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Home My WebLink About06-3891LORELEI CARLSON, Plaintiff V. LYNN CARLSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. D G- 3MI CIVIL TERM : CIVIL ACTION - LAW 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 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 COUNTYBAR ASSOCIATION 32 SOUTHBEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 r LORELEI CARLSON, : IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PA V. NO. 04,- 30) CIVIL TERM LYNN CARLSON, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Lorelei Carlson, who currently resides at 113 Sprignoli Lane, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Lynn Carlson, who currently resides at 115 May Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on September 7, 2001 at Enola, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c) and (d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since August 28, 2005 and continue to do so. 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 such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, DATE Q I DJ DL,;, ABOM & KUT uLAKrs, L.L.P. Kara W. Haggerty ' 36 South Hanover S Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 VERIFICATION I, LORELEI CARLSON, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 5 4904 relating to unsworn falsification to authorities. Date 27 D(p? ?a2?%/?-? LORELEI CARLSON r' CERTIFICATE OF SERVICE AND NOW, this k day of 2006, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Answer to Petition for Special Relief, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Grace E. D'Alo MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 Respectfully submitted, ABOM & Ku7vL4xrs, L.L.P. 1'kt0 P4'a"4:6-L- Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant ? ?., ,-? ?= ? ? ?? i -? eC C , T. p' r- 'T; ?.. ? r '1 ?, c .. c (? °4 4?' '.' N ? ?- 6` o Ua r ? LORELEI CARISON, Plaintiff V. LYNN CARLSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 06-3891 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on August 11, 2006, at Carlisle, Pennsylvania, addressed as follows: Lynn Carlson IZ4MayDrive Camp Hill, PA 17011 Retum card acknowledging receipt on August 12, 2006 is attached as Exhibit "A". QQ ABOM )&Sr,?T/Vrmm, LLP Date: ?U 5 ?`?J?W?/ Kara W. Haggerty, Esq ' e 36 South Hanover Stree Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 86914 ¦ CornpdM Om 1. 2. Mid & Also oonpiM hMn 4 N RdWWW DWWNY I* dtrI I ¦ p" yow NMIM Md MIdYMIi "I th0. mw" so d* we cm idw. the and to you ¦ At[ach tltle cod b the back of the mYp w% or on the hot K specs ptxmite. 1. Anbb Ad**WW to: t inn ea.r60-f\--, PR 177DI ?Jprd b dam V adds" dlrrd*Mkm iZ V YA MYES, ~ MMY address below: ONO OOn91ed11M OdprMd O hgMMW O""nftsoskd for MIND!- 0 Innesd MM O C.O.D. 4. FMeMC Rd D~ PD08 FwJ ? Nas 2r1itl°'W"""` 7005 1160 0002 1113 0192 MWMArRCm sw** A ap PS Fom13811, Febmary 2004 owwwo Rstum neoW taxessoa+,aieto EX141BIT A 1 yy ,,; "1 S c ?i? ?. ry< '- fCf???.,_ -. +'C .? O 'CJ b J V? -?__ -Z- Yl i?? ? ??ri --i N 4J MOM & LITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, ) Civil Action - Law Plaintiff, ) VS. ) No. 06-3891 LYNN CARLSON, ) Defendant, ) NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a Counter-Affidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on August 28, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 unworn falsification to authorities. A X Date: LEI CA SON ? P Y a o ? .R + fai .... pr ? ?J r' co i±'-? J t Aom c& ' TLILAKIS Kara W. Haggerty, Esquire Attorney I.D. 4: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, Plaintiff, ) Defendant, ) Civil Action - Law vs. LYNN CARLSON, No. 06-3891 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF YORK ) Lorelei Carlson, being duly sworn according to law, deposes and says that she is the Plaintiff in the above matter; that she personally knows the Defendant, Lynn Carlson, is over the age of 18 years; and that Lynn Carlson currently resides at 115 May Drive, Camp Hill, Pennsylvania. Plaintiff further avers that Defendant is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940 and its amendments. Sworn to and su scribed before me this day of , 2007. Not ublic Lorelei Carlson, Plaintiff COMMONWEALTH OF PENN YI,VANU NOTARIAL SEAL STEPHANIE NEBL, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Jan. 25, 2011 o ' C r? ? ? m : 2 ` J yy rr + ?.e\T 9 V i '1 ????oM & Ku2ULAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, VS. LYNN CARLSON, Plaintiff, Defendant, Civil Action - Law No. 06-3891 In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE To: LYNN CARLSON You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-affidavit to the §3301(d) affidavit. Therefore, on or after January 31, 2008, the other party can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counter-affidavit by the above date, the Court can enter a final decree in divorce. A COUNTER- AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the Court, a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Lawyer Referral Service (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. is S G co 13 LORELEI CARLSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA V. NO. 06-3891 CIVIL TERM LYNN CARLSON, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the Notice of Intention to Request Entry of 3301(d) Divorce Decree, an Affidavit under Section 3301(d) of the Divorce Code, an Affidavit of Non-Military Service and a Counter- Affidavit under Section 3301(d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on January 8, 2008, at Carlisle, Pennsylvania, addressed as follows: Lynn Carlson 119MayDdve Camp Hill, PA 17011 Return card acknowledging receipt on January 14, 2008 is attached as Exhibit "A". Date: 1 I _?O ? U ABOM & KUTULAms, LLP I/ Kara W. Haggerty, Es 36 South Hanover Str Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 86914 Form 3811, February 2004 Domestic Return Receipt to25es024r-1540 A. SOubm O Agent X , O Addressee B. R by ( !Marne) of Delivery ? ty D. Afeli?adftw O Yea if YES, enter de0very address beiow: O No 6 1 170)1. s, 3 SwvIc8 _a ?WMeM o Express Mail E3 Registered O Return Receipt for Mwdrandiae o N O insured ma O C.O.D. 4. RssVicted Delivery? (Extra Feel 6 e 9`'" Number 7005 2570 0000 3804 3361 `" ¦ CompWile hems 1, 2, and 3. Also complete item 4 It Restricted Delivery Is desired. ¦ prin4your name and address on the reverse so t we can retum the card to you. ¦ Attars card to the back of the meilpiece, or d[ 1be front If space permits. 1. Article Addressed to: ? n n Cav 1S rr - Exhib*A m ? CA) Q 5 ; Y ' N C ABOM CSZ' ICuTUrAKis Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, VS. LYNN CARLSON, Plaintiff, ) Defendant, ) Civil Action - Law No. 06-3891 In Divorce a v.m. COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ? (i) The parties to this action have not lived separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims for economic relief. 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. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other parry. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-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: LYNN CARLSON, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. 86 ,?. i 4-1 OM & KTLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, Plaintiff, VS. LYNN CARLSON, Defendant, Civil Action - Law No. 06-3891 ) ) In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Cumberland County Court of Common Pleas for entry of a divorce decree: 1. Ground(s) for Divorce: a. Irretrievable Breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the Divorce Complaint: a. August 6, 2006, by Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit required by §3301(d) of the Divorce Code: a. Signed by Plaintiff December 18, 2007. b. Date of filing and service of the Plaintiff s Affidavit upon the Respondent Filed: January 8, 2008 Served: January 14, 208 4. Related claims pending: a. None. 5. Date and manner of service of the Notice of Intention to File Praecipe a copy of which is attached: a. January 8, 2008, Received January 14, 2008 by Certified Mail. Respectfully submitted, DATE 02 105 1[& Kara W. Haggerty, e Supreme Court ID 14 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff ABOM & KUTULA"S, L.L.P OM AB & o .T LITLILAKIS = C_ _n Kara W. Haggerty, Esquire - 4"- tz7 ?? Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 =- s C N n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV4,1?IA LORELEI CARLSON, Plaintiff, ) Defendant, ) Civil Action - Law vs. LYNN CARLSON, No. 06-3891 In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE To: LYNN CARLSON You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-affidavit to the §3301(d) affidavit. Therefore, on or after January 31, 2008, the other party can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counter-affidavit by the above date, the Court can enter a final decree in divorce. A COUNTER- AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the Court, a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Lawyer Referral Service (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. r ?a ° Q rrl co -r? ?t C-n ''' C ? . _ CrJ L7 LORELEI CARLSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LYNN CARLSON, Defendant NO. 06-3891 CIVIL TERM ORDER OF COURT AND NOW, this 14th day of February, 2008, upon consideration of Plaintiff's praecipe to transmit record, and it appearing that Plaintiff's notice of intent and affidavit under Section 3301(d) of the Divorce Code were served simultaneously, in contravention of the holding in Burdick v. Burdick, 41 Cumberland L.J. 64 (1991) (Bayley, J.), a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiency and file a new praecipe to transmit. BY THE COURT, ? Kara W. Haggerty, Esq. 36 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff :rc 0,0 M-V 1191- {v? at ?"??`'s ???-Q?11? Aom &' LITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, VS. LYNN CARLSON, Plaintiff, ) Defendant, ) Civil Action - Law No. 06-3891 In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE To: LYNN CARLSON You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-affidavit to the §3301(d) affidavit. Therefore, on or after March 25, 2008, the other party can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counter-affidavit by the above date, the Court can enter a final decree in divorce. A COUNTER- AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the Court, a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Lawyer Referral Service (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Aom C& ' iITCILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, Plaintiff, VS. LYNN CARLSON, Defendant, Civil Action - Law No. 06-3891 In Divorce a v.m. COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ? (i) The parties to this action have not lived separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims for economic relief. 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. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other parry. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this Counter-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: LYNN CARLSON, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ( ` G 7r- LORELEI CARLSON, Plaintiff V. LYNN CARLSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 06-3891 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the Notice of Intention to Request Entry of 3301(d) Divorce Decree upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on February 29, 2008, at Carlisle, Pennsylvania, addressed as follows: Lynn Carlson 115 May Drive Camp Hill, PA 17011 Return card acknowledging receipt on March 11, 2008 is attached as Exhibit "A". Awm&KUTULAKis, LLP Date: 03114 V Kara W. Haggerty, E e --_? 36 South Hanover S " Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 86914 [-•y ?. ? ,T.tK ?'.. ' ? ??? r? ;i -- F sY f ? ? ? Cj Q ?. -? cv A. > ¦ Complete items 1, 2, and 3. Also complete A. Item 4 If Plestrlcted 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 mailplece, or on the front if space permits. 1. AMirJw Art'iroccnrl fn• ' L y r) r) C cwISnA,_ CarT H-? 11, P\ ? Agent ? Addressee Ived b Name) C. Date of Delivery r-rl -ll- nlf Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No ( '7()1 I 3. Service Type ed Mail ? EWess Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) b.Yes 2. Article Number 7005 2570 0000 3804 3347 (rransfer from service MO PS Form 3811, February 2004 Domestic Retum Receipt 102595-0&4A-1540 Exhibit A ?? ? Z ? -..?.x M? ? ? G;??7?. 7 ? t-?- : - y ?? ?.? y + _ ' ?....) ? 1 ???+ ?? ? ... ?' U - s OM & LITuLA.KIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORELEI CARLSON, Plaintiff, vs. LYNN CARLSON, Defendant, Civil Action - Law No. 06-3891 ) In Divorce a v.m. To the Prothonotary: Transmit the record, together with the following information, to the Cumberland County Court of Common Pleas for entry of a divorce decree: 1. Ground(s) for Divorce: a. Irretrievable Breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the Divorce Complaint: a. August 6, 2006, by Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit required by 53301(d) of the Divorce Code: a. Signed by Plaintiff December 18, 2007. b. Date of filing and service of the Plaintiff's Affidavit upon the Respondent Filed: January 8, 2008 Served: January 14, 208 4. Related claims pending: a. None. 5. Date and manner of service of the Notice of Intention to File Praecipe a copy of which is attached: a. February 29, 2008 sent Certified Mail, Restricted Delivery b. Received March 11, 2008 DATE 3 3 [ lot) Respectfully submitted, Awm&KUMAKIS; L.L.P 1 Kara W. Haggerty uire Supreme Court I 6914 A 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff r. Alom dZ' ILILILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSIfVATIIA o LORELEI CARLSON, ) Civil Action - Law :'T I ?- rt Plaintiff, ) A' `; t7 . _ y ?J Y vs. ) No. 06-3891 - . a C o rn LYNN CARLSON, ) Defendant, ) In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(4) DIVORCE DECREE To: LYNN CARLSON You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-affidavit to the §3301(d) affidavit. Therefore, on or after March 25, 2008, the other party can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counter-affidavit by the above date, the Court can enter a final decree in divorce. A COUNTER- AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the Court, a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Lawyer Referral Service (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ``-n C1 r"??? :??4..." ? i 1 ?, .?, . ../ . ? ' . ? £ fr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY tr4h STATE OF PENNA. LORELEI CARLSON, y Plaintiff VERSUS LYNN CARLSON, No. 06-3891 CIVIL DECREE IN DIVORCE AND NOW, 4'.-1 ? , Za00, IT IS ORDERED AND DECREED THAT AND LORELEI CARLSON LYNN CARLSON ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , 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; None. BY THE COURT: PROTHONOTARY .?z?? ??? ?o. ? ?? w? r