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Home My WebLink About00-00918 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "~'., -" .iJ _"~ ,.,"- l-,- -' " . . "n" "';1:; . . . ;F.;t: "':tiff. . .. . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KERRI FORRESTER No. 00-918 Plnintiff VERSUS MTCHART. R F'nRRR~rpKR Dp.fpnr1nnt AND DECREE IN DIVORCE NOW'~ 3 ~ -t ~: 'l,..{ · ~O , IT IS ORDERED AND DECREED THAT KERRI FORRESTER , PLAINTIFF, AND MICHAEL E. FORRESTER , 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; ~ c? .~ · ~ ROTHONOTARY . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . b. t . t7J 6'fr 'OJ r'--!, ,~ ~... , . :~,t ~'~ ;~ , , ' - w. t'9:P /~~ AI- /1~ #lc~ ~ dfI' ~,~ o. _., ,~, ~."., ,-.dIU..., '!l!"'l'1 """,' i-" -,,""wJ81l - _ I ~_ __ " eo" "",-,- "C' " "'-. KERRl FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-918 CIVIL TERM : CIVIL ACTION - LAW MICHAEL E. FORRESTER, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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: Certified mail, restricted Delivery, return receipt request. Original Service of the Section 3301 (c) divorce complaint signed for by the defendant on February 17, 2000. Affidavit of Service was filed on August 17,2000. 3. Date of execution of plaintiffs affidavit required by 93301 (d) of the Divorce code: April 8, 2003. Date of filing and service of the plaintiffs affidavit upon the defendant: April 8, 2003. 4. Related claims pending: None Date: ~. '. ~,,- . .<! <C~';, ,'; __,', ."" '< ,. . 5. Date and manner of service of the notice of intention to file praecipe a copy of which is attached: United States Postal Service First class mail, on April 18, 2003. S/'Z--:?-/ ()3 . ~ ~~ Michael Parker Certified Legal Intern /tJ~ S THOMA . PLACE Supervising Attorney LUCY JOHNSTON-WALSH Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 !" . ,>,'--- KERRI FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE MICHAEL E. FORRESTER, Defendant :NO. 00-918 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Parker, hereby certify that I served a Praecipe to Transmit the Record and Vital Statistics form on Michael E. Forrester on S-/z.z./ tJ 3 , by first class United States mail, at the following address: . . Michael Forrester 11 Adams Street Eno1a, P A 17025 Date: .5/Z.2/~3 . ~~ Michael Parker Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17103 (717) 243-2968 Fax: (717) 243-3639 .' ..'~ ",',,~ ~ -" " "~ -, ". -'" . ,,";~- .;... k~ ., , '.:.< '" , ~";"~; I 8 0 ~ (.j s: :::c '-J "t.>n, "'" "T" !pm -< ffi.:n :::t:' r- 2C. f'o..> ""1""11 en",. l'v ciA ~~ Q ~c' -0 :-;1~1 ~8 :::c '5-'" so c - ::srn :?::: --< --l ,~ >' -< \0 ::0 -< '-~- . ,-- . , "-0>'-> +'ri'" ,--..'.,. '<_- .. -';, ",--,,--, ~~;; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERR! A. FORRESTER, Plaintiff : No. .:;):::oO-q I ~ Civil Term v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE BEEN SUED 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 rights 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, Cwnberland County Courthouse, 1 Courthouse Square, Carlisle, Peunsylvania. 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 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. Cwnberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 . ~;. -1'- _, k_-. . ",--' .." ,- "':'.'~' -- :0'-' ''"Ak!J Le han 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 notificacion. U sted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier que ja 0 alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO 0 PROPIENDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UN ABOGADO, VA Y AEN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO 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. 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, P A 17013 (717) 249-3166 ~ ,-'I " -," ' ~ ~~ -,; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW KERR! A. FORRESTER, Plaintiff : No. 2000- 9/8 Cu.,cJtR,1'I v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE COUNT I COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE Am> NOW comes KERRI A. FORRESTER, by and through her attorney, Maryann Murphy, Esquire of Legal Services, Inc., who respectfully avers as follows: 1. Plaintiff is KERRI A. FORRESTER whose current address is 17 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL E. FORRESTER whose current address is 11 Adams Street, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. plaintiff and Defendant were married on March 16, 1997 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. " ';. "-, -~~ 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. Plaintiff and Defendant are the owners of bank accounts and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 13. Plaintiff requests this Court to equitably distribute the parties' marital property. COUNT III CLAIM FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE 14. Plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 15. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 16. Defendant does have a sufficient source of income to aid Plaintiff in supporting herself during the pendency of this action. 17. Plaintiff requests this Court to grant her alimony pendente lite during the pendency of this action. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equi tably distributing all property owned by the parties hereto; and c. directing the Defendant to pay alimony pendente lite during the pendency of this action; and ". ;-~..,,' -- d. for such further relief as the Court may determine to be equitable and just. Respectfully submitted, Maryann Murphy, LEGAL SERVICES, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for plaintiff , c. - .., ^.,~~'.t',"- AFFIDAVIT I, KERRI A. FORRESTER, verify that the statements made in the foregoing Complaint in Divorce 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. r9-/{P-~ Date '," r":'; _rIo,,' -':j I I i , ' '-, -~ -" - ,,", ,',.-- 2;:~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW KERR! A. FORRESTER, Plaintiff : No. v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Divorce Complaint was mailed to the Defendant, MICHAEL E. FORRESTER, by first class U.S. mail, postage pre-paid, certified/restricted delivery, addressed as follows: Michael E. Forrester 11 Adams Street Enola, PA 17025 Respectfully submitted, Murphy, LEGAL SERVICES, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for plaintiff .' , l,~ iiiilllI " "'''''"'-' ~'.'" .....~~~~ ' ~iJ < ~ -' .' .", , ~"""-'I+I~,=~' '~.i!lli1l'~uJ'fll . ",","""".., .""".,. - " ,,,. --C1 ~~[ f:: ..> "--y '... ~' -=--"~\-:-J ~1> "n-_ , -<, ~, '?- fJ (:) c-...:; -" 1"1 ,'--:;~J c' -'!J ON s,- '! I I () --'=1'1 u'-I ~~~~ ..,1-:'1 ';::J (~) ~, -':;2~S (;~:: i'Tl ::::~ ::;:1 -< , , 'j -. ..', , ."., , '." ' ,_c ~, "' 'i I " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW KERR! A. FORRESTER, Plaintiff : NO. .:2000- ql'? (I.. ('\ \,6A ~-'-'\IY\ v. : IN DIVORCE MICHAEL E. FORRESTER, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, KERR! A. FORRESTER, Plaintiff, to proceed in forma oauoeris. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma oauoeris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Marya Murphy, Esq Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff ,,- _c', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERR! A. FORRESTER, Plaintiff v. : NO. Qt:D.)- q l'8 Cu.cJ? le~iY\ : IN DIVORCE MICHAEL E. FORRESTER, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am KERRI A. FORRESTER, Plaintiff 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. (a) Name: KERR! A. FORRESTER Address: 17 Regencv Woods North. Carlisle. PA 17013 (b) Social Security Number: 560-35-1456 If you are presently employed, state Employer: Servicemaster of Greater Harrisburg Address: 5913 Linglestown Rd. Harrisburg. PA Salary or wages per month: $ 651.00 Type of work: office cleaner If you are presently unemployed, state N/A Date oflast employment: N/A Salary or wages per month: N/ A Type of work: N/A (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support NONE (Wife)(Husband) Name: N/A the parties are separated If your (husband) (wife) is employed, state Employer: N/A ",-,,,," ,. ,or'"~ - '-~ ,^,'. Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $1.00 Checking Account: -0- Savings Account: -0- Certificates of Deposit: -O- Real Estate (including home): -0- Motor vehicle: Make Mazda 323 Cost $500.00 -0- -0- Year 1987 Amount owed Stocks; bonds: Other: (f) Debts and obligations Mortgage: -0- Rent: $437.50 Loans: $175.00 Monthly Expenses: $1.000.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A ,,-~ ~'^ '0"", '-~-, -",- 'I , , Children, if any: N/A 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. Date:Ql-((f -(J/) ~~ ~ A. ~ RRESTER . -~i! n, ,~ ~ I.;,. " ;..,.." c." "'~:,~"- ... ,"" ~,. '"... < "-,,,- "-"''''''. . :':"^, -,:,(); ~\y (iJ " _z: .._._, CC-' ~ er\ o C I~~~\ ""f'\ ~'~'1 'c'::J - cr, -:-; ':;;:~.'{~:" "-~--' c.: .. ~ ~:;\ -<. t ? . ...) (51 ~ -".' , '" , ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERR! A. FORRESTER, Plaintiff : No. 2000-918 Civil Term v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: I. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on February 16, 2000, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number Z 338 891 171, a 3301(c) Complaint in Divorce to the Defendant, MICHAEL E. FORRESTER, at the following address: Michael E. Forrester II Adams Street Enola, PA 17025 3. That on February 17, 2000, the Defendant was served with the Complaint in Divorce as evidenced by his signature on the green card, number Z 338891 171, which is attached hereto. ~",,~~/L Maryann urphy, EsqUIre ~ 0 LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 ~"" _~",L"'''''-.~ ~~\\ .. ..., . ~~~"~ bl ... , 0 co c- .-, c: C;::) ~'\' 1 S-.. J> ""'00:;- C ~J f'llrTl ,:;") Z~T - ,"n LC: , 1 ,~,_, (fJ, r:':;:,: , ; --... "" ~: -.;~r~ f.2C; -0 'b.C -<::.~ '~--.:3 (~; Z .. :;;Q . , ~3t .. c_. '1: Z ::::> ).':>-~ -j :n -< (.J -< Ilr (10. SEN:DER: .... -3 . Complete items 1 andlor2 for additional services. 'j;; . Complete 119ms 3, 4a, and 4b. . . CD . Prinly?ur name and address on the reve~~:tftte~ ~is ~ card to you. n K;. I t;. II ~ . Attac~ this forlTJ to the front of the mail piece, or on e se ~s ace does not ; . ~r~'t;;Retum Receipt Requested" on the mai,nt:J..:I' e,D.Ver. . .c . The Return Receipt will show to whom the art~'&il'e d~rlIe ... delivered. " o " ~ Q. E o u 3. Article Addressed to: Hi cJl(ld t I' I A rJ, (JJY/3 E'no fa: ~ f+ p:cJlr-es"~u- SJi-t-ee+ 1'1&;;'0 5. Received By: (Print Name) /VI L. & C ~- tJl/..c;S?l?x. ~ 6.s~/il~rtn~ .!! PS Form 3811, December 1994 I also wish to receive the following services'(for an extra Jee): . 1.0 Addre dress Restricted Delivery Consult pas ma 4a. Article Number Z '?log gq/ 4b. Service Type D Registered o Express Mail o Return Receipt for Merchandise Z at of iv <Ii u <: 15. 'ij u " II: " ~ " ~ertified ~ D Insured ~ o COD .~ ~ .e /'1/ 8. Addres ee's A dress (Only if requested and fee is paid) " g, '" " .. .s:: I- 102595-98-8-0229 Domestic Return Receipt " , -. "- ., I ,,t r ~ Kerri A. Forrester, : IN THE COURT OF COMMON PLEAS OF Plaintiff vs. : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000-918 CIVIL TERM Michael E. Forrester, Defendant : 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 93301 (d) OF THE DIVORCE CODE 1. The parties to this action separated bn November 21, 1999, and continued to live separate and apart for a period of two years. 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 if! do not claim them before a Divorce is granted. I, Kerri Forrester, 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 made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. 3-ao-Q;t Date ..~~ . A. Forrester, P intiff i~.~;;.~"....I:,.: .;;. ~ ". " "~. c....',"'. ) ~~ "" ^:.~" "b;;' , ""c.,' "',',.'V.,','. ,." ., r tP g c:> () 1'-' -1"1 :g: "'" .,,{ ~5:J ''0 :::~; :1J rn AI ' 'r-- ~;'[) \ ~'CJ-t.:q WS-; w :;;:r'y ::.(4'_._ ":.',0 r::CJ ...--rl ." ,.}-::D '< ..". s20 3Eg -- ;"::~m 5>'c: r:'i' S ~ J? - :Q. , . ..,. """","" "[! If Ii ;! Ii I: - """'-" ..'~ , IN THE' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERR! A. FORRESTER, : Plaintiff : No. 2000-918 Civil Term v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE . . AFFIDAVIT nL~ CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 16, 2000. 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 ofa final decree of divorce after service of notice of intention to request entry of the decree. 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. Co -123 ~tf1j Date ~~liMiA1 - !p.ai..il i l&.ll'- ~,'~~ilUI\1\;..:j4.!l ~}l ~ii.._ . , .. ~. , (') 0 ~ C 0 s:: L :::1 "U.o:. c= ~-:'l,-':: n1m ;;;e Z:X:l N g~ 65~ \0 ~cs 3> ~ -::-'---:IJ 8 ::u: ~~(-) ~---m >c: I.f? 0 '" z .&;- ~ ~ .::- '_\\ ~ .' L ,'," IN THE' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff : No. 2000-918 Civil Term v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE W AlVEROF NOTICE OF INTENTION TO. REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l(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, 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. 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. I il.... c2?; -tJZ) Date .""_-"~'.L.~ ~ ~~ ~!i:~M!iil&t\H!tl:!~ ' ' , "., '";'d'~J. -''-"''1IlM; ""."',, ...'.", Lilti!J~llr .~ ~",",,""".' ." ._.,~". 'j !I ii' I: Ii \1 ! (") 0 ~ C 0 s;: c... .-4 '"Om c .r ;1~:n mrn z , 'r" Z:u N -.!,,1'n ZC' -p.o (f).P' \.D t:=) 1 ~;2j .....J(.) ~C..- "'" =1;:; ~O :x \...; ("") )5:0 'P. Orn ~ ~ ~ ~ :- -< f ,< .. Kerri A. Forrester, : IN THE COURT OF COMMDN PLEAS OF Plaintiff vs. : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000-918 CIVIL TERM Michael E. Forrester, Defendant : Divorce () 2 c: s: :DO ;:R CD -0 NOTICE TO DEFENDANT zgj ::>:11 zr-- (I);P W ~o .." If you wish to deny any of the statements set forth in this affidavit, you i@ fil~ counter affidavit within twenty days after this affidavit has been served on you 6Tlie - statements will be adrrJ.tted. ~ ;.::; PLAINTIFF'S AFFIDAVIT UNDER 93301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on November 21, 1999, and continued to live separate and apart for a period of two years. 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 in do not claim them before a Divorce is granted. I, Kerri Forrester, 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 made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. 3-c?<()-m Date " . , " /,q /;/[/.~--Z~~ . A. Fom',",,~ ".~.,.< o -n --; ~." "p '.Olll -00 ,._, L ',...1 e) :;~i-Tj ~~.:!1 l...,.,Fi"'j 2m o s;! ::0 -< ~~ . , -, -~ "I , SHERIFF'S RETURN - NOT FOUND ~, CASE NO: 2000-00918 P CO~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORRESTER KERRI A VS FORRESTER MICHAEL E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT FORRESTER MICHAEL E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - DIVORCE , NOT FOUND , as to the within named DEFENDANT , FORRESTER MICHAEL E MICHAEL'S FATHER LIVES AT ADDRESS GIVEN. MICHAEL HAS NEVER LIVED THERE AND FATHER HAS NOT HEARD FROM HIM IN 8 MONTHS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 19.32 5.00 10.00 .00 52.32 ~ .., : Thoma: in Sheriff of Cumberland County LEGAL .SERVICES 05/13/2002 Sworn and subscribed to before me this / j-<b day of~ ;ll7-p,2. A.D. ~C'~~ Pro honotary . "' ~ > '= -. , , Kerri A. Forrester, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL V ANJA Michael E, Forrester, Defendant 000 C N .1 -o.~ ~ --{ ~gj ~ i"11~ ZC I =-.._"b," ~:i:' c....1 - ~'C] ~ ~9 z0 J;.. ~C) )>8 N om Z .... ~ NOTICE OF INTENTION TO REOUEST ENTRY OF &3301(d) DIVORCE ffuciiE ?it v. : NO. 2000-918 : CML ACTION - LAW : IN DIVORCE You have been sned in an action for divorce. Yon have failed to answer the complaint or me a counter-affidavit to the ~3301(d) affidavit. Therefore, on or after the 24th day of April, 2002, the other party can request the court to enter a final decree in divorce. If you do not rue with the prothonotary ofthe court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a fmal decree in divorce. A counter-affidavit, which you may me with the prothonotary of the court, is attached to this notice. Unless you have already rued 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 TELEPOHNE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LmERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 OR 1-800-990-9108 TRUE COPY FROM RECORD r. Tll8tlmony wllef80f. I hef-llunto set my hand Md till seal of said ~ it! carlisle.. PI. ~~ ~ e ~- '-- . I"1.oLD ~~r;: lIG\ary ~- , ~~, " " Kern A. Forrester, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO, 2000-918 Michael E. Forrester, Defendant : CIVIL ACTION - LAW : IN DNORCE COUNTER-AFFIDA VIr UNDER &330l( d) OF THE DIVORCE CODE 1. Check either ( a) or (b) o (a) I do not oppose the entry of a divorce decree. o (b) I oppose the entry of a divorce decree because (check all that apply): o (i) The parties to this action have not lived separate and apart for A period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (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. o (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. IfI 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. p-- - . . I verifY that the statements made in the counter-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: Michael E. Forrester NOTICE: IF YOU DO NOT "'lSH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE TillS COUNTER-AFFIDAVIT. ~ ~<::0 . '. , .,. ,- .,.J " TIlH erL" '-~' r'H:'..::i ![,;_..." :"'t" ,. _"' "<iT, ;rTY ,. ~J J'IDR "'. MI.. ,.:'~ 'I ,- -' - <,.~~.~~'~,. - o ~ _'~"""l~J$lIh~ l"'lrrntlJlII!IIl"lil' -'- ,- IN THE .COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW Kerri Forrester, Plaintiff : No.00-918 Civil Term v. Michael E. Forrest..er, Uelenuant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE BEEN SUED 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 rights 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, 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 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 ,','"=' '" ",-" " , - ',' .....~ Kerr! A. Forrester, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-918 CIVIL TERM Michael E. Forrester, Defendant : Divorce Amended Comulaint to a &3301(d) Divorce AND NOW comes Kerri A. Forrester, by and through her attorney, Joan Carey, of MidPenn Legal Services, who respectfully avers as follows: 1. Plaintiff is Kerri A. Forrester whose current address is at an undisclosed location. 2. Defendant is Michael E. Forrester whose current address is believed to be 42 W. Allen Street, Mechanicsburg, Pennsylvania. 3. Plaintiff and Defendant were bona fide residents in the Commonwealth for at least six months prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on March 16, 1997, in Cumberland County, Pennsylvania. 5. The parties to this action separated on November 21,1999, and continued to live separate and apart for a period of two years. 6. On February 16,2000, a Complaint for Divorce under 3301( c) was filed in the Cumberland County Courthouse. See attached exhibit A. 7. On February 17,2000 the Defendant was served with the Complaint in Divorce as evidenced by his signature on the green card, number Z 338 891 171. See attached exhibit B. 8. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests that the Complaint for divorce under !j3301(c) filed on February 16,2000, be amended to a !j3301(d )divorce and that a Divorce Decree be entered. an Carey, Attorney Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 ',,0. -; ~ '>. VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating till unsworn falsification to authorities. Dated: 3-X-Od- .. .. ' '. ' " .'~ , ! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW KERRI A. FORRESTER, Plaintiff ~ No. dOCO- q /'6 Civil Term v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE .. NOTICE TO DEFEND AND CLAIM RIGHTS , , I ! i ~ 1 !I I I II II " I! 'Ii , I' " II :1 II !I I 'i 'I II I I " I YOU HA VE BEEN SUED 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 rights 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, DIVISION 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) 249-316E I A TRUE COpy FROM RECORD ~n '.s:;l~rn~Jln~' ~::lt~H..!~r~~l ~ r~~re W1W sst my hano t:md the S6al at 5ak~. Ga~rt a~ CarHsJe, Pa. Th!:; I'~+w day 1lI_ E'eh ,. :;Jcx::x) ~ ll!.1l::<m~1LC1n/ ~'1 PtottlOI1il'lary EXHIBIT '~.' - "L,_ Le han 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 Ia fecha de la demanda y la notificacion. U sted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier que ja 0 alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO 0 PROPIENDADES 0 OTROS DERECHOS IMPDRTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UN ABOGADO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 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. 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, P A 17013 (717) 249-3166 ~ -~, - " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA CIVIL AOTION- LAW KERR! A. FORRESTER, Plaintiff v. : No. ;Jr:::J.:Y.:)- q I 'if ~ \0\ (Y\ MICHAEL E. FORRESTER, Defendant : IN DIVORCE COUNT I COMPLAINT UNDER SECTION 330I(c) OF THE DIVORCE CODE AND NOW comes KERRI A. FORRESTER, by and through her attorney, Maryann Murphy, Esquire of Legal Services, Inc., who respectfully avers as follows: 1. Plaintiff is KERRI A. FORRESTER whose current address is 17 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Defendant. is MICHAEL E. FORRESTER whose current address is 11 Adams Street, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 16, 1997 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. "'I '-""', 6 . Defendant is not a member of the Armed' Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II CLAIM FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. Plaintiff and Defendant are the owners of bank accounts and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. ..~ . <~ "" ~ '"-,-,, ~--" -. ~., I 'I 1 13. Plaintiff requests this Court to equitably distribute the parties' marital property. COUNT III CLAIM FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE 14. Plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 15. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 16. Defendant does have a sufficient source of income to aid Plaintiff in supporting herself during the pendency of this action. 17. Plaintiff requests this Court to grant her alimony pendente lite during the pendency of this action. WHEREFORE, plaintiff requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equi tably distributing all property owned by the parties hereto; and c. directing the Defendant to pay alimony pendente lite during the pendency of this action; and :'<' d. for such further relief as the Court may determine to be equitable and just. Respectfully submitted, Llt1,LClA/ ,(1(:( l~LU IL;/llc[..-- MaryannVMurphy, Esquill'e1 LEGAL SERVICES, INC. , 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff ~ ' ,I', AFFIDAVI.T I, KERRI A. FORRESTER, verify that the statements made in the foregoing Complaint in Divorce 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-/{P-C8 Date = ~~~ ~ , ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERR! A. FORRESTER, Plaintiff : No. 2000-918 Civil Term v, MICHAEL E. FORRESTER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: (') 0 c a '-' --.$: --n 1.....,...,-' "" nl'''"~ .~ 2[.;" c-; :Z:r:-': ClJ";> -.; ;::;~::: ~c' ",,"=," '};;;------. '.i 7Lj ~-'- ;;:'0 -..... . , c: ~;' 2: 5: =<' :::> (N ::D -< 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on February 16, 2000, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number Z 338 891 171, a 3301(c) Complaint in Divorce to the Defendant, MICHAEL E. FORRESTER, at the following address: Michael E. Forrester 11 Adams Street Enola, P A 17025 3. That on February 17, 2000, the Defendant was served with the Complaint in ~ SENDER: 2 . Comple1e items 1 and/or 2 for additional services. In _ Complete items 3, 4a, and 4b. . . ~ . ~~: lo~~~ame and address on the reve{t!iSlftt6' EelS ~ . Att~ this 10TlTl10 the front of the mailplece, or on the back if s ee does not ~ .e.;~'t;Ae,umAeCeiPtAeqU&sled"onthemal\~l I Yer. !:! . The Return Receipt will show to whom the arti~Jft 8mi e d 1:.ie : deli\leretl. ; 3. Article Addressed to: , , ; ~ j . Hi d1 cu:d t. p:6rr-es.~e..r- 1\ Acl~3 Skt-ee+ EnOla) ~ft 1"10;2,Q I also wish to receive the following services (for an extra fee): 1. 0 Add,e ddress Restricted Delivery Consult pas ma 4a. Article Number 2 338- g91 i'1/ 4b, Service Type o Registered o Express Mall o Retum Receipt for Merchandise Z at of liv ..a:certlfied o Insured OeOD 5. Received By: (Print Name) . lJ'r C e (. 6. tJl../J~ 5?e~ 6. sin/IJ-1:tdJrtn~~ PS Form 3811, December 1994 102595-98.S-0229 Domestic Return Receipt i 3 8 891 171, which is attached oj '. "/ ~~.(!~.~ .~re \. () II ' II: ~. c 5 ~ ~ 0:: '" c -. , 5 ~ , o >. '" " ~ EXHIBIT IB dillltlW.': j <"~ - ~" ~ ~ 0"' (yg ~ -!miIM\l~1ij '"'~ir' , ., ~~ "~;" .- " " (') c ~ "01;:t:, mrn Z-q ZC ro.,:.'''' ~;2' r-o ~O 20 ::J>C -T ~ o f'v X>- -0 ;;r;J I W -0 :x 1;;'> <':) ~1:1 .-j .,. il~l :n ~~ :T:-;i ~]o Om -oj ?o -< - -,;.,. -, , ., . Kerri Forrester, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-918 CIVIL TERM Michael E. Forrester, Defendant : In Divorce PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Kern Forrester, to proceed in forma pauperis. I, Joan Carev, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the p Olin Carey Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 ~~ ~ "'-,'~'" ,~. ~, ~~ ,>\,'.;'.~ f' ~ o ~; _,,",~L: ,~ '. J., qJL:: :f.;: SJ r:: ~~ ~, S~~ -) -, ~ - ~ (:;:) \""0 ~ w., c\ o -n -':~'l ilF -.~, rTl -;-;0 ~Z~~ i~:JJ '..0 ()nl "" :0 -< ;'i i';-? U1 (::J ~"'~ -,',.__.c "<",)1 KERR! FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-918 CIVIL TERM : CIVIL ACTION - LAW MICHAEL E. FORRESTER, Defendant : IN DIVORCE PRAECIPE TO WITHDRAW AND ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of the Mid Penn Legal Services as the attorney for Plaintiff, Kerri Forrester, in the above captioned complaint. Please enter the appearance of the Family Law Clinic on behalf of the Plaintiff, Kerri Forrester, in the above-captioned complaint. ~L Michael Parker Certified Legal Intern Dated: 3/7/03 ~~"uJM T OMA .... ACE . ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 Date: -3/3/03 , ( ~~~~ Mid Penn Legal Services 8 Irvine Row Carlisle, P A 17013 _.,~ -: ". I "~.' ~~'" ;, ""~"""' "-' ..~ "I" r",~" ,,_~, - .,' ",.',;., , ,.. "... ., I I I 0 0 0 c. ,.hi "T1 :S~. ::;::: -=.:=1 -,)0_" :C'" ';~.l "f"'d [1"1\'"\'\ Co::> :z: ::::.~ I -'~') ;-q -;;7'1-- ."}'...--} ~? -, '~~1~ tee -0 ::~2 -" ~~..~. 3: 0 :r;~_ ~ 6fT1 -\ --,,'.- r::" ~ :2 -' '< (f:; , () I.' f)Nf ; . IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Kerri Forrester, Plaintiff : No. 00-918 Civil Term <;) ~ ~- -po ~("1;", -0 ffli'i\ -;0 ~~.2 ! <.7)~ c...) ~5 -:? ~o ..."'i.. 2'0 N 5c ., ~ -< I.'" o -4 ~-..!: B;pJ -o~ ..-0 C~(-) ~~-t1 bf'1 -"\ -~ ::0 -< v. Michael E. Forr~tjlrd !Jelen ant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED 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 rights 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, DIVISION 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 ALA WYER 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, P A 17013 (717) 249-3166 . A ", '", -~-' q' . Kerri A. Forrester, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-918 CIVIL TERM Plaintiff vs. Michael E. Forrester, Defendant : Divorce Amended ComDlaint to a &3301(d) Divorce AND NOW comes Kerri A. Forrester, by and through her attorney, Joan Carey, of MidPenn Legal Services, who respectfully avers as follows: 1. Plaintiff is Kerri A. Forrester whose current address is at an undisclosed location. 2. Defendant is Michael E. Forrester whose current address is believed to be 42 W. Allen Street, Mechanicsburg, Pennsylvania. 3. Plaintiff and Defendant were bona fide residents in the Commonwealth for at least six months prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on March 16, 1997, in Cumberland County, Pennsylvania. 5. The parties to this action separated on November 21, 1999, and continued to live separate and apart for a period of two years. 6. On February 16,2000, a Complaint for Divorce under 3301( c) was filed in the Cumberland County Courthouse. See attached exhibit A. 7. On February 17,2000 the Defendant was served with the Complaint in Divorce as evidenced by his signature on the green card, number Z 338 891 171, See attached exhibit B. 8. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests that the Complaint for divorce nnder g3301(c) filed on February 16,2000, be amended to a g3301(d )divorce and that a Divorce Decree be entered. Respectfully submitted, Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 ~ ~- . ,', ,. . ~; . VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: 3 ~I;()"-()~ .,--....... .-.., < ' " .,---,,;;. TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff : No. QOCD- QI'6 Civil Term v. MICHAEL E. FORRESTER, Defendant : IN DIVORCE . NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED 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 rights 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, DIVISION 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 TillS 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 CAfR GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 TRUE CO?'" FFiOM REGORD J A i~ TiJ$thn~~~~. ~J<lh;l!~rf8ff, ! f~t~re tiflm $-jt mv r-,ana imd t~e ~~,,2d m t~4i~(i. Gnurl ~I' GarHs.!e t Pa. 11;1-<; f0?-IM (lay iJLLeb '.\ ;;lC:CX::' l Llv~~ l),l~n'L! Ol~)' -/ -If,rft; ~ -., , ',~ j" ~otl.ltll1(';,rdry EXHIBIT .. ~ .^' r. Le han demandado a usted a la corte. Si usted qui ere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de Ia fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entraruna orden contra usted sin previo aviso 0 notificacion y por cualquier que ja 0 alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO 0 PROPIENDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO T1ENE 0 CONOCES UN ABOGADO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO 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. 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, P A 17013 (717) 249-3166 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION- LAW KERR! A. FORRESTER, Plaintiff v. : No. .;)ocx.-"'-q ('if c.1..~\-Qf\(Y\ MICHAEL E. FORRESTER, Defendant : IN DIVORCE COUNT I COMPLAINT UNDER SECTION 330H c) OF THE DIVORCE CODE AND NOW comes KERRI A. FORRESTER, by and through her attorney, Maryann Murphy, Esquire of Legal Services, Inc.. who respectfully avers as follows: 1. plaintiff is KERRI A. FORRESTER whose current address is 17 Regency Woods North, Carlisle, Cumberland County. Pennsylvania. 2. Defendant is MICHAEL E. FORRESTER whose current address is 11 Adams Street, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 16, 1997 in Cumberland county, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. - .... 0< 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. plaintiff and Defendant are the owners of bank accounts and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. - L" ~ l3. Plaintiff requests this Court to equitably distribute the parties' marital property. COUNT III CLAIM FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE 14. plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 15. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 16. Defendant does have a sufficient source of income to aid plaintiff in supporting herself during the pendency of this action. 17. Plaintiff requests this Court .to grant her alimony pendente lite during the pendency of this action. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equitably distributing all property owned by the parties hereto; and c. directing the Defendant to pay alimony pendente lite during the pendency of this action; and - " '; ,,-,-,"'01' ,. ': d. for such further relief as the Court may determine to be equitable and just. Respectfully submitted, L/lttC0..J {CltrC lA~(! I c)2l CL...- MaryannVMurphy, Esqui;e{ LEGAL SERVICES, INC. , 8 Irvine Row Carlisle, PA 17013 {717} 243-9400 I.D. # 61900 Attorney for Plaintiff .'->=,- ~I I I AFFIDAVIT !, KERRI A. FORRESTER, verify that the statements made in the foregoing Complaint in Divorce 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. i;;2-/(Y-w Date , rRRI ~~ IlIlIlIiirlIIilJ , . , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff : No. 2000-918 Civil Term v. MICHAEL E. FORRESTER, : IN DIVORCE Defendant AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: (') G: _.s;: vr-;--, gJ'lfi 7-~. ~r S:? ic ~C) -,. z~ ;c.ci c 2: -' -< c c :e: C3 '::h -J 0..--=.- gA s! ::.w -< ~ :::> (~, 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on February 16,2000, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number Z 338 891 171, a 3301(c) Complaint in Divorce to the Defendant, MICHAEL E. FORRESTER, at the following address: Michael E. Forrester 11 Adams Street Eno1a, PA 17025 3. That on February 17,2000, the Defendant was served with the Complaint in SENDER: . Complete items 1 and/or 2 for additIonal services. . C~mple!e Items S, 4a, Bnd 4b. ~S1'Rte. ~fD . Print your name and address on the reve cUn is c.ardto"you. I II Auach this 10ITt) to 'ihe front of the mallpiece, or on lhe back~. ace does not perm;!. ~i'd iB~ III Write -Return Receipt Requested" on the mall i EIb I ar. III The Relum Receipt w/IJ show to whom the art! erml e d te delivereti. 3. Article Addressed to: HI t.M (Ie-I ~. r-:or-r-es.~u- I ~ A d. r:-m3 SJl.-t--e e+ Enola) I{;/t J'if),},':J I also wish to receive the following services (for an extra fee): 1. 0 Addre ddress Restricted Delivery Consult pas m ;AtI3gmb~q J '/7/ 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise Z at of liv ..a:certlfied o insured o COD 5. Received By: (Print Name) 8. Addressee's A dress (Only if requested /file. e c 6- ;eJ1..I!-(;S?€.d and fee is paid) 6. Signat;J~ bAdcyess.e~"fr~.en~ . ~~ .vr. x /'Lu:;/~ t, -r/tYV&~ '5 Form 3811, December 1994 102595.9'.6.0229 Domestic Return Receipt 08 891 171, which is attached .; " "I ~ #;).. ~D. UJ ..( , 0. : I Q) re \. / il " a: ~. I: - ::I ;; a: '" I: u; ::I - o ~ " & '" 1:, m '" ... I EXHIBIT B ~ ~ <<JP w ~ (fE;; l!:!bJJ @'2) ...~ , ~ , m""""~",..,, - . ". -' ","'~ , . OFt::(;c ~.;" jH~': '~iHErHFF I,;!,~:;:\" "J (~,/r.I!1TY L,PR 3D J". l,1 (": t~ i'; : , . 1,.', ll!l ~. '--""_ ,."">/'wm~Itffl'~_., .... lI1ll1lL.~~ ~.~~.~!mI .@~~ -~~ -~- . ~! .. . Kerri A. Forrester, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-918 Michael E. Forrester, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF &3301(d) DIVORCE DECREE 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 the 24th day of April, 2002, 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 signalture notarized or verified or a counter-affidavit by the above date, the court can enter a fmal 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 TELEPOHNE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LmERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 OR 1-800-990-9108 -.'i ~ , Kerri A. Forrester, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-918 Michael E. Forrester, Defendant : CIVIL ACTION - LAW : IN DIVORCE COUNTER-AFFIDAVIT UNDER !!3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b) D (a) I do not oppose the entry of a divorce decree. D (b) I oppose the entry of a divorce decree because (check all that apply): D (i) The parties to this action have not lived separate and apart for A period of at least two years. D (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): D (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 if! do not claim them before a divorce is granted. D (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!ntention 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 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: Michael E. Forrester 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. il;l. IidMiII"'- , , Q)~ c'"' .~...... ,- . -~ : ,.,;",'. ,,.; ~. ~',- ""-"-' 'i~,~o~'"';"''' II... ., .~","' ., ..;,."" , 'Ii I I .. o .J "- ,> - ~' ,,<C.",, "-_',",~, ; .> '" 4.--, "'" KERR! FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-918 CIVIL TERM : CIVIL ACTION - LAW MICHAEL E. FORRESTER, Defendant : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 3'd day of June, 2003, hereby elects to retake and hereafter use her previous name of Kerri Peters, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. ~704. ! ~._-.. Wishes to be known as: jt:..NS"-d COMMONWEALTH OF PHJ}!8YL V!.l'ILA. d-r'f COUNTY OF ClH,IDERLAJ>ID On the I R- . day of Sdt ' 2003, before me, a Notary Public, Kerri Forrester, known to me to be the person hose name IS subscnbed to the WIthin document, acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. N~~O~ ~RECEIVED JUl 2 9 2003 ~ ,-'" .., f\~ '- .t: o ~ " '" ~ ~ \ (') c: $.: ;:Qm LAJ [:0 ...-. " ze ~-<.:,~ ~t'] S:c ~fi .~ ~ ~ ~ <::> w L.. c:: r- N ..0 o ." .~ T f"11 ::!J [-~~ ~;2B is'T1 ~ ~ -,1 :::tr: ~:l :n '" w', I h..' 0 ,~ ~~, . "^ . - '~-'v.':.~..' ""i.' '.1' _.,. , ;-, 'i,' )"~_ " "-'"'.:',C'-"'- KERR! FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE MICHAEL E. FORRESTER, Defendant :NO. 00-918 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Parker, hereby certii)' that I served a Counter-Mfidavit and a Notice of Intention to Request Entry of a Divorce Decree on Michael E. Forrester on J..j /18' /0 '2, by first class United States mail, at the following address: ' , Michael Forrester II Adams Street Enola, P A 17025 Date: 1//8/03 I J ~~ Michael Parker ' Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17103 (717) 243-2968 Fax: (717) 243-3639 , " ~.'. .; "I .,"[ .~ .II', .."" ~ ,~ . ,',. ',.< ,. ~ '" ,,- - .~~"." .,,,,,,.,,",,.,...~y,,. ."> '0-,"," "."'..'.""".' (") l:=; 0 C G.) -~, .~. """ "'QC,C: ~r; -',"- r':j i ~~D 2: .. /~ I"," ~, U~ I',. -< ,..-. :,--- -. ~~ )> ." en ,1::- ~~ . ," , ~ , . -'~ -' '~-" "_ ~.'-I _ ..", -' " '~,~:;", '/' '" '.~ -' -- ,.""";;.:;.",,~,,.>.,; -' =,~ , ",',,:,'1 KERRI FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-918 CIVIL TERM : CIVIL ACTION - LAW MICHAEL E. FORRESTER, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Michael Parker, Family Law Clinic, hereby certifY that I am serving a true and correct copy of the Praecipe to Enter Appearance on Michael Forrester II Adams Street Enola, Pennsylvania 17025, by dep,ositing a copy of the same in the United States mail, first class, postage prepaid, this ?/Z-I day of March, 2003. Date: .5/2-/ /03 I ~;U Michael Parker Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 .., ~L,;.i_" -~, 11 iIilliM- ~ ,,"","..ffic.._ .... ." .," .>- ". '.,~" (') r= C") c: . . '~.',~ '-,"1 ~... V ,'.-2 .. rn r- .,.--. :;!: 2' ',"^,) C/) (.;'j ~~ r::: ~'() ~;C ~-_.. {-- )>' .. T:":) ~ ';;-:'1 :.11 ~~:; (J'\ -. . , ~'" , -,,-,. .~,".'. KERRl FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-918 CIVIL TERM : CIVIL ACTION - LAW MICHAEL R FORRESTER, Defendant : IN DIVORCE NOTICE 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 SECTION 3301(d) OF THE DIVORCE CODE L The parties to this action separated on November 21,1999, 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 penalties of 18 Pa.c.S. 9 4904 relating to unsworn falsification to authorities. 3-;l%-G3 Date ~~.- --:PI ntiff .1 ~,;., ,<-"""....'1~""", -'~. -..j"', "~'",.;-' '~. - , '""-,,,,,", ,;~,,~",:'-,";;;I.-' ,'" ,~,.,,, . ..~'- " I' , ,..". ..".,. (') c=, 0 C G~ -1'1 -.. ::''''' :':;.'b -0 G.'! \'] f1'l p', ".~J -. ~S-:_ ';' c:.' .cri -:~: . ~; S;~ ~;:~ ~'" ~Ti ',;';: ("') )>'1 ~O ~:-ir-r; ; :J1 ~ :0 -< (,,) -< . ,~.~ " <-<-' "'~',... _,,_,' _~__, ,"'~, -,f'--~i~( "'_ "'~...P,..,' KERRI FORRESTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-918 CIVIL TERM : CIVIL ACTION - LAW MICHAEL E. FORRESTER, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Michael Parker, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Plaintiffs Affidavit Under Section 3301 (d) of the Divorce Code on Michael Forrester 11 Adams Street Enola, Pennsylvania 17025, ~ depositing a copy of the same in the United States mail, fIrst class, postage prepaid, this <f? day of April, 2003. Date: '1/g'/tl3 , . ~~ Michael Parker CertifIed Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 .'''''_ .:.~.i -,^ ., ~~ ~, ~" ,,'." 'X _ -"",';.0-"", ,,0/ '" _',0 ,,~, ".c.,"".'.' ,,,,.,. "'.'..' , o ,;; ~ -o;~r: rrtrc': "7"-'" zC" Cl) ,;,-, -< ~~ c:=C:-, i:r'. k;"; >r::: "7 ::-'1 -< " "." ,,' C-:J ,- , _.~ o -n ~ "C) _,:,1 T; '-,~I5 ':i],8 .:".~e) .J~.::.n1 ~"...j .-; ,:;; +-'"J :< cc 2:~ \9 :..n (,.0 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff MICHAEL E. FORRESTER, Defendant :No. C.X -q 153 : IN DIVORCE Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS. YOU HA VE BEEN SUED 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 rights 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, DIVISION 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 Le han 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 notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra suya. 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 que ja o alivio que es pedido en la peticion 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. All arrangements must be made at least 72 hours prior to any heating 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff MICHAEL E. FORRESTER, Defendant : IN DIVORCE COUNT I COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW comes KERRI A. FORRESTER, by and through her attorney, Maryann Murphy, Esquire of Legal Services, Inc., who respectfully avers as follows: 1. Plaintiff is KERRI A. FOP, RESTER whose current address is 17 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL E. FORRESTER whose current address is 11 Adams Street, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 16, 1997 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II CLAIM FOR EQUITabLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE COD~ 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. Plaintiff and Defendant are the owners of bank accounts and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 13. Plaintiff requests this Court to equitably distribute the parties' marital property. COUNT III C?~T~ FOR A~IMONY PENDENTE LIT~ UNDER SECTION 3702 OF TWR DIVORCE CODE 14. Plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 15. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 16. Defendant does have a sufficient source of income to aid Plaintiff in supporting herself during the pendency of this action. 17. Plaintiff requests this Court to grant her alimony pendente lite during the pendency of this action. Plaintiff requests this Honorable Court to enter a Decree: so bo c o dissolving the marriage between the Plaintiff and Defendant; and equitably distributing all property owned by the parties hereto; and directing the Defendant to pay alimony pendente lite during the pendency of this action; and do for such further relief as the Court may determine to be equitable and just. Respectfully submitted, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. ~ 61900 Attorney for Plaintiff AFFIDAVIT I, KERRI A. FORRESTER, verify that the statements made in the foregoing Complaint in Divorce 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 RRI A. F/R~ESTER IN THE coURT OF coMMON PLEAS OF cuMBERLAND coUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff MICHAEL E. FoRRESTER, Defendant : : IN DIVORCE CERTIFICATE OF sERVICE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Divorce complaint was mailed to the Defendant, MICHAEL E. FOP. RESTER, by first class U.S. mail, postage pre-paid, certified/restricted delivery, addressed as follows: Michael E. Forrester 11 Adams street Enola, PA 17025 Respectfully submitted, LEGAL SERVICES, INC. $ Irvine Row carlisle, PA 17013 (717) 243-9400 I.D. % 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaimiff Vo MICHAEL E. FORRESTER, Defendant · NO. aO00 · IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, KERRI A. FORRESTER, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. l{ei~tryan~- g, lurphy, Esq~re Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaimiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, : Plaintiff : · NO. ~(~Q.~- C~ {~ V. ; : IN DIVORCE MICHAEL E. FORRESTER, : Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am KERRI A. FORRESTER, Plaintiff 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. (a) Name: Address: KERRI A. FORRESTER 17 Regency Woods North, Carlisle, PA 17013 (b) Social Security Number: If you are presently employed, state Employer: Address: Salary or wages per month: Type of work: office cleaner 560-35-1456 Servicemaster of Greater Harrisburg 5913 Linglestown Rd. Harrisburg, PA $ 651.00 If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: N/A N/A N/A N/A (d) (c) Other income within the past twelve months Business or profession: -O- Other self-employment: -O- Interest: -0- -0- Dividends: Pension and annuities: -O- Social Security benefits: -O- Support payments: -O- Disability payments: -0- Unemployment compensation and supplemental benefits: -O- Workman's compensation: -O- Public Assistance: -O- Other: -0- Other contributions to household support NONE (Wife)(Husband) Name: N/A the parties are separated If your (husband) (wife) is employed, state Employer: N/A (e) Salary or wages per month: N/A Type of work: N/A Comributions from children: -0- Property owned Cash: $1.00 Checking Accoum: -0- Savings Account: -0- Certificates of Deposit: -0- Real Estate (including home): Motor vehicle: Make Mazda 323 -0- Year 1987 Cost $500.00 Stocks; bonds: -0- Other: -0- Amount owed (f) Debts and obligations Mortgage: -0- Rent: $437.50 Loans: $175.00 Monthly Expenses: $1,000.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A Children, if any: N/A 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. IN THE'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ICERRI A. FORRESTER, Plaintiff Ve MICHAEL E. FORRESTER, Defendant : No. 2000-918 Civil Term : IN DIVORCE AI~FIDAVI_T 07 CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 16, 2000. 2. The marriage of Plaintiff and Defendant is in'etrievably broken, and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consem to the entry ora final decree of divorce after service of notice of intention to request entry of the decree. 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 IN TH~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff VJ MICHAEL E. FORRESTER, Defendant : No. 2000-918 : : : IN DIVORCE Civil Term WAIVER OF NOTICE OF INTENT!QN TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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, 3. I understand that I will not be divorced until a divorce decree is emered 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. 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff MICHAEL E. FORRESTER, Defendant No. 2000-918 Civil Term IN DIVORCE AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on February 16, 2000, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number Z 338 891 171, a 3301(c) Complaint in Divorce to the Defendant, MICHAEL E. FORRESTER, at the following address: Michael E. Forrester 11 Adams Street Enola, PA 17025 3. That on February 17, 2000, the Defendant was served with the Complaint in Divorce as evidenced by his signature on the green card, number Z 338 891 171, which is attached hereto. l~lar~ann ~urphy, Esquird LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 ~ also wish to receive the ~_' ~-~C?~ sland/~l~l~.add't'°natsew'ces' ------c~[~',~m~n's f~t~f~e~tces tess ~ · ~:~, 3, 4a, he reve t~ ~' 1. ~ · aFflmyuu, · iece oronu~' ~ te"He[Un~- - owtOwnU'" ~-" mba' - awn ei t w~ll sh [c~e t Iu ~ Hi ~ h ~1 ~ ' ', j~ ~ Registered etum Receipt ~or ~erch~n~ise ~ . ~ ~,~ 3811, o IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND coUNTy, PENNSYLVANIA CIVIL ACTION - LAW Kerri Forrester, : Plaintiff : : No. 00-91 8 V. : : : IN DIVORCE Michael E. Forre~t~r, Defendant : Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS YOUHA VE BEENSUED IN COURT. If you wish to defend against the claims set 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 bc 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 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, DIVISION 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 Kerri A. Forrester, Plaintiff VS. Michael E. Forrester, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-918 CIVIL TERM : : Divorce Amended Complaint to a §3301(d) Divorce AND NOW comes Kerri A. Forrester, by and through her attorney, Joan Carey, of MidPenn Legal Services, who respectfully avers as follows: 1. Plaintiff is Kerri A. Forrester whose current address is at an undisclosed location. 2. Defendant is Michael E. Forrester whose current address is believed to be 42 W. Allen Street, Mechanicsburg, Pennsylvania. 3. Plaintiff and Defendant were bona fide residents in the Commonwealth for at least six months prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on March 16, 1997, in Cumberland County, Pennsylvania. 5. The parties to this action separated on November 21, 1999, and continued to live separate and apart for a period of two years. 6. On February 16, 2000, a Complaint for Divorce under 3301(c) was filed in the Cumberland County Courthouse. See attached exhibit A. 7. On February 17, 2000 the Defendant was served with the Complaint in Divorce as evidenced by his signature on the green card, number Z 338 891 171. See attached exhibit B. 8. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests that the Complaint for divorce under §3301 (c) filed on February 16, 2000, be amended to a §3301 (d)divorce and that a Divorce Decree be entered. t/Joan Carey, Attorney ~/r Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: A. Fo~r~ster-~laintiff rr, IN THE COURT OF COMMON PLEAS OF CUMBERLAND coUNTy, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff MICHAEL E. FORRESTER, Defendant : No. : IN DIVORCE : Civil Term 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 rights 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, DIVISION 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 Le han demandado a usted a la cone. 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 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 objeciones a las demandas en contra suya. 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 que ja o alivio que es pedido en la peticion 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. 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff MICHAEL E. FORRESTER, Defendant :No. O. _C7 t : IN DIVORCE COUNT__._~I COMPLAINT UNDER SECTION 3301(c] OF THE DIVORCE CODE AND NOW comes KERRI A. FORRESTER, by and through her attorney, Maryann Murphy, Esquire of Legal Services, Inc., who respectfully avers as follows: 1. Plaintiff is KERRI A. FORRESTER whose current address is 17 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL E. FORRESTER whose current address is 11 Adams Street, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce annulment between the parties. Plaintiff and Defendant were married on March 16, 1997 in or for Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. Court to enter a Decree in 9. Plaintiff requests this Divorce from the bonds of matrimony. COUN~ II CLAIM F~. UITABLE DISTRIBUTION OF MARITAL PROPERTY ., R SECTION 3502 OF T~E DIVORCE COD., 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. Plaintiff and Defendant are the owners of bank accounts and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 13. Plaintiff requests this Court to equitably distribute the parties, marital property. COUNT Iii CLAIM FOR ALIMONY PENDENTE LITF UNDER SECTION 3702 OF TWR DIVORCE CODF, 14. Plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 15. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 16. Defendant does have a sufficient source of income to aid Plaintiff in supporting herself during the pendency of this action. 17. Plaintiff requests this Court to grant her alimony pendente lite during the pendency of this action. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equitably distributing all property owned by the parties hereto; and c. directing the Defendant to pay alimony pendente lite during the pendency of this action; and do for such further relief as the Court may determine to be equitable and just. Respectfully submitted, 8 Zz~±~e ~o~ Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff AFFIDAVIT I, KERRI A. FORRESTER, verify that the statements made in the foregoing Complaint in Divorce 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 RI A. ~R~ESTER -- IN THI~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KERRI A. FORRESTER, Plaintiff Ve MICHAEL E. FORRESTER, Defendant : No. 2000-918 Civil Term : : IN DIVORCE AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on February 16, 2000, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number Z 338 891 171, a 3301(c) Complaint in Divorce to the Defendant, MICHAEL E. FORRESTER, at the following address: Michael E. Forrester 11 Adams Street Enola, PA 17025 o SENDER: · Complete items 1 and/or 2 for ' · ." pC_o._m.?t, items 3, 4a, and 4b. ,dd,tional sauces. . .m your name and address on the rev ~ to'you, sq~l~l~Q~.,, ~,~,z~ ~ ~,. ~,,,~. · Altach this form to the front of the m ...... I ~ ~-- ~1~/~'[~ T ~,U~jllS permit ,,,,p,~ce, or on the back if space doe~'~no'~ · Write ;Return Receipt Requested" on the mailIer 5~ei. v.ed~By'. (3rint Name) (. PS Form 3811~ December 1994 lO2595-@8-B.o229 Domestic Return Receipt That on February 17, 2000, the Defendant was served with the Complaint in ~ to receive th 438 891 171, which is attached fol!ow!ng, services (for ane extra ~ee): , ..~.~Addressee'fl ~Ldress ~m~er ~'~ re .~ ~./ 4b, Se~ice Type Registered ~e~ified Express Mail ~ Insur~ Return Re~ipt for Merchanaise ~ COD ~ (~mY tr requested Kerri A. Forrester, · Plaintiff · Michael E. Forrester, ' Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-918 CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE DECREE 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 the 24th day of April, 2002, 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 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 TELEPOHNE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR 1-800-990-9108 Kerri A. Forrester, · Plaintiff · Michael E. Forrester, · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-918 CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER §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 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 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 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 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: Michael E. Forrester 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. Kerr A. Forrester, Michael E. Forrester, Plaintiff VS. Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2000-918 CIVIL TERM : : 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 1. The parties to this action separated bn November 21, 1999, and continued to live separate and apart for a period of two years. 2. The marriage is irretrievably broken. o 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, Kerr Forrester, 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 made herein are subject to the penalties for unswom falsification to authorities as provided in 18 P.S. Section 4904. Date 'K~ri A. Forr~st~r, ¢intiff Kerri Forrester, Vo Michael E. Forrester, Plaintiff Defendant · NO. 00-918 · In Divorce IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Kerfi Forrester, to proceed in forma pauperis. I, Joan Carey, attomey for the party proceeding jn forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the part)b: ~Joan Carey Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00918 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FORRESTER KERRI A VS FORRESTER MICHAEL E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT FORRESTER MICHAEL E unable to locate Him COMPLAINT - DIVORCE in his bailiwick. but was He therefore returns the the within named DEFENDANT , NOT FOUND , as to , FORRESTER MICHAEL E MICHAEL'S FATHER LIVES AT ADDRESS GIVEN. MICHAEL HAS NEVER LIVED THERE AND FATHER HAS NOT HEARD FROM HIM IN 8 MONTHS. Sheriff's Costs: Docketing 18.00 Service 19.32 Not Found 5.00 Surcharge 10.00 .00 52.32 So ans~: /~i'''` / -~ ~.' Thomas k~in~ Sheriff of Cumberland County LEGAL SERVICES 05/13/2002 Sworn and subscribed to before me this /~-~ day of~ ~ A.D. Prc~honotary ' ~ Kerri A. Forrester, · IN THE COURT OF COMMON PLEAS OF Plaintiff · · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 2000-918 ~ Michael E. Forrester, · CIVIL ACTION - LAW z - Defendant ' ~ .a:' · IN DIVORCE ~ o NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE C You have been sued in an action for divorce. You have failed to answer the complaint or f'de a counter-affidavit to the {}3301(d) affidavit. Therefore, on or after the 24th day of April, 2002, the other party can request the court to enter a final decree in divorce. If you do not ~e 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 fled 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 TELEPOHNE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR 1-800-990-9108 TRUE COPY FROM RECORD I~ T~Jfl'mny wherBof, I here unto set my hafld Kerri A. Forrester, Plaintiff V. Michael E. Forrester, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 2000-918 : · CIVIL ACTION - LAW · IN DIVORCE COUNTER-AFFIDAVIT. UNDER §3301(d) OF TI4-1?, DIVORCE CODE Check either (a) or Co) [] (a) I do not oppose the entry of a divorce decree. Co) 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. Check either (a) or Co): (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 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 Co) 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. I verify that the statements made in the counter-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 unswom falsification to authorities. Date: Michael E. Forrester 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. KERRI FORRESTER, Plaintiff Vo MICHAEL E. FORRESTER, Defendant · IN THE COURT ,OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 00-918 CIVIL TERM · CIVIL ACTION -- LAW · IN DIVORCE PRAECIPE TO WITHDRAW AND ENTER. APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of the Mid Penn Legal Services as the attorney for Plaintiff, Kerri Forrester, in the above captioned complaint. Please enter the appearance of the Family Law Clinic on behalf of the Plaintiff, Kerri Forrester, in the above-captioned complaint. Michael Parker Certified Legal Intern Dated: ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY' LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 2425-2968 Fax: (71'7) 243-3639 Date; ~;ey Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 KERRI FORRESTER, Plaintiff Vo MICHAEL E. FORRESTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW :IN DIVORCE : :NO. 00-918 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Parker, hereby certify that I served a Counter-Affidavit and a Notice of Intention to Request Entry of a Divorce Decree on Michael E. Forrester on ~/] ! 8'/0 ~ by first class United States mail, at the following address: Michael Forrester 11 Adams Street Enola, PA 17025 Michael Parker Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17103 (717) 243-2968 Fax: (717) 243-3639 KERRI FORRESTER, Plaintiff MICHAEL E. FORRESTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 00-918 CIVIL TERM : CIVIL ACTION -. LAW : : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above mailer, having been granted a Final Decree in divorce from the bonds of matrimony on the 3rd day of June, 2003, hereby elects to retake and hereafter use her previous name of Kerri Peters, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. §704. Wishes to be known as: COMMONWEALTH OF ~ COUNTY OF ~ K~:ri Peters On the l ~7 day of ,.T'~i¥ ,2003, before me, a Notary Public, Kerri Forrester, known to me to be the person O/hose name is subscribed to the within document, acknowledged that she executed the foregoing for the purpose therein contained. 1N WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. ~ ~-~.L~-~-,~' , ,~RECEIVED JUl.