HomeMy WebLinkAbout02-5255IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND coUNTy,
PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff :
Defendant :
NOTICE TO DEFEND AND CLAIM RIGHTS
YOUHA VE BEENSUED 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 fights important to you, including custody or visitation of
your children.
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, 1 Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT 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
2 Liberty Avenue
Carlisle, PA 17013
.......... (717~ 249-3166
Ee hah demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas
expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la
demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la torte en forma escrita sus defensas o sus objeciunes a las demandas en
contra suya.
Se has avisado que si usted no se defienda, la corte tomara medidas y puede enlzar una
orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en
ia petition do demanda. USTED PUEDE PERDER 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 OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES 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. Ail 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
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2002-
:
: CIVIL ACTION - LAW
:
: IN DIVORCE
OMPLAINT UNDER §~301(c) or (d) OF THE DIVORCE CODE
1. Plaintiff is ' I\hf~/k ~-~ e an % ~ o~--, , who currently resides at
Cumberland County, Pennsylvania.
2. Defendant is ~.c~)e2['~'-~,'1~1,~ ~<~'c-(,..~, who cur,:ently resides
at
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on ~-o lq 0 at
The marriage is irretrievably broken, and the parties separated on
There have been no prior actions of divorce or annulment between the parities,
Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
rrfilitary service of the United States of America, but is in fact livin,~ at the address
given in Paragraph 2 above.
8. Plaintiffhas been advised of the availability of counseling and that Plaintiffmay 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.
Date Plaintiff, Pro Se
I, ~O~t'rl ~l'¢ff_. , verify that the statements made in this Complaint
are true 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.
/ 0 -~25 .fo ~ ~/~ o ~O
Date Plaintiff
Assisted by:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Plaintiff
Defendant :
: 1N THE COURT OF COIvI2MON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2002- ~'-~"
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION TO PROCEED IN FORMA PAUPERIS
The Petitioner, ~/O_f'~¥h -~}q ~.~6-., is the Plaintiff in this action. On
her behalf, I, Joan Carey, attorney for MidPenn L~-gal 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.
yly s~.ubmitted:
MidPerm Legal Services
Pro Se Divorce Clinic
8 Irvine Row
Carlisle, PA 17013
VS.
'-~o. (/Z {~--,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FOPJVL~ PAUPER¥$
1. I am the~[(~,'~,'~lin 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 abiJJty to pay the fees and costs is true and
correct.
(a) Name: ~OA. ~2) t'o.~~-~
Address: I'X~tt ~ex~[I,'S
¢) Soci~ S~ufi, Number:
If you ~e presently employed, state
Address:
Salary or wages per month:
Type of work: ~_~ OS ]~o
If you are presently unemployed, state 4~/~
Date of last employment:
Salary or wages per month:
Type of work: ~__~o$
(c) Other income within the past twelve months
Business or profession: ~//~
Other self-employment:
Interest: n
Dividends:
Pension and annuities: tl/A
Social Security benefits: Ft/tt
Support payments: ~/~ 75, o o
Disability payments:
UnemPloyment compensation and ti/ti
supplemental benefits:
Worlanan's compensation: tl
Public Assistance:
Other:
(d) Other contributions to household support
(Wife) (l-Iusb and) Name:
If your (husband) (wife) is employed, state
Employer: ~Jl'c6 SuDperr~ar~-~
salary or wages per month: rl/~4
Type of work:
Contributions from children:
(e) Property owned
Cash: /-?, o o
Checking Account:
Savings Account: ~o O, o o
Certificates of Deposit: d/4
Real Estate (including home):
Motor vehicle: Make ~ CVf°~Sear {
Cos~t'/r'~ Amount owed
Stocks; bonds:
Other:
(f) Debts and obligations ti/fir
Mortgage: rl/A
Rent: ~ ~~)0'~ O
Loans: ~/~' DO, OD
Monthly Expenses:
(g) Persons dependent upon you for support
(Wife) (Husband) Name: /[[~
Children, if any:
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 hue 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. ~ ~~~ .__~/~x_.2/
Date:~ -~ .
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304. i (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:
I 0- 2j- 5
DOCKET NUMBER:
PLAINTIFF/PET!j~ONER SS#
NAME: //( ~/re/4 '~-,~,
DEFENDANT/RESPONDENT
m
m
Plaintiff
V.
Defendant
: IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY', PENNSYLVANIA
:
:
: NO. 2002 - ~o~55
:
: CIVIL ACTION - LAW
:
: IN DIVORCE
AFFIDAVIT OF SERVICE FOR PERSONA/L SERVICE
~)~x~ ~Ou, J~ i C--~- with a Divorce Complaint and Plaintiff's Affidavit
under Section 3301(d) of the Divorce Code by personally handing him/her a copy at
at
(Time)
~ P~q~ Iq- (Street ~.~k~?,er and Address)~T.._~.
(City) (State)
]:119 ~ .m. onthe 1~ dayof [X~O~J
(Date) (Month)
(Zip)
,200
(Year)
(Na~ne of person who performed s~rvice)
Affidavit of Service is tree and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to
authorities.
Date:
Karen Jean Bice
Robert Matthew Bice
Plaintiff
V.
Defendant
· IN THE COURT OF COMMON PLEAS OF
' CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 2002-5255
· CIVIL ACTION - LAW
· IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on October 30,
2002.
2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce.
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:
Signature: ~ ~c~J~~ ~
Robert Matthew Bice, Defendant
Karen Jean Bice
Plaintiff :
V. :
Robert Matthew Bice
Defendant
· IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5255
· CIVIL ACTION - LAW
· IN DIVORCE
o
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECRF. F~ UNDER §3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice·
I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
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 atter it is filed with the
Prothonotary.
I verify that 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.
Date: ~ '- ~-0-O3
Sig
nature:
Robert Matthew Bice
Karen Jean Bice
Robert Matthew Bice
Plaintiff
V.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5255
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on October 30,
2002.
2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce.
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: ~ '.~d)-~)5 Signature: ~"0,~,~--2 _/~.2,~ ,Sz,,?-j
Kar'~h J~hn ~i'ce.. Pro Se~laintiff
Karen Jean Bice
Robert Matthew Bice
Plaintiff
V.
Defendant
· NO. 2002-5255
· CIVIL ACTION - LAW
:
· IN DIVORCE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Date:
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
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 ifI do not claim them before a divorce is granted.
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 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.
Signature:..
Karen Jean B~ce - -
Karen Jean Bice
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs. · No. 2002-5255 CIVIL TERM
· IN DIVORCE
Robert Matthew Bice
Defendant
To The Prothonotary:
PRAECIPE TO TRANSMIT RECORD
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 (c) of the
Divorce Code.
2. Date and Manner of service of the Complaint: Defendant personally accepted service
of the divorce on November 12, 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, February 20, 2003; by Defendant, March 20, 2003.
(b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d)
of the Divorce Code: N/A
(2) Date of filing and service of Plaintiff's Affidavit upon Defendant: N/A
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: N/A.
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: March 24, 2003.
(c) Date Defendant's Waiver of Notice in Section 330 l(c) Divorce was filed
with the Prothonotary: March 24, 2003.
Plaintiff's Social Security Number: 561-17-8155
Defendant's Social Security Number: 561-57-7027
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF ~~ PENNA.
KAREN JEAN BICE
PLEAS
N o. 2002-5255
VERSUS
ROBERT MATTHEW BICE
DECREE IN
DIVORCE
AND NOW,~~- ~
DECREED THAT KAREN JEAN BICE
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
~~, IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED Of RECORDIN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
ALL CLAIMS HAVE BEEN RESOLVED.
PROTHONOTARY