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Home My WebLink About06-5430 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILYDMSION Lynn A. K. Sullivan Plaintiff No. () (, ~ !:J-q 30 ~ T.t.-- v. Kevin P. Sullivan, Defendant Divorce NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against 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, property or other rights important to you, including the right to demand marriage counseling. When the ground for divorce is indignities of irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary for Cumberland County: Court of Common Please, Cumberland County 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSELING FEES OR EXPENSES BEFORE THE FINAL DECREE OF DNORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service Carlisle: (717) 249-3166 . IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA FAMILYDMSION Lynn A. K. Sullivan Plaintiff No. O~.543D ~ T~ v. Kevin P. Sullivan, Defendant Divorce COMPLAINT UNDER SECTION 330 1 (C) OF THE DIVORCE CODE 1. Plaintiff is Lynn A. K. Sullivan who resides at 324 N. College Street, Apt. A, Carlisle, Cumberland County, Pennsylvania. She has resided at this address at least since August 2006. 2. Defendant is Kevin P. Sullivan who resides at 321 W. Penn Street, 2nd Floor, Carlisle, Cumberland County, Pennsylvania He has resided at this address at least since August 2006. 3. Defendant has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on December 29, 2003 at the Pacific Beach Hotel, Honolulu, Hawaii, County of Honolulu. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Servicemember's Civil Relief Act of 2003 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant will also file such an affidavit. r WHEREFORE, ifhoth parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301 (c) of the Divorce Code. Date: Cf - /5 - O'=' ~. ~lf.' 'ted amtlff (Se -Represen ) r ;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lynn A. K. Sullivan Plaintiff No. O&,. 59 JIJ ~ 1Lv- v. Kevin P. Sullivan, Defendant Divorce Verification I verify that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PaC.8. Section 4094 relating to unsworn falsification to authorities. Date: 9-/s-~ ~~'.' aintiff r f ~ ,~ , ~ "- ~ ~ - ,,') -.c LI-, ~ ~ f9 Q !"'.'..) (~-:C"'" c ::;:J '1,(3) r'. ! (,;-: c' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lynn A. K. Sullivan Plaintiff No. O&'- 5'130 ~ -r~ v. Kevin P. Sullivan, Defendant Divorce AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me, the undersigned, a Notary Public in and for said County and State, Lynn A. K. Sullivan, for the Plaintiff and duly authorized to execute this affidavit, and states that the Affiant knows of her own knowledge that the Defendant, Kevin P. Sullivan, herein is not in the military service as defined in the Servicemember's Civil Relief Act of 2003 and its Amendments thereto, for the following reasons: Kevin P. Sullivan served in the United States Army beginning in May 2002 and received an honorable medical discharge in October 2005. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against surety guarantor, endorser, or other personal liable, primarily or secondarily, for a party in military service. ~~ aintiff IN WI1NESS THEREOF, I have hereunto set my hand and seal. Date~-\ '<; ~ Notarial Seal Wemy WhisUer. Notary Public Carlisle Bore. Cumber1ancl County My Commission Expires Mar. 24, 2007 ember, Pennsy'vani<, !"5~oelatlon (!)f NQIIrl81 r', --1 c t ,'- ,. 'A T;;~ o l., - ':;'-/3 D \....t.A.A-{ ~- - COUNSELING NOTICE UNDER Pa.R.C.P Rule 1920.45(a)*(I) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 330 I (a)(6) Indignities Section 3301(c) Irretrievable Breakdown Mutual Consent Section 3301(d) Irretrievable Breakdown Two- Year Separation where the court determines that there is not a reasonable prospect of reconciliation A list of qualified professionals is available for inspection in the Prothonotary Office of the Cumberland County Court. Court of Common Pleas, Cumberland County I Courthouse Square Carlisle, Pennsylvania 17013 I- t: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce AFFIDAVIT OF SERVICE Lynn A. K. Sullivan, after being duly cautioned and sworn, deposed and says that in regard to the above-captioned case, I served Kevin P. Sullivan with a true and correct copy of the Complaint for Divorce on the date of September 15,2006 in the manner of Personal Service. This document was hand delivered by Christiane Swartz whose age is 32 and address is 158 Lincoln Street, Carlisle, Pennsylvania 17013. ~ ~ .,-." . ~ aintiff SWORN and SUB~~RIBED to B~me!hiS ~- dayof ~Jtr , 2006. ~~~ Notary Public '" U\f 0., .:\..-t\f\'J~"; 1\ ') ~ ~"-~~, ,I., II ~u. . J ~{ :. ) U\\~ of (1~~Il\h~ ') COMMONWEALTH OF PENNSYLVANIA NoIaJIaI Seal Eric A. HesS. NoI8rY POOIlC South MiddI8\OO Twp., ~ CountY My C/:ll'Mli8SiOI' ExpIreS July 20.2010 Member, Penn8ylvanla As8oclatlon of Notaries (") ~ u,~c' 1-r1 r i '~/: ~:: ""t--.o-. ._,__, ~~::.? \. 52:: "--1" ~4 -< ~ c:;;::) 0"' (/) r'1 -0 N N -0 :J' N .' <.J1 \JJ ~ ~." rOr: -om :(:19 00 3-r, -'- "n C) -(1 '7' , 5rn -::.t ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce ACCEPTANCE OF SERVICE I, Kevin P. Sullivan, hereby state that I have accepted service of a true correct copy of the Complaint for Divorce in the above captioned matter on September 15, 2006 by Personal Service. This document was hand-delivered by: C~~"$I ,4"0( S W D,I-Z. whose age is ~ and address is: It~ L,-"'c.~/t1 SI- C atl' ,..-S 1<(. , fJA } 70(3 ILk- Defendant (") c: s: -00:1 mp, Z:I1 -f" L... (fJ..- -<~: r:; (:~. "'- -p.,. '~~~, C Z _-l .-<: r--.l c:,:) <== <:7' (/) f'Tl -0 N N ~ ~,:n nr- m ~9 9~~ :::t:-n ()~. '7" o ?E -< -0 ::K I)? U1 \.0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above captioned matter, [select one by marking ''x''] l 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 name of Lynn Ayako Kim Arashiro , and gives this written notice avowing her intention pursuant to the provisions of the Act of December 16, 1982, P.L. 1309, 54 Pa.C.S.A. Sec. 704. Date: q - 22.-Ob ~-.<. 'ffi;::..J.,~t:l?~ Ay 0 Kim Sullivan TO BE KNOWN AS: ~ ".....)L..",e...:.- J:.J. ako . Arashiro COMMON WEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) On the;<> .;>....( day of ~r.~, .I, _ , 2006, before me, the Prothonotary or the notary public, personally appe the above affiant known to me to be the person whose name is subscribed to the written 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. PR01liO:Oo.r:i~o~ JARl/SlE CUMBERLAND MY PU8UC ro MY COMMISSION EXP'RE~~ ~ti ~ -:-J d: r....'.----.' ';,' . .. \ ~\ \;,"'~ 'Ii , "".' ,^',;' -.) '{; 'j ~ {', (j~ ,t' "', 4" . \.,..,..._.....~...r ......,........-.... '," g s: -on; flIrt '-7 ..,. k-, -~" 7.:::--:ro. "'!)jC,' l;2C: -;;;, g;~') :Z ~ ~ c:::> <T" .(/) Cd ~ -0 :J' ~ ~::o r: :gt? o.~o ,~-r\ _-'- -r, 9t~.~ <?:. o .~ r& - .. C> N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILYDMSION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed and served on September 15., 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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. 4. 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. Date: OZ-05' -07 ~.~ SWORN and SUBSCRIBED to Before me this S day of F &13 P...u lit 1.1I ., 2007. ( COMMONWEALTH OF PENNSYLVANIA Notarial Seal Viola Roelke, Notary Public Ml Holly Springs Boro, Cumbertand County My Commission Expires Nov. 21, 2007 Member. Pennsylvania Association Of Notaries Il~~~ Notary Public f""'=' c;:? ::3 -n ~ 1 ,-0 -0 ~ ~ ~'"1'1 rl'lF -om :SJY ,-..),0 ~:;~5 ~~ Zen 9\ J..:-'" ~ ~ - c..:> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed and served on September 15,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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. 4. 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. Date: 2 - 6 -07 ,'; . ~ ~ ~ - Defendant SWORN and SUBSCRIBED to Before me this t/ day of F~l<u/9 ry ,2007. ~ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Viola Roelke, Notary Public Mt Holly Springs Bora. Cumberland County My Commission Expires Nov. 21. 2007 Member, Pennsylvania Association Of Notaries --'-,--""-":~""'-~: ~T..~1''';;';;''.: --~ ,.'.. ", l":~-.~"~~~~i,p-].:-",,~~....~~- ":_ "Il. ~,~ o f; <." ""t.le:-~ CIJc1 . ,,,...""~ .~i ._j>-~- ..? ," ~'~ -"C Z =< ~ <;::;;:> c:=; -..I --. f'T1 C'J J m o 11 :t!. .." mp:; -om ,119 ~;~ ~~ ;,:,:;C) :::.5 rr, -.,....i: ;c.~ ~ -0 ~ "-) ~ IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 1 3301(C) AND 13301(>>) TO THE PROTIlONOTARY: 1. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fee or expenses if I don 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 statement are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 19 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: '2 ' J. 0 7 i:-~ Dlfen t '"'''''~_:'''-''''''' , ~ ""f"l ~ , U) i' " ~ N .. ~ :?--n r\1r=:: -a,.t!4 -n........ :;?\~). ~~\f~\ ~~:::~, "'^"" ~ - c.-o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DMSION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant Divorce WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 1 3301(C) AND 13301(>>) TO THE PROTHONOTARY: 1. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fee or expenses if I don 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 statement are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 19 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 2 -9 - 0, ~tiff ~<3u~~ r-:> c;:::r ~ ..." r""'\ Q:J , "'" ~ '~f9 ~~l~: -0 ::.c iG .. 9~, @" ..J.r ~ w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILYDMSION Lynn A. K. Sullivan, Plaintiff No. 06 - 5430 Civil Term v. Kevin P. Sullivan, Defendant 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 Section 3301(c) of the Divoree Code. 2. Date and manner of service of complaint: September 15,2006 by penonal service. Affidavit of Aeceptanee of Serviee was filed on September 22, 2006. 3. (a) Date of execution of the affidavit of consent required by ~ 3301 (c) of the Divorce Code by Plaintiff: February 5, 2007. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code by Defendant: February 6, 2007. 4. Related claims pending: None. 5. (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: February 9, 2007. Date Defendant's Waiver of Notice was filed with the Prothonotary: February 9, 2007. I verify that the statements made in this statement are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 P A C.S. ~ 4904, relating to unsworn falsification to authorities. pfL~ Date: 2.. - cr -07 ~ <:? ~ -n rn CP , "" -0 -r;~ -""" r::? ~ -4 :t:-n f'I"\e -o~ ~~\ ~} -~~~ -:-4, -r'......... ~ - - .... ?~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~' ~ '" ~ '+' ~ '+' '+' .. '+' .. .. .. '+' .. '+' '+' '" '" .. .. .. .. .. .. .. ~ .. ~ .. .. .. '+' '+' ~ '+' '+' '" '" '" '+' '" :-!- IN THE COURT OF COMMON P EAS OFCUMBERLANDCOUNTY STATE OF PENNA. Lynn A. K. Sullivan, 06 - 5430 ivil Term Plaintiff No. VERSUS Kevin P. Sullivan, Defendant DECREE IN I DIVORCE .. uo1 , IT IS OR ERED AN D AND NOW, /~"""l /'1' Lynn A. K. Sullivan , PLAI TI FF, DECREED THAT AND Kevin P. Sullivan , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS HICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORD R HAS NOT YET BEEN ENTERED; NONE By THE COU:1 i ~, ~ ~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~+++~~~~~~~~~~ J. i/~t ~ ~ LOY"e /7r t:t ~ htr"/'17 U;>"5f"r> . '; '. !-; - - -----