HomeMy WebLinkAbout02-4087
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KRISTI L. BRESSLER,
Plaintiff
v.
CIVIL ACTION - LAW
NO.2002- lfoP7 G~l'r~
KENNETH L. BRESSLER,
Defendant
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 the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from the list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you
desire to pursue counseling, you must make your request for counseling within twenty (20) days of
the date on which you receive this notice. Failure to do so will constitute a waiver of your right to
request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE 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 THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KRIST! L. BRESSLER,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2002- 4o~7 (?,~~( <-r~
KENNETH L. BRESSLER,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this 28TH day of August, 2002 comes Plaintiff, Kristi L. Bressler, by and
through her attorneys, Hanft & Knight, P.C., and files the following Complaint in Divorce, and in
support thereof avers as follows:
I. The Plaintiff is Kristi L. Bressler, an adult individual, who currently resides at 1860
Walnut Bottom Road, Newville, Cumberland County, Pennsylvania 17241.
2. The Defendant is Kenneth L. Bressler, an adult individual, whose last known address
was 3512 Grier Point Road, Marysville, Peny County, Pennsylvania 17053.
3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of
the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding
the filing of this Complaint in Divorce.
4. The parties were married on November 4,2000, in Newville, Cumberland County,
Pennsylvania.
5. The marriage is irretrievably broken. The foregoing facts are averred and brought
under Sections 3301(c) or, in the alternative, 3301(d) of the Divorce Code of 1980, as amended.
6. Alternatively, Plaintiff avers that the Defendant has offered such indignities to her,
the injured and innocent spouse, as to render her condition intolerable and her life burdensome, The
foregoing facts are averred and brought under Section 3301(a)(6) of the Divorce Code of 1980, as
amended,
7. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff
may have the right to request that the Court require the Parties to participate in counseling, and
Plaintiff waives same.
8. The date of separation of Plaintiff and Defendant is April I 0, 2002,
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintifffrom the Defendant.
Respectfully submitted,
HANFT & KNIGHT, P.C.
"\
ichael J. H , Es
Attorney LD. No. 57976
Lindsay Gingrich Maclay, Esquire
Attorney LD. No. 87954
19 Brookwood Avenue, Suite 106
Carlisle, Pennsylvania 17013-9142
Attorneys for Plaintiff
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered by
my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint in Divorce and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KRISTI L. BRESSLER,
Plaintiff
CIVIL ACTION - LAW
v.
NO. 2002 - 4087
KENNETH L. BRESSLER,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 3rd day of September, 2002, I, Lindsay Gingrich Maclay, Esquire, hereby
certify that the following person was served with a True and Correct copy of the Complaint in
Divorce filed in the above-referenced matter. The Complaint in Divorce was mailed on August 29,
2002, but actual service took place on August 30, 2002, by Defendant signing for a copy of the
Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt
Requested, Restricted Delivery, Postage Prepaid, addressed as follows:
Mr. Kenneth L. Bressler
3512 Grier Point Road
Marysville, Pennsylvania 17053
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof.
Respectfully submitted,
HANFT & KNIGHT, P.C.
~.~~
i dsay Gi . M~ay, Esquire
Attorney ill No. 87954
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KRISTI L. BRESSLER,
Plaintiff
CIVIL ACTION - LA W
v.
IN DIVORCE
KENNETH L. BRESSLER,
Defendant
No. 2002-4087
PRAECIPE FOR WITHDRA'V AL OF APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the Plaintiff, Kristi L. Bressler, in the above-
captioned matter.
Date: J{bfU4Kj 2."1, '2llll.3
din42~~~~J:;
i Cisay Gin . hfMac y
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, Pennsylvania 17013
(717) 243-6222
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Kristi L. Bressler, in the above-
captioned matter.
Date:
Z[2-'103
HANFT & KNIGHT, P.C.
Jef:E~
Attorney LD. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, Pennsylvania 17013-9142
(717) 249-5373
Attorneys for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KRISTI L. BRESSLER,
Plaintiff
No. 2002-4087
v.
CIVIL ACTION - LA W
KENNETH L. BRESSLER,
Defendant
(In Divorce)
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please transmit the Record, together with the following information, to the Court for entry
of a Decree in Divorce:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) ofthe Divorce Code.
2. Date and manner of service of the Complaint: Defendant was served via Certified Mail,
Return Receipt Requested, Restricted Delivery, by signing the domestic return receipt on
August 30, 2002. A Certificate of Service was filed and docketed at the above-referenced
docket number on September 3, 2002.
3. As required by Section 3301(c) of the Divorce Code, Plaintiff and Defendant executed
their respective Affidavits of Consent on October 18, 2005, which Affidavits are being
filed simultaneously herewith.
4. Related claims pending: None.
5. As required by Section 3301(c) of the Divorce Code, Plaintiff and Defendant executed
their respective Waiver of Notice forms on October 18,2005, which Waivers are being
filed simultaneous herewith.
Date: JO!IQ!D5""
By:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KRISTI L. BRESSLER,
Plaintiff
No. 2002-4087
v.
CIVIL ACTION - LAW
KENNETH L. BRESSLER,
Defendant
(In Divorce)
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
SS.
COUNTY OF CUMBERLAND
)
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
August 28, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and at least 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 in Divorce after service of the Notice of
Intention to Request Entry of a Divorce Decree.
I verify that the statements made in this Affidavit 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., Section 4904 relating to unsworn falsification to
authorities.
Date: / () -/(1- t) S-
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KRISTI L. BRESSLER,
Plaintiff
No. 2002-4087
v.
CIVIL ACTION - LAW
KENNETH L. BRESSLER,
Defendant
(In Divorce)
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 without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! 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 I further understand 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 Waiver 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. S4904, relating to unsworn falsification to authorities.
Date: !t7-I?- tJ _\
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KRISTI L. BRESSLER,
Plaintiff
No. 2002-4087
v.
CIVIL ACTION - LAW
KENNETH L. BRESSLER,
Defendant
(In Divorce)
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
SS.
COUNTY OF CUMBERLAND
)
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
August 28, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and at least 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 in Divorce after service of the Notice of
Intention to Request Entry of a Divorce Decree.
I verify that the statements made in this Affidavit 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., Section 4904 latin unsworn falsification to
authorities.
Date: lv-If} -Dr
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KRISTI L. BRESSLER,
Plaintiff
No. 2002-4087
v.
CIVIL ACTION - LA W
KENNETH L. BRESSLER,
Defendant
(In Divorce)
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 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 I further understand 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 Waiver 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. 94904, relating to unsworn [; . ation to authorities.
fO!tV )o~
I
Date:
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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KRISTI L. BRESSLER,
STATE OF
PENNA.
No.
2002-4087 Civil Term
Plaintiff
VERSUS
KENNETH L. BRESSLER,
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Defendant
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DECREE IN
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DIVORCE
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AND NOW,
CVtW
1.-,.0
, IT IS ORDERED AND
2005
Kristi L. Bressler
DECREED THAT
, PLAINTIFF,
AND
Kpnnprh T.
R("C?~Q.le-r
, 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.
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PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KRISTI L. BRESSLER,
Plaintiff
No. 2002-4087
v.
CIVIL ACTION - LAW
KENNETH L. BRESSLER,
Defendant
(In Divorce)
NOTTCE OF INTENTION TO RESUME PRIOR N c\ME
NOTICE IS HEREBY GIVEN t:ml KRISTi L. BRf'::SSLER, ;h~ Pluintiff in the above-
captioned matter, having been granted a Final Decree in Divorce on October 27, 2005, hereby
intends to resume and hereafter use the previous name of KRISTI L. COOPER, and gives this
written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980,
P.L., 23 P.S. 702, effective July I, 1980.
~.~ fl. l~L--C
KRISTI L. BRE LER, Petitioner
TO BE KNOWN AS: ..I/~ .../. CZInL/f/
~I L. COQMR /
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF DAUPHIN
ON this, the 3,'9. day of \-..\",'{'\,\y,\ , 2005, before me, a Notary Public,
personally appeared KRISTI L. BRESSLER, now to be known as KRIST! L. COOPER, known to
me or satisfactory proven to be the person whose name is subscribed to the within instrument and
acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seaL
\ \'\\, \ 1(\"" \. " ~ \'C\ 'Cj~,.,.
. Notary Public
COMMONWEALTH OF PENNSYL
Notarial Seal
Michelle M. Bross, Nolllry Public
Lower Paxton Twp., Dauphin County
My Commission Expires Sept. 23, 2006
Member, Pennsylvania Associatioo of Notaries
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