HomeMy WebLinkAbout06-5015
,
,
Donald T. Kissinger, Esquire
HOWETT. KISSINGER, CONLEY & HOLST, P.C.
130 Walnut Street, P.O. Box 810
Harrisburg, P A 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Donald L. Knepp
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DONALD L. KNEPP,
Plaintiff
)
)
)
)
)
)
)
NO. 2006- ~IVS CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
v.
LORI A. KNEPP,
Defendant
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 rnarriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'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 County Bar Association
32 South Bedford Street, Carlisle, PA 17013
Telephone: (717) 249-3166
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.
,
...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DONALD L. KNEPP,
Plaintiff
)
)
)
)
)
)
)
CIVIL ACTION - LAW
IN DIVORCE
v.
NO. 2006- S't')I.S' CIVIL TERM
LORI A. KNEPP,
Defendant
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Donald L. Knepp, by and through his counsel, Howett,
Kissinger, Conley & Holst, P.C., who states the following in support of the within Complaint:
I. Plaintiff is Donald L. Knepp, an adult individual who currently resides at
2726 Ritner Highway, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Lori A. Knepp, an adult individual who currently resides at
113 Front Street, Second Floor, P.O. Box 132, Boiling Springs, Cumberland County,
Pennsylvania, 17007.
3. Both the Plaintiff and the Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for a period of at least six months immediately preceding the
filing of this Complaint.
4. Plaintiff and Defendant were married on November 16, 1985 in
Lewistown, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the rnilitary or naval service of the
United States or its allies within the provisions of the Servicemembers Civil Relief Act.
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6. There have been no prior actions for divorce or annulment of the marriage
instituted by either of the parties in this or any other jurisdiction.
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.
Date:
8. The marriage of the parties is irretrievably broken.
9. The parties have lived separate and apart since on or about July 14,2005.
10. Plaintiff requests the court to enter a decree of divorce.
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Respectfully submitted,
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Donald T. Kissinger, Esquire
HOWETT, KISSINGER, CONLEY & HOLST, P.c.
130 Walnut Street, P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Donald 1. Knepp
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.
VERIFICATION
I, Donald L. Knepp, hereby swear and affirm that the facts contained in the foregoing
COMPLAINT IN DIVORCE are true and
correct to the best of my knowledge, information and belief and are made subject to the penalties
of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities.
Date:
8/28/06
DONALD .
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant
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NO. 2006-5015 CIVIL TERM
DONALD L. KNEPP,
Plaintiff
v.
LORIA. KNEPP,
CIVIL ACTION - LA W
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Carol J. Lindsay, Esquire, accept service of the Complaint in Divorce on behalf of
Lori A. Knepp, Defendant in the above-captioned action, and certify that I am authorized to do
so.
Date: q
. d y, Esquire "-
SAIDIS, UFF, FLOWER & LINDSAY
26 West High Street
Carlisle, PA 17013
Telephone: (717) 243-6222
Counsel for Plaintiff Donald L. Knepp
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant
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NO. 2006-5015 CIVIL TERM
DONALD L. KNEPP,
Plaintiff
v.
LORI A. KNEPP,
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~3301(c) of the Divorce Code was filed on
August 29,2006.
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 in 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
~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 above 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.
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Donald L. trlepp, lai t ff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PEI'.'NSYL VANIA
DONALD L. KNEPP,
Plaintiff
Defendant
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NO. 2006-5015 CIVIL TERM
v.
LORI A. KNEPP.
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under S3301(c) of the Divorce Code was filed on
August 29,2006.
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 in 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
~3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce \vithout 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 above are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn
falsification to authorities.
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Date: .z.c c.. Ie, .J oCsv
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Lori A. Knepp, Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Defendant
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NO. 2006-5015 CIVIL TERM
DONALD L. KNEPP,
Plaintiff
v.
LORI A. KNEPP,
CIVIL ACTION - LAW
IN DIVORCE
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 S3301(c) ofthe Divorce Code.
2. Date and manner of service of the complaint: Service accepted by Carol J. Lindsay,
Esquire on September 1, 2006; Acceptance of Service filed on September 21, 2006.
3. Date of execution of the affidavit of consent required by S3301(c) of the Divorce
Code: by plaintiff, December 4,2006; by defendant, December 10,2006.
4. Related claims pending: No related claims pending.
5. Date plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the prothonotary:
contemporaneously herewith; date defendant's Waiver of Notice in S3301(c) Divorce
was filed with the prothonotary: contemporaneously herewith.
Date: /~ /}- -{)fr,
Donald T. Kissinger, Esquir
HOWETT, KISSINGER, CONLEY & HOLST, P.c.
130 Walnut Street, P. O. Box 810
Harrisburg, PAl 71 08
Telephone: (717) 234-2616
Counsel for Plaintiff Donald L. Knepp
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
DONALD L. KNEPP,
PENNA.
STATE OF
Plaintiff
No.
2006-5015 CIVIL TERM
VERSUS
LORI A. KNEPP,
Defendant
DECREE IN
DIVORCE
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2006 , IT IS ORDERED AND
AND NOW,
DONALD L. KNEPP
, PLAINTIFF,
DECREED THAT
LORI A. KNEPP
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.
PROTHONOTARY
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