Loading...
HomeMy WebLinkAbout02-4492 GORDON W. KAISER, III Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. LINDA M. KAISER, Defendant : CIVIL ACTION - LAW : NO. O:L-l{<{t):J.... Cc.;--z.1 7(~ : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defendant 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 will proceed without and a decree in 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 in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 GORDON W. KAISER, III Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. LINDA M. KAISER, Defendant CIVIL ACTION - LAW : NO. 0'<. 'fY'l;z. ~0-- : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Gordon W. Kaiser, III, an adult individual currently residing at 1262 Boyer Mill Road, Chambersburg, Franklin County, Pennsylvania. Plaintiff has resided at this address for approximately one year. 2. Defendant is Linda M. Kaiser, an adult individual currently residing at 1262 Boyer Mill Road, Chambersburg, Franklin County, Pennsylvania. Defendant has resided at this address for approximately one year. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 27, 2002, in Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, . fie, Esquire ''n JO Plaintiff IE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. 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. 9)1/ DATE: t?;2. /"1 :;j:j? /A/V~p,/~ GORDON W. KAISER, III p ~ '- ...... ~ "" '" w ~ ~ " ~ '" ~ ~ I ~ co s;.' <' ~~''', [D( ~~ th oll, ..... ~ ~ r,,-"; i/) :"'1 (':~J ~ S--; ~^-:I -( "'<" ',.) f,.> n ~; l',; " ~ "J) ! ,) -p ~ Jr ~ '- I "- "" - ",'. Iv <:;. '" Uc _.:i '<:' ~ , f,_ N C> "- ~ t "- ol. "- Si; \9 I verify that the statements made in the foregoing document are true and correct. 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: r )11t?J- /1 ~ /A/V~;;'/~ GORDON W. KAISER, III GORDON W. KAISER, III Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 02-4492 CIVIL TERM : IN DIVORCE LINDA M. KAISER Defendant AFFIDAVIT OF SERVICE AND NOW, this 1< day of September, 2002, comes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, Gordon W. Kaiser III, and states that a true and attested copy ofa Complaint in Divorce was sent to Defendant, Linda M. Kaiser, at 1262 Boyer Mill Road, Chambersburg, P A 17201 by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on September 20, 2002. Sworn and subscribed to before me this day of '~ Notarial Seal . Karisa J, Lehman, Notary pub'~C Carlisle Boro, cEuXmpi~:~I~~~~~~ 2~03 My commissIon . Complete Items 1. 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and addr8sS on the __ that we can retum the card to you. . !tach this card to the back of the mellpieca, or on the front If space permits. '[;{j;iA !(AI~( fZf1Z &7' Mill f?a4 Ctlavw~btrrv Pit () 1'1'lf!1 2, Article N (Trans"', PS Form ~ I ..=I ..=I C IT' ~ IT' ..II ~ postage Certified Fee 1\1 Retum Recelpt Fee (Endomm.nt Required) C C Restricted O.11ve1Y Fee C (Endorsement Required) C ITl LJ"I ..=I C C C ('- ~~ '" /L~ B. Received by ( Printed Name) O. Ie deHvery addnlss diIfenlnl frcm Item 1? If YES, enter delivery address below: LIA.)tJt1 M. t'1}//E}L 3.!:Typ8 Cerlifled Mall 0 Express Mail Reglstllt'lld 0 Return ReceIpt for o Insured Mail 0 C.O.D. 4, R8lIlrIcled Delivery? (Extnt Fee) I 15-02-M-Q835 ( ( "7 ') ) ) () 0 ~ c: N -offi en -f ~S9 rrJ :h:n -0 r- Ze- I'\) "'Plrt'1 C/) ."eo -.J :"i~ r:$~ <::: J ::-..:::"._- " -r' -r :::;:C, :x "'--H 5;;C; ':.2("-) c j"\,;) Om -".. );! ..r:_ :.n ::J (....> ::0 , -< J ./ .. . << , . GORDON W. KAISER, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW LINDA M. KAISER, Defendant : NO. 02-4492 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 divon:;e is granted. 3. I understand that I will not be divorce 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 THE FOREGOING 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 F ALSIFICA nON TO AUTHORITIES. DATE: ~ I~~L ~l /~ - ~ IA/, L?~ GORDON W. KAISER, III, Plaintiff . ... ... () C <'. '"'Om CPg; zc' en ).;" -<2" r:c '<' ~o ---0 )>c ~ o f'J o rrt CJ N 0"\ o -1") t..~ t:; I Q ~~~ oj" -t 55 -< "'TJ ~ (X) , . GORDON W. KAISER, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LINDA M. KAISER, Defendant : NO. 02-4492 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on September 18, 2002, and served on September 20, 2002. 2. The marriage of Plaintiff and Defendant is irrc~trievably 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: I;J..../:M /0 !L- ~w~::r2 GORDON W. KAISER, III, Plaintiff . :. i () C s: ~CC.: r!1 ::X' ZC ~:?". t<C )>0 ~2 ~ o N o rr1 ("") N 0\ ~~ 'Cr ~ f'- -.:...; ,.__.~:t;- -u CSf~ -( ~r.>- ~ _'i" ~ ....J - -" - , ~' GORDON W. KAISER, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LINDA M. KAISER, Defendant : NO. 02-4492 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorc€:: 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 divorce 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 THE FOREGOING 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: / ;/)./-1d/~.:z. . , ~A/c~ LINDA M. KAISER, Defendant ., . .. .. . () c $.' ""00:, rMrr: 2:1:; 2'): CJ') .-,;, -<." ~C Pl) ;So )>c: Z =< a- N o rrJ n N m ~ ,,} j.; '1 if} :~')f0 ~. ._'; ,.J..1 -f ;:;r: ~:;;j(~~; Om :-f ?o -< -0 -:11: - .. (X) .. ~ " . GORDON W. KAISER, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LINDA M. KAISER, Defendant : NO. 02-4492 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on September 18, 2002, and served on September 20, 2002. 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. DATE: /~/./v/&?~ / / ~.#f. r~ LINDA M. KAISER, Defendant >- ~ LUq ~2r; H:" ~T. (~) ;~'.:-,", C.~~;,~ LU- '" c: u.... o <:0 ~ ::::>-- --} ...... ~)Z ':-- ~ ..::J~ ',""'00 .~~Z :r:Z UJW 9.20.. .d: :::J <..> ..~....- ..'.;::.- (I..- \.0 N U W c:::l N C> ~ :. ~ GORDON W. KAISER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW LINDA M. KAISER, Defendant NO. 02-4492 : IN DIVORCE CIVIL TERM 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 ~3301(c) 3301(d)(1) of the Divoree Code, (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Acceptance of Service on September 20, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code: by Plaintiff: December 20, 2002 by Defendant: December 20, 2002 (b) (1) Date of execution of the affidavit required by ~i330 1 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (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 of plaintiffs Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: December 24, 2002 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: December 24, 2002 1 T ") (') C s: rR ~~g Z.:X:.1 zr ~.2;' '-:;0 ~ ZC ~~ ~ o N o .""1 C'") N CT'I () '-0 -n ;;:....; m f"'->; ....t.~. (!~) ~~~~ ;E2 :5! -.~ 3: - .. \.0 '" '" t "'4 '" "''''''' '" "''''''' '" "'''' "''''''''''''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF GORDON w. K~TSF.R, TTT '" Plaintiff VERSUS LINDA M. KAISER, Defendant PENNA. NO. --0.2-4492 Cinn TUIII DECREE IN DIVORCE AND NOW, L:et..c Vt-tkr \ 3 ( DECREED THAT Gorodon W. Kaiser, III AND Linda M. Kaiser ARE DIVORCED FROM THE BONDS OF MATRIMONY. , .7. 60 2., IT IS ORDERED AND , 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; By THE COURT'::? /l / : ~ (JJ~ b-. ATTE U ?7~ PROTHONOTARY ~. '" '" J. ) ,. '\ -h J!- ~~ &0 ~ -P;J: ~ ~- p1j [0>( . . ... ,_ \' 'rill .".- \. ~~ # \.