Affidavit and Counter Affidavit
COURT OF COMMON PLEAS OF PIKE COUNTY
COMMONWEALTH OF PENNSYLVANIA
KRISTEN K. JENKINS, :
Plaintiff, :
v. : NO: 949-24 CV
MICHAEL JENKINS, : IN DIVORCE
Defendant. :
NOTICE
If you wish to deny any of the statements made in this affidavit, you must file a counter-affidavit within twenty (20) days after service of this affidavit has been served on you or the statements will be admitted.
PLAINTIFF, KRISTEN K. JENKINS, AFFIDAVIT UNDER
23 Pa. C.S.A. § 3301(d) OF THE DIVORCE CODE
The parties to this action separated since July 31, 2023.
2. Check (a) or (b):
(a) the date of separation was prior to December 5, 2016, and the parties have continued to live separate and apart for a period of at least two (2) years.
X (b) the date of separation was on or after December 5, 2016, and the parties have continued to live separate and apart for a period of at least one (1) year.
3. The marriage is irretrievably broken.
4. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees and 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 made herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities.
DATE: May 28, 2025 /s/Kristen K. Jenkins
COURT OF COMMON PLEAS OF PIKE COUNTY
COMMONWEALTH OF PENNSYLVANIA
KRISTEN K. JENKINS, :
Plaintiff, :
v. : NO: 949-24 CV
MICHAEL JENKINS, : IN DIVORCE
Defendant. :
COUNTER-AFFIDAVIT UNDER 23 Pa.C.S.A. § 3301(d)
OF THE DIVORCE CODE
Check either (a) or (b)
(a) I do not oppose entry of a divorce decree.
(b) I do oppose entry of a divorce decree because
Check (i ), (ii), (iii) or both:
( i ) The parties to this action have not lived separate and apart for the required separation period: two years for parties that separated prior to December 5, 2016, and one year for parties that separated on or after December 5, 2016.
( ii ) The marriage is not irretrievably broken.
( iii ) There are economic claims pending.
Check either (a),(b) or (c):
(a) I do not wish to make claims for economic relief. I understand that I may lose rights regarding alimony, division of property, lawyer's fees or expenses. If I do not claim them before a final 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 (2)(b) ABOVE, I MUST ALSO FILE ALL OF MY ECONOMIC CLAIMS WITH THE PROTHONOTARY IN WRITING AND SERVE THEM ON THE OTHER PARTY.
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.
(c) Economic claims have been raised and are not resolved.
I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities.
DATE:________ _______________________
Michael Jenkins, 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.
October 23 2025
LSOM0391671