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HomeMy WebLinkAbout96-01193A M) a? C7 {Atr .;?, .?. .x. .yp .:t• 91F 314 ?JC .ME..ry?..:i• ?:K• :?. .?. .:K• :K• .:K• :K..:K• S .x. •:16'. •7K. •a[• •A4 {Afi •:A6 •? 91p. ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ?t JENNIFER MICHELLE LAMBERT ? •? \; n, 1193 I996 j( A CARL DOUGLAS LAMBERT, JR. ?f DECREE IN DI VORCE AND NOW . ............................ . 19...... , it is ordered and $ n MICHELLE LAMBERT. ..JENNIFER. .... ..... ................. , plaintiff, decreed that VS . ? and .... CARS,. pOUGPA$ . LAMBERT.,. .JR ........................ . defendant, y y R t1 are divorced from the bonds of matrimony. fl 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; ............................... .............. .... ...... 8 . k By The Court! + Attest: J. 3 3 Prothonotary 7116 fL yK..yt..y?. ,M. .?. :x. .:1t• :w:' 'i?4 !11:• 'Li.' :w -:?: :?:{1: :?:i1i !?:;1:' :1: :?:CO:' :1i •'.?i' ti?% •'XJ ?. Ralf W. Greenwood, Jr. I.D. No. 52343 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 19103-2793 (610) 965.2761 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Attomey for Plaintiff Court of Common Pleas Cumberland County No. 96-1193 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrivable breakdown under § 3301(d) of the Divorce Code. 2. The complaint was served by United States mail and an Acceptance of Service signed by the Defendant was filed on May 22, 1996. 3. Plaintiff executed the affidavit required by § 201(d) of the Divorce Code on August 28, 1998. 4. Plaintiffs affidavit required by § 201(d) of the Divorce Code was served upon Defendant at Defendant's last known address, which is is the home of Defendnat's father, 1700 Burlington Avenue, Delanco, NJ 08075 by first-class mail, postage prepaid, on August 31, 1998. 5. There are no related claims By: n g. RAL W. G ENW I.D. 0.52343 Attor y for Plaintiff , JR. ?" N G <. f)i ?.?_ c r. V _, ?. ? .?? ?u_ ? ip ??? l j, N 1 I ??_ L .n Y u? C v ' CJ .? T { 1.: n ? H L: H lu 1 N a o _ W n J to 2 0 ? Z J O >. Ln 67 W i 2 M it W n 0 0(L n i < cu m 0 N r.l x .w w?o? maa,n?.va?, v n rc.w OIrrIYC`r 6').4YN qn1. 11rIL IM1 JENNIFER MICHELLE LAMBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. No. it ?l' 3 C"tr / Te» CARL DOUGLAS LAMBERT, JR., CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED N O T I C E YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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. Court Administrator Cumberland County Courthouse, 4th Floor One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 N O T I C I A Le han demandado a usted en 1a Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la facha de la demanda y la notificacion. Usted debe presenter una apariencia escrita o en Persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objectiones a las demandas encontra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse, 4th Floor One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 44WWIDWw ra.W.rutmp.e mmrse 7:41pe JENNIFER MICHELLE LAMBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. (j W; 3 L'co. y T. CARL DOUGLAS LAMBERT, JR., Defendant CIVIL ACTION - DIVORCE COWLAINT UNDER SECTION 3301(c) OR 33010 OF TIIE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Jennifer Michelle Lambert, by her attorneys, SMIGEL, ANDERSON & SACKS, and represents as follows: COUNT I OR 3301(d OFT UNDER DIVORCE CODE 1. Plaintiff is Jennifer Michelle Lambert, who currently resides at 607 B, Apartment 35, Geneva Drive, Mechanicsburg, Pennsylvania and has resided there since on or about June 1995. 2. Defendant is Carl Douglas Lambert, Jr., who currently resides at 1700 Burlington Avenue, Delanco, New Jersey 08075. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 17, 1993, at Lawton, Oklahoma. S. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 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. 8. Plaintiff avers that there are no children of the parties under the age of 18. 9. Plaintiff requests the court to enter a decree of divorce. SMIGEL, ANDERSON & SACKS - 2 - By: • a.vG1/L•7(J(Jlj((. IDO 76327 Vi 2917 North Front Street Harrisburg, PA 17110-1223 (717) 234-2401 Attorneys for Plaintiff 5C }r VERIFICATION I, Jennifer Michelle Lambert, verify that the statements made in this Complaint 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 /?" J er chelle Lambert 4d161-/lmY1P8WhM l of 6pviOdAytil 19, 1996 JENNIFER MICHELLE LAMBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 96-1193 CIVIL TERM CARL DOUGLAS LAMBERT, JR., Defendant CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I, CARL DOUGLAS LAMBERT, JR., Defendant, accept service of the Divorce Complaint and certify that I am authorized to do so. Date: ,2J?atcl? ? Ad e CARL DOUGLAS LAMBERT, 4TRe ,: Ralf W. Greenwood, Jr. I.D. No. 32343 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 19103.2793 (810) 965-2761 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Attorney for Plaintiff Court of Common Pleas Cumberland County No. 96-1193 PLAINTIFF'S AFFIDAVIT UNDER § 3301 (d) 1. A Complaint in Divorce under § 3301 (d) of the Divorce Code was filed on March 5, 1996. 2. The parties in this action separated on or about August 7, 1994 and have continued to live separate and apart for a period of at least two years. 3. The marriage is irretrievably broken. 4. 1 understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, costs or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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. § 4904 relating to unsworn falsification to authorities. DATE: r, cr Li I?? ( Ralf W. Greenwood, Jr M No. 32343 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 19103-2793 (610) 965.2761 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 98-1193 AFFIDAVIT OF NON-MILITARY SERVICE JENNIFER MICHELLE LAMBERT, being duly sworn according to law, deposes and says that she knows of her personal knowledge, and therefore avers, that Carl Douglas Lambert, Jr., the Defendant in this action, is 27 years of age, that his last known residence is 1700 Burlington Avenue, Delanco, NJ 08075, and that he is not in the military or naval service of the United States or its allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. Sworn to and subscribed before me this day of $ 1998. Notary Public K';TAHIALSEAL -_ WALMI L. VANCH. Nc'ary putGc Su_q(; n%, .u ir,U 0"upM"I County My Comm' Attorney for Plaintiff y c: ri r ??. '-; ?_ ui' , r S';^ r+ : ? `_ :. ?T} ? n C-?..Gr O. .:.iu ?.. ?. '? ?; ?,i .1 1 Ralf W Greenwood, Jr. I.D. No, 52343 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 19103-2793 (810) 965.2761 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 96-1193 AFFIDAVIT OF RALF W. GREENWOOD, JR. RALF W. GREENWOOD, JR., ESQUIRE, being duly sworn according to law, deposes and says as follows: 1. 1 am the attorney of record for Plaintiff in this matter. 2. The Plaintiff is my step-daughter. I have personal knowledge that Plaintiff and the Defendant have not lived together for more than four years as of this date. During this period the parties have not seen or communicated with one another. 3. For the foregoing reasons, there is some question as to where the Defendant currently resides. 4. On October 22, 1998 1 caused the INA detective agency, of Harrisburg, Pennsylvania, to conduct a social security number search on the Defendant's social security number, which is 204-56-0286. 5. The report of the aforementioned search as attached hereto as Exhibit 1, Attorney for Plaintiff and is hereby incorporated by reference. 8. The address given on Exhibit 1 as 282 W. Ridge Road, Nottingham, Pennsylvania, 19382 is known to be the Defendant's father's address; and it is known that the Defendant has used his father's address as his mailing address within the past four years. 7. The address given on Exhibit 1 as 5225 Winding Way, Harrisburg, Pennsylvania, was formerly the Plaintiffs address, to which the Defendant had his mail forwarded. The Defendant has never resided at this address. 8. The address given on Exhibit 1 as 344 Hodgson Street, Apt. 8, Oxford, Pennsylvania, 19383, was the Defendant's address during part of 1996 and 1997; the defendant has not resided at this address during the last twelve months. 9. The address given on Exhibit 1 as 273 East A Street, Torrington, Wyoming, 82240 is stated on Eyhibit 1 to be valid as of February, 1998; and it is believed that this address is the Defendant's current address. 10. 1 have provided the Prothonotary's office with self-addressed, stamped envelopes for service to both the Nottin m, Penns Iva and the Torrington, Wyoming addresses. Ralf %1. Greenwood, Jr. Sworn to and subscribed before me this 0,?0h'ga day of 1998. Notary N b is ?IemUe,, Veniullvai.w A.,uuaUUn of NUIG.J GOTWX 2d4'-16-s dd TRANS UNION TRACE REPORT flKT-,SUi INFIL.E DATE TIME FOR 17 PHSSN DW WY ON 0 SOCSOL SECURITY NUMMER TRACE * 201-36-0206 08HAW.ALM*wm END MT NAME ADDA RPT DATE ADDRESS 1. LAV43m. CARL D. 262 Y. RIDS41 RD.- NLQTTINBHAM PA. 19312 ".,1996 5223 WINDIN9 WY.. NARRISvjm PA. 17109? 000HAW.ALERTaCLEAR FOR ALL SEARCHES PvWORMED+; 2. LMNNM- CARL. 0.JR. d2?19lL1 273 E. A. TORRINGTON WY. 02240 344 HODGSON ST.. ". OWORD PA. 19363 OV19% 3225 WINDING WY., HARRISBURG PA. 17109 •wIMM(-ALERTICLEAR FOR ALL SEARCHES PERFORNED+*w w1EN0 OF NETWORK TRACE*+ COPYRIGHTED TRANS UNION 1993 c ?. l/.1 cv U i? U Reff W. Greenwood, Jr. M No. 52343 4000 Bell Atlantic Tower Attorney for Plaintiff 1717 Arch Street Philadelphia, PA 191034793 (215) 994.5176 EAX 994-5146 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 96-1193 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance in the above-captioned matter. By: W ittL Heather D. RoyV-'' Attorney for PlakdW-f ' I. D. # 76327 SMIGEL, ANDERSON & SACKS 2917 North Front Street Harrisburg, PA 17110-1223 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the By: Ralf Jr. Attorn y for Plaintiff I.D. # 2343 4000 Bell Atlantic Tower Philadelphia, PA 19103-2793 (215) 994-5176 t: ? i ? ?': ?? ,, `?. u ?" CJ °i .? r Ralf W Greenwood, Jr. 1. D. No. 32343 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 19103-2793 (610) 965-2761 Jennifer Michelle Lambert Plaintiff V, Attorney for Plaintiff Court of Common Pleas Cumberland County No. 98-1193 Carl Douglas Lambert, Jr. Defendant NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT RECORD TO: CARL DOUGLAS LAMBERT, JR. You are hereby given notice that five days following the mailing of this notice, a Praecipe to Transmit record will be filed in this matter with the Prothonotary. After the Praecipe is filed, you will have a period of ten days during which you may file objections to the entry of the Final Decree based upon this Praecipe. Any objections must be filed in writing with the Prothonotary, Cumberland County Court of Common Pleas, One Courthouse Square, Carisle, PA 17013. If no objections are filed before the expiration of the ten-day period, this case will be submitted to the Court for entry of the Final Decre . Date of Mailing: September 8, 41 ) Bv: /%/--- -- RAF W. GREENWOOD, JR. I.D, No. 52343 Atto ney for Plaintiff Ralf W. Greenwood, Jr. I.D. No. 52343 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 19103.2793 (810) 905-2781 Attorney for Plaintiff Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant CERTIFICATE OF SERVICE Court of Common Pleas Cumberland County No. 98-1193 Ralf W. Greenwood, Jr., hereby certifies that on September 8, 1998 he caused to be served upon the following a true and correct copy of a Notice of Intent to File Praecipe to Transmit Record and a copy of the affidavit required by § 201 (d) of the Divorce Code, by first-class mail, postage pre-paid, as follows: Carl Douglas Lambert, Jr. 1700 Burlington Avenue Delanco, NJ 08075 The aforementioned Notice and affidavit Date: By: e t b en re et W. Greenwood, Jr. postmaster. Y t•1 ' Cr (Y i.. 1 f?_ c r ?1 CL. [•. _ -j L'. C ln". othonotary turthouse ie Courthouse Square idisle, PA 17013-3307 Carl Lambert, Jr. 262 W. Ridge Road Nottingham, PA 19362 0 1 ', LAW OFFICES OF RALF W. GREENWCOu JR. 4000 Bell Atlantic Tower 171 ] Arch Street Philadelphia. PA 19103 A Ralf W. Greenwood, Jr., Esquire 118 Church Street Macungie, PA 18082 a 44 1 N r r 1,. 610 ge&3a30 f•.M.? u?On'11 y,, 1 `?.r+ 5-1 M) 2 V? 6 Is ? 8 T 0 a • ?1 0 e s-v u 0 t ?? J v ? io `? ? • ! y d c 4 A X a•puy?•s tu+l+ Y'QdTE 40 B6 '9Z '60 y ? IN THE COURT OF COMMON PLEAS i! OF CUMBERLAND COUNTY s? PENNA. STATE OF + , M ; ft JENNIFER MICHELLE LAMBERT 1193 1996 CARL DOUGLAS LAMBERT, JR. r DECREE IN DI VORCE AND NOW .............................. 19...... , it is or dered and 11 t ti NNIFER•MIq"V;,J.•$.I•AMBIr6T.......... J. decreed that . . . . . . . . . E. .. . Plaintiff, . ? and . • . • • CARL. AOUGLAS . LAMBERT.,..JR. ...................... . defendant, are divorced from the bonds of matrimony. 8 $ $ 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 k been entered, ............... ................................ ........... ft ................. M r? By The Cuurl y Attest: J. Prothonotary ` tit. LsG 'JC• •iY• •7C• rx• •Y:• .•y;. t«••:M.•?:«• •9?> ce: c«• :e:? te: cq :e: te: <« •:e> :r• •7N te:•?:e> <e: :«• ?a;• •:IG nil AL 542 RALF W. GREENWOOD, ESQUIRE w+aoo+m •? MACUNGIE. PA PH. 610.OW2761 ,? . jgg - F^ ?? ? rt r1 olIJL^.tiy -- 1 $ -7 mr Allim 1223137`30691: 625&0001280' 8542 ._.n. i Prothonotary Courthouse One Courthouse Square Carlisle, PA 17013-3387 Carl Lambert, Jr. 273 East A Street Torrington, WY 82240 -ja1= r t: i ' 1 JENNIFER MICHELLE LAMBERT, PLAINTIFF V. CARL DOUGLAS LAMBERT, JR. DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 96-1193 CIVIL TERM .;. ; . AND NOW, this 28th day of October, 1998, the request of plaintiff for the entry of a decree In divorce at this time, IS DENIED.' By the Edgar Ralf W. Greenwood, Jr., Esquire 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 17103-2793 For Plaintiff Carl Douglas Lambert, Jr. 1700 Burlington Avenue Delanco, NJ 08075 :sea 1. As required by Pa. Rule of Civil Procedure 1920.72(d), Section 3301(d) did not advise defendant that he must file a counter-affidavit within twenty days after service or the statements will be admitted. A new affidavit should be filed with proper service. A notice of Intent to file a praecipe to transmit the record cannot be filed until twenty days after service of the Section 3301(d) affidavit. r?)Fn?'?. •• ? • 2A , ?; t ?nC;?? ,. S? c.''? JENNIFER MICHELLE LAMBERT, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CARL DOUGLAS LAMBERT, JR. DEFENDANT : 96-1193 CIVIL TERM ORDER OF COURT AND NOW, this 28th day of October, 1998, the request of plaintiff for the entry of a decree in divorce at this time, IS DENIED.' By the Edgar Ralf W. Greenwood, Jr., Esquire 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, PA 17103-2793 For Plaintiff Carl Douglas Lambert, Jr. 1700 Burlington Avenue Delanco, NJ 08075 :sea C 1. As required by Pa. Rule of Civil Procedure 1920.72(d), Section 3301(d) did not advise defendant that he must file a counter-affidavit within twenty days after service or the statements will be admitted. A new affidavit should be filed with proper service. A notice of intent to file a praecipe to transmit the record cannot be filed until twenty days after service of the Section 3301(d) affidavit. ._.. • EDGAR B. BAYLEY JUDGE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013-3387 act 18.9 8 :o3z= I 0.5. GOS ( f... In.vrMq,?m AOflr sasy,'..,,: aid D glas rt J \ 170Q urlin lanc M.- ?E r Raft W. Greenwood, A I.D. No. 52343 118 S. Church Street Attorney for Plaintiff Macungie, PA 18082.1020 (810) 985.2781 FAX 966.3830 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 1996-1193 CIVIL Civil Action - Divorce AMENDED COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: Plaintiff, Jennifer Michelle Lambert, by her attorney, Ralf W. Greenwood, Jr., represents as follows: COUNTI DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Jennifer Michelle Lambert, who currently resides at e07 B, Apartment 35, Geneva Drive, Mechanicsburg, Pennsylvania, and has resided there since on or about June, 1995. 2. Defendant is Carl Douglas Lambert, who currently resides at 273 East A Street, Torrington, Wyoming. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Amended Complaint. 4. The Plaintiff and Defendant were married on December 19, 1993 at Lawton, Oklahoma. 5. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 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. 8. Plaintiff avers that there are no children under the age of 18 years issuing from the marriage. 9. Plaintiff requests the court to enter a decree of divorce. COUNT II REQUEST FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 10. Paragraphs 1 through 9 of this Amended Complaint are incorporated herein by reference as though set forth at length. 11. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 12. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff respectfully requests "onoroo Court jq enter an ward of alimony in her favor pursuant to Section By: Ralf W. (greenwood, Jr., [r C7) J C.71 J 1 ?r a 8? ? Ralf W. Greenwood, Jr. 1. D. No. 32343 P.O. Box 3342 Allentown. PA 18106-0342 Attorney for Plaintiff Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 96-1193 PRAECIPE TO ATTACH VERIFICATION TO THE PROTHONOTARY: Kindly attach the within Verification to the on or about June 9, 2000. Date: 2-27-00 By: er I hereby verify that the statements made in the within Amended Complaint 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 IS Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE:/L, G O Ralf W. Greenwood, A L O. No. 32313 P.O. Box 3311 Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Attomey for Plaintiff Court of Common Pleas Cumberland County No. 98-1193 Ralf W. Greenwood, Jr., hereby certifies that on July 27, 2000 he caused a true and correct copy of the Amended Complaint to be served upon the following by first-class mail, postage prepaid: Carl Lambert, Jr. 273 East A Street Torrington, WY 82240-888; Date: By: Ralf W. Greenwood, Jr. 10. No. 32343 P.O. Box 3342 Attorney for Plaintiff Jennifer Michelle Lambert Court of Common Pleas Plaintiff Cumberland County V. Carl Douglas Lambert, Jr. Defendant No. 98-1193 Ralf W. Greenwood, Jr., hereby certifies that on July 27, 2000 he caused a true and correct copy of the Amended Complaint to be served upon the following by first-class mail, postage prepaid: Carl Lambert, Jr. 273 East A Street Torrington, WY 82240-888; Date: -222-00 By: RALF W. GREENWOOD, JR., ESQUIRE LD. All. J2.Il.t P.O. Box 3.142 IR¢ntown, P.1 18106.0.142 TEL EI'IIOA'E. (610) 96.1-2761 F IC 1111I.E. (610) 966-.1830 JENNIFER MICHELLE LAMBERT Plaintiff I TTORNE), FOR PLALvTI FF CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 96-1193 V. CARL DOUGLAS LAMBERT, JR. Defendant CIVIL ACTION - DIVORCE STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: Please be advised that the Plaintiff the a6a case. By: Ralf W. reenwoocl, Jr., Esquire Attorney or Plaintiff =. ? ,: ., .. 4436.141HD1Up=VAccepunce of Service/April 19, 1996 JENNIFER MICHELLE LAMBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 96-1193 CIVIL TERM CARL DOUGLAS LAMBERT, JR., Defendant CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I, CARL DOUGLAS LAMBERT, JR., Defendant, accept service of the Divorce Complaint and certify that I am authorized to do so. Date: I?A-.4 0.66 ? dwc .??77s CARL DOUGEAS LAMBERT. ?? ss 3 cio to Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant AFFIDAVIT OF CONSENT Court of Common Pleas Cumberland County No. 96-1193 1. A complaint in divorce under 3301 (c) of the Divorce Code was filed on March 5, 1996. 2. The marriage of the parties is irretrievably broken and ninety days have elapsed RM $Le 40 Rf # i"in& trip FROI 'RING 3. I consent to the entry of a final decree of divorce. I hereby waive my right to receive a notice of intention to request entry of the divorce decree. I verify that the statements made in phis affidavit are trite 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. 4904 relating to unworn falsification to authorities. DATE:. 9 /z/ /'J'7 Jennifer Michelle Lambert Plaintiff v. v. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. Q6-1193 WAIVER OF NOTICE OF JNTTNTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a find decree of divorce without notice. 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 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. 4904 relating to unsworn falsification to authorities. ow,E qlqL67 f 1. JENNIFER MICHELLE LAMBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 96-1193 CIVIL TERM CARL DOUGLAS LAMBERT, JR., Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 5, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree of Divorce. .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. 5. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being entered by the Court. l I verify that the statements made in this Affidavit 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: CARL DOUGLAS LAMBERT,-JR.-.. DEFENDANT `Ile - x co Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 96-1193 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNER 301(C) OF THE DIVORCE CODE 1. I consent to the entry of a find decree of divorce without notice. 2. I understand that I may lose rights Foncerning alimony, division of property, lawyer's fees or expenses if I do not clam than before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will In sent to me immediately after it is filed with the prothopotary. 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. 4904 relating to unworn falsification to authorities. DATE: (ZC& Zl La-o,2 ?M zke? ' IV , Carl l>ouglds Lambert, Jr. VERIFICATION I, Carl Douglas Lambert, Jr., verify that the statements made in this Amended Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, rclafng to unworn faisif fftion to authorities. Date:_ JJZddD ;Z Farj Douglas Lambert, Jr. } s ?:?'??.'?;i tom. c V ? i Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defeendant Court of Common Pleas Cumberland County No. 1996-1193 CIVIL Civil Action - Divorce AMENDED COMPLAINT UNDER SECTION 3301(c) OR 3301 (0) OF THE DIVORCE CODE TO Tj#E HONORABLE, THE JUDGEF OF SAID COCJRT: Plaintiff, Jennifer Michelle Lamrt represents as follows: COUNT I DIVORCE UNDER SECTION 3301(c) OR 3301(d) Of TH? DIVORCE CODE 1. Plaintiff is Jennifer Michele LaTbert, who currently resides at 412 W. Savory Street, Pottsville, Pennsylvania, ,and has resided there since on or about dune, 2006. 2. Defendant is Carl Douglas Lambert Jr., who currently resides at 264 Olympus Boulevard, Court Ludlow, Wjshi pon. 3 . Plaintiff has been a bona fide, res}dent in the Commonwealth for at least six mks it ately previous to the, filing of this Ama*d Complaint. 4. The Plaintiff and Defendant were married on December 17, 1993 at Lawton, Oklahoma. 5. There have been no prior actions Pf divorce or for annulment between the parties. 6. The marriage, is irretrievably bro? en. 7. Plaintiff has been advised tlat counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff avers that there are no children wider the age of 18 years issuing from the marriage. 9. Plaintiff requests the court to enter a decree of divorce. VERIFICATION I, Jennifer Michelle Lambert, verify that the statements made in this Complaint 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:-q/ Cllot-7- F 1,3 P 2 IS Ii In - '7S ,r ? ' ? ?._ v Cn ?x ,. C ... ? - ? ?? ?r QD W jM0t' '.r rntt keuc Lamjoerb ` I11'h ti ff vs. Carl lax9ia s tamau-t, ,?r: Z)Jtndanr IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 9 jp - 11 Q 3 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 Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Ud0 1 6 nboo S 13r 104 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: d' by plaintiff. q /!0- by defendant .131 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: "One.. 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 plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: % c.) 1 J %j r Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: cam, T x ;T tbi J r k jL- ?F 4 ._ r. JENNIFER MICHELLE LAMBERT, PLAINTIFF V. CARL DOUGLAS LAMBERT, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 96-1193 CIVIL TERM ORDER OF COURT AND NOW, this day of October, 2007, the request for the entry of a decree in divorce, IS DENIED AT THIS TIME.' ,,/ennifer M. Lambert, Pro se 412 W. Savory Street Pottsville, PA 17901 Zarl D. Lambert, Jr., Pro se 264 Olympus Blvd. Court Ludlow, WA 98365 sal 'J By the C Edgar B. Bayley, J. Y 'This divorce action originally filed in 1996 is in complete tray. Plaintiff filed an amended complaint under Sections 3301(c) and 3301(d) of the Divorce Code on September 13, 2007. The amended complaint could not be filed without leave of court or the consent of defendant. Therefore, it is a nullity. The praecipe to transmit the record sets forth that the amended complaint was served on August 31, 2007, by certified mail, which would mean it was served before it was filed. No certified mail receipt by defendant was filed. Rather, there is a document signed by Carl Douglas Lambert, Jr., as to the acceptance of service dated August 31, 2007, again prior to the filing of the amended complaint on September 13, 2007. Service cannot be made before a document is filed. Defendant signed a Section 3301(c) affidavit of consent on August 31, 2007. Plaintiff signed a Section 3301(c) affidavit of consent on September 4, 2007. Affidavits of consent cannot be signed until ninety days after the filing and service of the amended complaint. `4. ftv °w Ln ?? sr r? - .. ,,, cn Lk . f C-i Jennifer Michelle Lambert Plaintiff V. Court of Common Pleas Cumberland County No. 96-1193 Carl Douglas Lambert, Jr. NOTICE Defendant If you wish to deny any of the s%tergpts set forth in this Affidavit, you must file a Countcr-Affidavit within twenty (20) d#ys after this Affidavit has been served on you, or the statements will be admitted. AFFIDAVIT UNDER SECTION 3, 01(d) OF THE DJVOR E CODE 1. The parties to this action separated on August 8, 1995, and have continued to live separate and apVt for 4 period of at least two years. 2. The marriage is irretrievably proken. 3. I understand that I may lpse TIghts concerning alimony, division of property, lawyer's fees or 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 herein are made subjep? to the penalties of 18 Pa. C.S. s4904 relating to unsworn falsification to authorities. Date; m c... x ?;? a?D ? ?; ?i G "L7 ?, "? ? --C y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jennifer Michelle Lambert, Plaintiff V. Carl Douglas Lambert, Jr., Defendant No. 96-1193 DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check: (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (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 (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 delay. I verify that the statements made in this Counter-affidavit are true and correct. I understand that r false statements herein are made subject to the penalties of 18 Pa.C. S. Section 4904 relating to unworn falsification to authorities. Date 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 need not file this Counter-davit. r t ? ii ' ?? ?g"o ?? t C. ? i ? ~ ? 5-?° . .. a't s"m IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jennifer Michelle Lambert, Plaintiff No. 96-1193 V. Carl Douglas Lambert, Jr. Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (d) DIVORCE DECREE TO: Carl Douglas Lambert, Jr. 264 Olympus Boulevard Court Ludlow, Washington 98365 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the section 3301 (d) Affidavit. Therefore, on or after February 18, 2008, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above the date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR 11 .. 1% TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR Cumberland County Courthouse 1 Courthouse Square, 3R Carlisle, PA 17013 (717) 240-6200 1-888-697-0371, x6200 Enclosure C:zp rt --t ..r r? 1'ti1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jennifer Michelle Lambert, Plaintiff V. No. 96-1193 Carl Douglas Lambert, Jr., Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true and correct copy of the foregoing Notice of Intention to Request Entry of Divorce Decree and Counter-Affidavit was served by first class mail to the following: rl> r-` O-N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jennifer Michelle Lambert, Plaintiff V. No. 96-1193 Carl Douglas Lambert Jr., Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under Section 3301(c) or 3301(d) of the Divorce Code. 2. Date and manner of service of Complaint: Acceptance of Service signed on on 04/25/1996 and served by registered mail. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff by Defendant (b Date of execution of Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: 09/30/1998 ;Date of service ofthe Plaintiff's Affidavit upon the Defendant: 08/07/1996. 4. Related claims pending: None Complete either (a)or (b). 0(a) Date and manner of service of the Notice of Intention, a copy of which is attached: 02/01/2008 via first class mail. N (b) Date Plaintiff s Waiver of Notice was filed with the Prothonotary: Date Defendant's Waiver of Notice was filed with the Prothonotary: Dated: t"? r? -Ti om.. YN T ? V i 77 ,f JENNIFER MICHELLE LAMBERT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CARL DOUGLAS LAMBERT, JR. : 96-1193 CIVIL TERM ORDER OF COURT AND NOW, this day of March, 2008, the request for the entry of a decree in divorce, IS DENIED AT THIS TIME.' Jennifer M. Lambert 412 W. Savory Street Pottsville, PA 17901 ?Carl D. Lambert, Jr. 264 Olympus Blvd. Court Ludlow, WA 98365 sal 0 1 LL ,a P 0-S en CCL S/10 /0 0 -tL? By the ' This is the third time we refused to enter a divorce decree. The record is deficient of the requirements for the entry of a final decree. cV ? C j ""!C 0- `rte-' J a 1 A. `? C= N Jennifer Michelle Lambert Pleas Plaintiff V. CIVIL Carl Douglas Lambert, Jr. Defendant Court of Common Cumberland County No. 1996-1193 PRAECIPE TO REINSTATE AMENDED COMPLAINT IN DIVORCE TO THE PROTHONOTARY: Kindly reinstate the above-captioned Amended Complaint in Divorce. Pro Se w o v zt - rn € jr- e ,9h. ' { Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant NOTICE Court of Common Pleas Cumberland County No. 96-1193 If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within twenty (20) days after this Affidavit has been served on you, or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on August 8, 1995, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the tie of 18 C.S. s4?Q4 relating to unswom falsification to authorities. Date: -) ( / I ka-- ,; t„-F?, '?.? ? t. ?;?} cs? { ?. ?... ^-{ ?,? tr '-.:1 ',.t. s° Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant AFFIDAVIT OF SERVICE Court of Common Pleas Cumberland County No. 1996-1193 CIVIL Civil Action - Divorce I, Jennifer Michelle Lambert (Plaintiff), being duly affirmed according to law, depose and say that: 1. On March 27, 2008, a copy of the Complaint in Divorce in the above captioned-matter was mailed to the Defendant by Certified Mail/Restricted Delivery at the Defendant's last known address, as indicated on the attached mailing receipt. 2. On March 31, 2008 and on April 1, 2008, the United States Postal Service attempted to deliver the Complaint in Divorc Certified Mail/Restricted Delivery. Evidence are attached hereto made part_bdrjpf_\ USPS - Track R Confirm • . r EX h; n http://trkcnfrml.smi.u.sps.com/PTSIntemetWeb/InterLabe]Detail.do _ UNITEOSTATES 'OSTAL SERVICE= Home I Help I Sian in Track 8 Confirm FAgs Track & Confirm Search Results Labei/Reeeipt Number: 7007 3020 0001 0616 9929 Detailed Results: • Delivered, April 29,200111,11:24 pm, POTTSVILLE, PA 17901 • Unclaimed, April 21, 2006, 2:36 pm, PORT LUDLOW, WA • Notice Left, April 01, 2006, 9:42 am, PORT LUDLOW, WA 96366 • Processed, April 01, 2006, 7:44 am, PORT HADLOCIKWA 96339 • Notice Left, March 31, 2006, 11:16 am, PORT LUDLOW, WA 98366 • Arrival at Unit, March 31, 2006, 8:67 am, PORT HADLOCK, WA 98339 • Acceptance, March 27,2008,10:57 am, POTTSVILLE, PA 17901 8;,, E Ref-Flo usps com Nonre > Traci, & i;oult,m Enter Label/Receipt Number. t:u Notrff263lioo ol;.tior,:> Track & Confirm by email Get current event information or updates for your Item sent to you or others by email. Go Site map Corrtact Us Forrns Gott Semces Jots Privacy Policy Term of Use National & Premier Accounts CopyrightO 1999-2007 USPS. AN Rights Reserved. No FEAR Act EEO Data FOIA 0 ilF 1 of 1 5/12/2008 4:43 PM a ?, ? f,.., _ ? v '? c?.. _ ? ?. ... a: ^.+ ?- .. ': ? ?; ti _, Jennifer Michelle Lambert Court of Common Pleas Plaintiff V. No. 1996-1193 CIVIL Carl Douglas Lambert, Jr. Defendant CERTIFICATION OF SERVICE BY CERTIFIED MAIL I, Jennifer M. Lambert, state that on or about March 27, 2008, I did notify the defendant, Carl Douglas Lambert, Jr. of this action by mailing a true and correct copy of the amended complaint in divorce in the above-entitled action by certified mail number 7007 3020 0001 0616 9929, restricted delivery, with a return card attachment, addressed to the defendant at 264 Olympus Boulevard, Court Ludlow, Washington 98365. On or about April 29, 2008, I received notice of the certified mail number 7007 3020 00010616 9929, restricted delivery, being returned to sender. Said proof is attached hereto, made a part hereof, and marked Exhibit "A". I verify that the statements made in this pleading are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa.C.S.Section 4904, rel?sworn falsification to authorities. i Ir ru Ir 0- ru" .n -in Postage O $ Certified Fee $2.65 J ? ..? C3 Retum Receipt Fee f2 15 C ?•, %a,k (Endorsement Required) O . e O Restricted Delivery Fee (Endorse mentRequired) :4.10 $ O Total Postage & Fees $9.31 M r%- Sent To ` Street, Apt. o.; or PO Box No. \ ?y u's P A v 6 ----------------------------------- U------ . City State, ZIP+4 --------- -- ---------- 2 N ? o D O C o ? D37 -? (Jp??f :K -Ln 1?...lJI ._r N __1 C 01? P 000 m D M M M M U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, D PROVIDE FOR INSURANCE-POSTMASTER Received From: y Y,` One piece of ordinary mail addressed to: ? L\ \ U UUQ, Lt J? PS Form 3817, Mar. 1989 PS Form :00 USPS POTTSVILLE POTTSVILLE, Pennsylvania 179019998 4144060901 -0096 03/27/2008 (570)622-6744 10:58:54 AM Sales Receipt Product Sale Unit Final Description Qty Price Price PORT LUDLOW WA 98365 $0.41 Zone-8 First-Class Letter 0.90 oz. Return Rcpt (Green Card) $2.15 Restricted Delivery $4.10 Certified $2.65 Label #: 700730200001 06169929 Issue PVI: $9.31 Certificate 1 $1.05 $1.05 of Mailing Total: Paid by: MasterCard Account #: Approval #: Transaction #: 23 903160596 $10.36 $10.36 XXXXXXXXXXXX6633 DRZZDE 13 Order stamps at USPS.com/shop or call 1-800-Stamp24. Go to USPS.com/clicknship to print shipping labels with postage. For other information call 1-800-ASK-USPS. Bill#: 1000403343360 Clerk: 01 All sales final on stamps and postage. Refunds for guaranteed services only. Thank you for your business. www*w*wwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwww www*wwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwww HELP US SERVE YOU BETTER Go to: http://gx.gallup.com/pos TELL US ABOUT YOUR RECENT POSTAL EXPERIENCE YOUR OPINION COUNTS wwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwww wwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwww 7 - _-A t? Customer Copy C Jennifer Michelle Lambert Court of Common Pleas Plaintiff Cumberland County V. Carl Douglas Lambert, Jr. No. 1996-1193 CIVIL Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: Carl Douglas Lambert, Jr. 264 Olympus Blvd. Port Ludlow, WA 18365 You have been sued in an action for divorce. You have failed to answer the Amended Complaint or file a Counter-Affidavit to the Section 3301(d) Affidavit. Therefore, on or after July 7, 2008, the other party can request the court to enter a final decree in divorce. If you do not file with the Protonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. COURT ADMINISTRATOR Cumberland County Courthouse 1 Courthouse Square, 311 Carlisle, PA 17013 717-240-6200 Respectfully submitted, i r M. Lambert, Pro Se r?o C= (D - G C= n r§ ' cn _ r Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant I In The Court of Common Pleas Cumberland County, Pennsylvania No. 1996-1193 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Transmit tine record, together with the following information, to the Court for entry of a divorce decree: 1. Grou for divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date a d manner of service of the Amended Complaint: March 27, 2008 by Certified, Restricted Delivery Mail via the United States Postal Service. 3. Compl a. b. 4. Relate 5. Compl, a. b. ate either paragraph (a) or (b). Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff ; by Defendant Date of execution of Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: Filed with the Prothonotary's Office on May 16, 2008 and mailed a time- stamped copy via first class mail to the Defendant's last known address, 264 Olympus Blvd. Port Ludlow, WA 18365, on May 23, 2008. I claims pending: None fte either (a) or (b). Date and manner of service of the Notice of Intention to file Praecipe, a copy of which is attached: June 25, 2008 by first class mail to the Defendant's last known address, 264 Olympus Blvd. Port Ludlow, WA 18365. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: Date Defendant's Waiver of Notice was filed with the Prothonotarv: Dated: 916108 ? ? --?' ^ y ? 9? 'r ?,.. ? 4, P 1., \ ? ? ?? „ ?I.F `? "Y? ?y? N1 ? ? Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 1996-1193 CIVIL NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: Carl Douglas lambert, Jr. 264 Olympus Port Ludlow, A 18365 You have been sued in an action for divorce. You have failed to answer the Amended Complaint or file a Counter-Affidavit to the Section 3301(d) Affidavit. Therefore, on or after June 9, 2008, the other party can request the court to enter a final decree in divorce. if you don not file with the Protonotary of the court an answer with your signature notarized or verified or a coun er-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you ave already filed with the court a written claim for economic relief, you must do so by the above date o the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. COURT ADMINISTRATOR Cumberland County Courthouse 1 Courthouse Square, 311 Carlisle, PA 17013 717-240-6200 Tern j ca 1) rv? ?n r1 C? -s?s`r'' ? ? ?m t???- ?? -' ? , ?. ; ,?-. Y` ?... P _.?:, ?., S_?r .....? JENNIFER MICHELLE LAMBERT V. CARL DOUGLAS LAMBERT, JR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 96-1193 CIVIL TERM ORDER OF COURT AND NOW, this ? d day of July, 2008, the request for the entry of a final decree in divorce at this time, IS DENIED. By the Court, /Jennifer M. Lambert, Pro se 412 W. Savory Street Pottsville, PA 17901 Carl D. Lambert, Jr., Pro se 264 Olympus Blvd. Court Ludlow, WA 98365 :sal COF I lu Ma" LL 7a t/08 -?7 Edgar 8 Bayley, s-- t.-a Cl-j Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant In The Court of Common Pleas Cumberland County, Pennsylvania No. 1996-1193 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. 2. 3. 4. 5. Ground for divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code. Date and manner of service of the Amended Complaint: March 27, 2008 by Certified, Restricted Delivery Mail via the United States Postal Service. Complete either paragraph (a) or (b). a. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff : by Defendant b. Date of execution of Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: Filed with the Prothonotary's Office on May 16, 2008 and mailed a time- stamped copy via first class mail to the Defendant's last known address, 264 Olympus Blvd. Port Ludlow, WA 19365, on May 23, 2008. Related claims pending: None Complete either (a) or (b). a. Date and manner of service of the Notice of Intention to file Praecipe, a copy of which is attached: June 25, 2008 by first class mail to the Defendant's last known address, 264 Olympus Blvd. Port Ludlow, WA 18365. b. Date Plaintiffs Waiver of Notice was filed with t Date Defendant's Waiver of Notice was filed with n) ) nR Dated: "1 .? -v??? ?* ? Court of common Pleas Jennifer Michelle Lambert Cumberland County Plaintiff V. No. 1995-1193 CIVIL Carl Douglas Lambert, Jr. Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE T0: Carl Douglas Lambert, Jr. 264 Olympus Blvd. Port Ludlow, WA 18365 nded Comp 'a'nt failed to answer the Ame ber . You have an action for divorce er July 7, 2008, the o .f Jennifer M. Lambert 412 W. Savory Street ' Pottsville, PA ILED-0 ?. " Y ; .. < < r.. -•H. , ? p 27901 P F OF f ` •V•.•yM. ir? V L? i { OWW(7Y?1? Carl Lambert, Jr. 264 Olympus Blvd. Port Ludlow, 18365 NZXIa 964 DE 1 00 07 -:. RETURN TO SENDER NOT DELIVERABLE AS ADDRESSEE " UNABLE TO FORWARD DC: 17901395412 *2923-23307- 13)) j11111)10011. M,IJ11.1 -fhis \"S Lloufrs -)-o KQe.p /-+krb? Q Jennifer Michelle Lambert Plaintiff V. Carl Douglas Lambert, Jr. Defendant Court of Common Pleas Cumberland County No. 1996-1193 CIVIL Civil Action - Divorce AMENDED COMPLAINT UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: Plaintiff, Jennifer Michelle Lambert represents as follows: COUNTI DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Jennifer Michelle Lambert, who currently resides at 412 W. Savory Street, Pottsville, Pennsylvania, and has resided there since on or about June, r Ti: F OF THE Ppm-if ':""' lEu'G . P ?$ o113t ;d' C' 4 C??^J 2 !()? , ??1S3R038 c? ? 1d1333y N 3y ' to 6266 9'C90 200D 020E ?-bu- ?- 1-10 A83AI13 Q ? 03131HIS-38 00 gPYLEY GPR $' ED pU??H?? p[?lp 170??'3387 i G N?l5`?v CPRU'?"' PE ;" ??PPC56rq„ !_? X008 001. %MA FR ?-.. bert, Jr _ 14 0011!2/00 Garl ©• 1-a us Blvd • g5 41DA cv i ?ENprcgRESsEP 2g4 Owm ll WA ON lodlov" N r o 11 ?©RQ -1` a J u? GO NSXS ? Dl~ UNAF3ftA r ?c0'? Q`04seE? O N '10-10 1„11N X1111 cka- cva-Ass David D. Buei-C prothonotary KirkS. Sohonage, ESQ Solicitor y 4= i. r 1,10 ;r 1Rgnee X Simpson 1" Depuq Trothonotary Irene E. 9dorrow 2nd Deputy (Prothonotary Office of the Prothonotary Cumberfand County, 1Tennsylvania CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25T" DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION 70 PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square* Suite 100 e Carfsfe, (PA 17013 • (717)240-6195 • 'F .)C(717)240-6573