her attorneys, Broujos & Gilroy, P.C., following: 1 Plaintiff is Kimberly M. Calaman, an adult individual residing at 1231 Carlisle, Cumberland County, Pennsylvania. 2 Defendant is David L. Calaman, an adult individual residing at 1231 Carlisle, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married on November 23, 1996 in Cumberland Commonwealth of Pennsylvania. 4 Both Plaintiff and Defendant have resided continuously in the Pennsylvania and in Cumberland County for at least 6 months prier to the this action. forth the Road, Road, the of of There have been no prior actions of divorce or for annulment between the The marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree djvorcing her from the Defendant. BROUJOS & GILROY, P.C. x Attorney for laintiff Broujos ilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717-2434574 VERIFICATION I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCSI4904 relating t# unworn falsification to authorities. Y ?V 1. c.aQ "?.. "'F? ? C .? G? t.. o- .-R. _? ?? p I jtY `? _q ?? ( i >m t r"_ 4.J ? .? KIMBERLY M. CALAMAN, Plaintiff VS. DAVID L. CALAMAN, Defendant WAIVER OF NO' ENTRY OF 1. 2. 3. 4. 5. A Complaint in divorce 30, 2006. Defendant acknowledges June 2, 2006. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- : CIVIL ACTION -LAW : IN DIVORCE VIT OF CONSENT AND CE OF INTENTION TO REQUEST DIVORCE DECREE UNDER 1(c) OF THE DIVORCE CODE Section 3301(C) of the Divorce Code was filed on May and accepts service of the Complaint on or about The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date oft the filing of the Complaint. I consent to the entry of a fmalldecree of divorce without notice. I understand that I may lose rhts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be and that a copy of the Decree Prothonotary. 7. I have been advised of the may request that the Court counseling. I verify that the statements made in statements herein are made subject falsification to authorities. Date: 11 mD rced until a Divorce Decree is entered by the Court be sent to me immediately after it is filed with the .lity of marriage counseling and understand that I counseling. I do not request that the Court require s affidavit are true and correct. I understand that false the penalties of 18 Pa.C.S. §4904 relating to unsworn Kimberly M. C man, Plaintiff C7 ?? ?" cs N .o :?. co KIMBERLY M. CALAMAN, Plaintiff VS. DAVID L. CALAMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 1 ()q 0 : CIVIL ACTION -LAW : IN DIVORCE AFFID T OF CONSENT AND WAIVER OF NOT CE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER 1. 2. 3. 4. 5. A Complaint in Divorce 30, 2006. Section 3301(C) of the Divorce Code was filed on May Defendant acknowledges June 2, 2006. The marriage of the Plaintiff have elapsed from the date of I consent to the entry of a and accepts service of the Complaint on or about I Defendant is irretrievably broken and ninety days filing of the Complaint. decree of divorce without notice. I understand that I may lose rhts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not and that a copy of the Deci Prothonotary. 7. I have been advised of the may request that the Court counseling. I verify that the statements made in t statements herein are made subject falsification to authorities. Date: ?? divorced until a Divorce Decree is entered by the Court will be sent to me immediately after it is filed with the lity of marriage counseling and understand that I counseling. I do not request that the Court require affidavit are true and correct. I understand that false the penalties of 18 Pa.C.S. §4904 relating to unsworn David L. Calaman, Defendant r-J T C C CD -r? KIMBERLY M. CALAMAN, Plaintiff VS. DAVID L. CALAMAN, Defendant I, Hubert X. Gilroy, being duly IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-3090- CIVIL TERM : IN DIVORCE VIT OF according to law do depose and state that a copy of the Divorce Complaint, along with the Notice to Plead, in the above referenced matter was served on Defendant David L. Calaman 2697, Return Receipt Requested, being Defendant's household. Copies of evidencing service are attached hereto November -) b , 2006 Sworn to and subscribed before me this day of November, 2006. June 2, 2006 by Certified Mail #7099 3400 0018 5046 by Veston V. Calaman, an adult member of the Certified Mail form and the Return Receipt form marked as Exhibit A. Hubert X. Gilroy, Esquire Attorney for Plaintiff Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 VAN A- '0ww S" qw iiv W.sry Pubifo Cols* jra. ?'tGSiflk? i $r d trournY t+m k?t? ' , 512W9 Mamb®r, Pera?By?? A Asso?imtlon of Notmes IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KIMBERLY M. CALAMAN ii Plaintiff VERSUS DAVID L. CALAMAN Defendant No. 2006 ._.. -3090 DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT KIMBERLY M. CALAMAN PLAINTIFF, DAVID L. CALAMAN AND 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 of record. THE C ATT V)ST: +1?w a• J. PROTH0NUOTARY .z ?_r. i.., !` ? / l?? ?? r r- ? Er 7 7 ti „-p Postage O Certified Fee U1 Return Receipt Fee cG (Endorsement Required) a C3 Restricted Delivery Fee C3 (Endorsement Required) 0 Total Postage & Fees C3 M r"I Recipi_I Namg (Plga: _ r Q" - ---------------------------- Street, Ap yp PC U C] City, State, 4 I ¦ Complete items 1, 2, and 3. Also corn item 4 if Restricted Delivery is desirec ¦ Print your name and address on the r so that we can return the card to you ¦ Attach this card to the back of the rni or on the front If space permits. 1. Article Addressed to: w,? .yam&e)a rnaf rA IWt Postmark -P? Here O (tqb? plleteedd by mailer) ----------------- V -------------------------------------------------- I7013 A. Signature X y ? Agent Addressee B. Received by (FWnW Name) C. fat 0*1ivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No .?W 3. Serv Type fled Mail ? Mail ? Registered W Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Artlc3e Numberservke label) V t ` -) 601V 3- Q v-01 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ; EXHIBIT EA ra `- Q r^? C T ` 1 ,j U7 •< . _Cj '` C N O . KIMBERLY M. CALAMAN, Plaintiff v DAVID L. CALAMAN, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-3090 CIVIL : CIVIL ACTION -LAW : IN DIVORCE Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. 2. 3. 4. Ground for Divorce: Irretrievable breakdown under Section (x)3301(c) ()3301(d)(1) of the Divorce Code. Date and manner of service of the Complaint: June 2, 2006 by U.S. Postal Service, Certified Mail, Return Receipt. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff. November 8, 2006; by Defendant: November 8, 2006. (b) (1) Date of execution of the Plaintiffs affidavit required by Section 33010 of the Divorce Code: 2) Date of service of the Plaintiffs affidavit upon the Defendant: . Related claims pending: None. 5. Complete either (a) (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 Plaintiff s Waiver of Notice was filed with the Prothonotary: November 29, 2006. (b) Date Defendant's Waiver of Notice was file"th the Prothonotary: November 29, 2006. Hu ' . Gilroy, Esquire orney for Plaintiff Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-2434574 cry 14. r . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY M. CALAMAN, Plaintiff Vs : File No. 2006-3090 DAVID L. CALAMAN, Defendant : IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] X prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of HURLEY, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date:- Alto COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) On the 9?A! day of aAao? -- , 2006, before me, the Prothonotary or the 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 hereunto set my hand and official seal. COMMONWEALTH, OF PENNSYLVANIA Notarial Seal Shelly Brooks, Notary Public Carlisle flora, Cumberland County My Commission Expires Aug. 5, 2009 Member. Pennsylvania Association of Notaries 1? A O ?v\ r-? } ._ . rye ? F.\FILES\DATAF[LE\General\Cuffent\12390lstipulationI\mas Created. 9;^_0/09 0 06PM Revised: 2/7107 2.36PM 1'_390.1 Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. No. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KIMBERLY M. HURLEY (formerly Kimberly M. Calaman), Plaintiff, V. DAVID L. CALAMAN, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-3090 CIVIL ACTION - LAW IN DIVORCE STIPULATION The parties in the above-captioned action hereby stipulate and agree that the attached Court Order may be signed by a Judge of the Court of Common Pleas of Cumberland County and incorporated as a Court Order. Dated: fS, y) o1 Kimberly M. Hurley Witness Dated: David L. Calaman Witness r-, n. i ?'? a C? = -?, ?°z G :? ??, ' l ?? " ? 1 i _. ;'"n __ ?? .: ?-- ? -._.. _. J -f ??. r? ti.,J "'K F:\FILES\DATAFILE\General\Currmt\ 123901order I\Mas Created: 9/20104 0:06PM Revised: 2/107 11:19AM M390.1 KIMBERLY M. HURLEY (formerly Kimberly M. Calaman), Plaintiff, V. DAVID L. CALAMAN, Defendant. AUG 27200791 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-3090 CIVIL ACTION - LAW IN DIVORCE O AND NOW this 2 " day of , 2007, upon consideration of the attached Stipulation signed by the above two parties, it is ORDERED and DIRECTED as follows: 1. The father, David L. Calaman, and the mother, Kimberly M. Hurley, shall enjoy shared legal custody of Kayla Ik Calaman, born August 9, 1994, and Cory L. Calaman, born October 27, 1997. 2. The mother shall enjoy primary physical custody of the minor children. 3. The father shall enjoy liberal periods of temporary physical custody with the minor children as follows: a. On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. b. On alternating or shared holidays pursuant to a schedule as agreed upon by the parties. C. During the summer for a period of vacation pursuant to a schedule as agreed upon by the parties. d. At such other times as agreed upon by the parties. 4. In the event either party desires to modify this Custody Order and the parties are unable to reach an agreement on that modification, either party may case scheduled with a Custody Conciliator for a conference. cc: tVubert X. Gilroy, Esquire, Attorney for Plaintiff 06. David L. Calaman to have the IN D C"i C7 r