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Home My WebLink About02-5250v. ~ No. 09,- NOTICE TO DEFEND AND CLAIM RIGHTS YOUH.4 FE BE'ENSUED IN COURT. If you wish to defend against the claims set fo~h in the following pages, you must take prompt action. You are warned that if you fa/1 to do so, the case may proceed w/thout 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 may lose money or property or other rights important to you, Plaintiff You your children, including custody or visitation of When the ground for 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONy, DIVISION OF PROPERTY, LAWYER,S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE TIlE RIGIIT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAIVYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE 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 Ee ban demandado a usted a la cone. Si usted quiere defenderse en contra estas demandas expuestas en/as paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus contra suya. objeciones a las demandas en Se has avisado que si usted no se defienda, la corte 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 do demanda. USTED PUEDE PEP, DER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIC1NA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. PARA AVERIGUAR Cumber/and County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DI-~SABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Plaintiff COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- : CIVIL ACTION - LAW : : IN DIVORCE _COMPLAINT UN~) ordO~ DIVORCE CODE 1. Plaintiffis~q.12~I ~,,e-,, .~ ~ ~x"V,~Ci-~_ , who currently resides at Cumberland County, Penns2d~a~:'a 2. Defendant is0~{y~%~c.~/. - ' . ~%.), WhO currently resides at 3. Plaintiff has been a bonafide resident of the Commonwealth of Permsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ~h~q-'~ ..~ \ ~C~.C5,--~ at The marriage is irretrievably broken, and the parties separated on There have been no prior actions of divorce or annulment between the parities. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised °f the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. tqamtiff, Pro Se 'X}~--r~ I, ~/'~t I . ~ ¢ ~-~lq~, verify that the statements made in this Complaint are hue and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unswom falsification to authorities as provided in 18 Pa. C.S. §4904. Date Pla'-intiff (~ Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243~9400 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vii. :NO. 2002~ O5-~5--O Defendant : : 1N DIVORCE PETITION TO PROCEED IN FORMA PAUPERIS The Petition . , is the Plaintiff in this action. On her behalf, I, Joan Carey, attorney for MidPenn Legal Services, do hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn Legal Services is assisting the Petitioner in filing a divorce casepro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests leave to proceed without payment of fees or costs. Rqspectfully submitted: /,~VoXan Carey, Attorney ~ MidPenn Legal Services Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEI~.D IN FORMA PAUPERIS 1. I.am th~to~\ V F in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and COrrect. Address: I_\c_~ {~..) . ~_~(~ ~O-~-'- (b) Social Security Number: \ If you are presently employed, state Employer: ~X~ ~ ~ Address: Salary °r wages per m°nth: ~x~ ~ ~x~ Type of work: If you are presently unemployed, state Date of last employment: Salary or wages per monfl~(~ 4~2)i~ ~ ~.c2~-7.)~-& Type of work: ~,2)~C~4x (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: ~22~-~ ~_~ Social Security benefits: Support payments: ~C~ Disability payments: C'r~h& Unemployment compensation and supplemental benefits: Workman's compensation: 'C'~ 8_ Public Assistance: ~ Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: C~c\\S\~. '-'~x"-~ 4~ Salary or wages per month.~l Type of work: Contributions from children: C'xDrX?..' (e) Property owned Cash: Checking Account: Savings Account:~cy~ Certificates of Deposit: Real Estate (including home): Motor vehicle: Make ~ Year Cost ~C~:F Amount owed Stocks; bonds: ~ Other: (f) Debts and obligations Mortgage: ?x~ca ~ ~ Rent: Monthly Expenses~ \ ~ (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: ~ Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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. 4904, relating to unsworn falsification to authorities. SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY,S OFFICE DATE: ~ DOCKET NUMBER: PLAINTIFF/PETI'FIONER S S# NAME. ~ Plaintiff · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA vi. · NO. 2002- Defendant · · IN DIVORCE .NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d)OF THE DIVORCE CODE The parties to this action separated or~ ~ X,~, C~D~ live separate and apart for a period of t~o ye~r~t~_) - and continued to 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses ifI do not claim them before a Divorce is granted. I,~~ ~. ~'X~(' ~r~(-~-x) , verify that the statements made in this Affidavit are tin'and correct t~) the be~t' of my knoWledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. Daie Plaintiff, Pro Se ~J Bobbi Lynn Latchford Plaintiff Vs. Christopher Adam Latchford Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 02-5250 CIVIL TERM : IN DIVORCE ACCEPTANCE AND ACKNOWLEDGEMENT OF SERVICE I, Christopher Adam Latchford., Defendant in the above captioned proceeding accept and acknowledge service of the Divorce Complaint and Affidavit under §330 l(d) of the Divorce Code filed in this action by the Plaintiff, Bobbi Lynn Latchford. I also waive any defects in any form or manner of service. Date: B~bbi LYnn Latchford, Plaintiff VS. Christopher Adam Latchford, Defendant IN THE COURT OF COMMON PLEAS OF CUM~ERLAm) COtrNTV PENNSYLVANIA NO. 02- 5250 Crv]L TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE DECREE To: Christopher Adam Latchford You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after July 4, 2003 the other party can request the court to enter a final decree in divome. 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 date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the counter-affidavit form 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 OR 1-800-990-9108 Bobbi Lynn Latchford, Plaintiff VS. Christopher Adam Latchford, Defendant : IN THE COURT OF COMMON PLEAS OF CUM~Ee.L~XND COUNTY PENNSYLVAN~ NO. 02- 5250 CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER §3301{d) OF THE DIVORCE CODE 1. Check either (a) or (b) ,J~ I do not the of a divorce decree. (a) oppose entry (b) I oppose the entry of a divorce decree because (check all that apply): [] (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 And expenses ifI 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 [ 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. I verify that the statements made in the counter-affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ff Christopher,~d~(cla~rd, 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. Bobbi Lynn Latchford : Plaintiff : : Vs. : : Christopher Adam Latchford : Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 02-5250 CIVIL TERM : IN DIVORCE ACCEPTANCE AND ACKNOWLEDGEMENT OF SERVICE I, Christopher Adam Latchford., Defendant in the above captioned proceeding accept and acknowledge service of the Divorce Complaint and Affidavit under §330 l(d) of the Divorce Code filed in this action by the Plaintiff, Bobbi Lynn Latchford. I also waive any defects in any form or manner of service. Bobbi Lynn Latchford, Plaintiff VS. Christopher Adam Latchford, Defendant : IN THE COURT OF COMMON PLEAS OF CtmmSRLAND Cou~ PENNSYLVANIA NO. 02-5250 CIVIL TERM : IN 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(d) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgement of Service form on November 28~ 2002. 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, N/A; by Defendant, N/A. (b)(1) Date of execution of the PlaintiWs Affidavit required by Section 3301 (d) of the Divorce Code: October 23~ 2002. (2) Date of filing and service of PlaintiWs Affidavit upon Defendant: Filing Date: April 15, 2003. Date of Service: November 28~ 2002. 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (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: Defendant was personally served on April 17, 2003. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divome was filed with the Prothonotary: N/A. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: N/A. Plaintiff's Social Security Number: 163-60-1462 Defendant's Social Security Number: 206-58-7082 Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 IN THE COURT Of COMMON PLEAS Cf CUMBERLAND COUNTY ST/~TE OF .~.. PENNA. BOBBI LYNN LATCHFORD PLAINTIFF VERSUS CHRISTOPHER ADAM LATCHFORD DEFENDANT N o. 02-5250 _cJ_v_iL_ DECREE iN DIVORCE AND NOW,~ , IT [$ ORDERED AND DECREED THAT BOBBI LYNN LATCHFORD PLAINTIFF, AND CHRISTOPHER ADAM LATCHFORD ,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; ALL CLAIMS HAVE BEEN RESOLVED. ~TARY