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Home My WebLink About00-01050 ~.,~"" ~....~iilif:" . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SERENA A. MARLOWE, .. .. Plaintiff .. CIVIL ACTION-LAW .. .. .. vs. .. NO. 2000-1050 CIVIL TERM .. .. .. KEITH P. MARLOWE, SR., .. IN DIVORCE .. Defendant .. .. CERTIFICATION/AFFIDA VIT OF SERVICE OF COMPLAINT IN DIVORCE BY CERTIFIED MAIL COMMONWEALTH OF PENNSYLVANIA .. .. SS. COUNTY OF CUMBERLAND Roger M. Morgenthal, Esquire, being duly sworn according to law, deposes and says that on the 9th day of March, 2000, he caused to be deposited in the U.S. Mail at Carlisle, Pennsylvania for delivery to the above-named Defendant, at 644 South San Jose, Mesa AZ 85202, by Certified Mail, Return Receipt Requested, a true and correct copy of the Complaint in Divorce in the above case. Said Receipt is attached hereto, made a part hereof and marked Exhibit "A". R~~ Attorney for Plaintiff H.. Sworn to and subscribed before me this 1. '( day of March, 2000. NOTARIAL SEAL KATHY L. MUMMERT, NOTARY PUBLIC CITY OF CARLISLE, CUMBERLAND CO. PA MY COMMISSION EXPIRES AUGUST 11 2003 - ~ '"", . + ..~ompiete ita ., a '3. 'I~b fete . 'litem 4 if Restricted Delivery is desired. .' Print your 'name and 'address on the reverse ";so that we can return the card to you. ~Attach this card to the back of the mailpiece, or on the front if space permits. 1. ArtIcle,Addressed to: 'YY)r. Iteir\" 7, YV\.o.r\cweJ Sr. IP '1'1 So~ SRM 3DS( Y\1.eso A? \?,sciC0 J . Is delivery address different from Item 1? YES, enter delivery address below: o Agent o Addressee DYes ONe 3. Service Type rs-Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery~ (Extra Fee) Dyes 2. Article Number (Copy from service label) 7.. 3.3'1 0<08 0)1$3 pS~<ir"i~~1quly\1$9 i. bOmestic Return Receipt 10259S-99-M-1789 FXHlflfT it IJ I' ""'..:. " .~l WjWll!J"_~Ii[f_~~ ,. -""~~ ',";,'."J" ,""""'~,,- ". , '<,.""0,',',, J .r.......- , ~,~ ~ " ..I'. (") 0 0 c <:::> '-n <" :x '"Um ):.)i11 :::! S2rr: = ;';i~ :JJ r- ZS:: N -.'~m ~2~~ .;:-- 236 ~o :2 -~~'t :i'c -":J,-r; Z ~ ~ '>-5;5 ):>0 N o,n c Z "'" =< w $ Ul -< m-~ " ~~""';J~ ['. -.....'" J I Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SERENA A. MARLOWE, Plaintiff vs. CIVIL ACTION-LAW NO. 2000- IOS'/:) CIVIL TERM KEITH P. MARLOWE, SR., 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 the 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone: (717) 249-3166 - _I .~\",_!Ii!&:;L' ) , '\ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SERENA A. MARLOWE, Plaintiff CIVIL ACTION-LAW vs. NO. 2000- /050 CIVIL TERM KEITH P. MARLOWE, SR., Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Serena A. Marlowe, who currently resides at 169 West North Street, Carlisle, Cumberland County, Pennsylvania, where she has lived since on or about November 15, 1999. 2. Defendant is Keith.P. Marlowe, Sr., whose present or last known address is 644 South San Jose:, Mesa, Arizona 85202, where he has resided since on or about June 1, 1999. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on May 9, 1996, at Mt. Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree in divorce. Date: Februarv 17.2000 ~l11dk-l-e Roger M. MorgentJ{al, Esquire, m# 17143 95 Alexander Spring Road, Suite 3 Carlisle, P A 17013 (717) 249-6333 L~_-ar_M:" " '\ J I I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. 94904, relating to unsworn falsification to authorities. ~,,~j.~ Serena A. Marlowe 2 'd",C4 IIl>L J ~"iI._Jl~f ., --~IIIIIW~~ . [" " C) C. C) ~::: a 1 -:~ -oF,--. nlf-. ~.f,:: 0,.) ;::S;,,'- " <- ....-. ):>r, ~&:J C,) ;..0.:: ::< \.0 \. , J --'-r~r'_.! SERENA A. MARLOWE, IN THE COURT OF COMMON PLEAS OF plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. . : NO. loS:D :~ CIVIL TERM KEITH P. MARLOWE, SR., Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allowpERENA A. MARLOW~ (~~~~~~/Plaintiff), to proceed in forma pauperis. I, Rogpr M. Morgpnthal, 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. ~VVl~ ~Qqer M. Morgenthal, Esquire Att:"orney for Plaintiff ID#l7143 FISHMAN & MORGENTHAL 95 Alexander Sprin~ Road Suite 3 Carlisle, PA 17013 717-249-6333 ~, - ~~ "~ >'1!fl.\ SERENA A. MARLOWE, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO . 02/;-&<) - It> s2J CIVIL TERM v. : KEITH P. MARLOWE, SR., : Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the Plaj ntiff 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: Serena A. Marlowe Address: 169 W. North Str~et Carlisle, PA 17013 Social Security Number: 176-52-7139 (b) If you are presently employed, state Employer: Not employed. Address: Salary or wages per month: None' Type of work: If you are presently unemployed, state Date of last employment: I q qLf ,.~~..., - ", (e) Property owned Cash: Checking Account: {)Y'rrf~"'-V", 15"",,/(. #-I(J~ 00 los-q Savings Account: Certificates of Deposit: Real Estate (including home): Motor vehicle: Make Year /z"n- Cost Amount owed stocks; bonds: Other: (f) Debts and obligations Mortgage: Rent: Loans: Monthly Expenses: (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name:Rebecca A. Marlowe Age: 4 yp~r~ Keith P. Marlowe. Jr. 2 yp~r~ 10~- , .=~-~ ........""'iilllIiI~ ~ Salary or wages per month: Type of work: p.,(Ce/9f,'f/lo,', 1-1 StelA. rl'~ ,)J./I'''~.J /;"''7 L1 Y;Mf'n'f'1 (e) other income within the past twelve months Business or profession: other self-employment: Interest: Dividends: Pension and annuities: social Security benefits: SSI $430/. '10 Support payments: Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: ., C"" I rl"",,,,..S L AJ. .Iie I 14nid70-"~ Publ~c Ass~stance: ----:~ __' tJ.o?! ,) To '~r <r ~, ., "" other: (C~;IA )'-tffwf- ~JJLj.- (d) Other contributions to household support (Wife) (Husband) Name: If your (husband) (wife) is employed, state Employer: salary or wages per month: Type of work: contributions from children: - ~ ,,. -~ 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: February 17, 2000 ~A~.A. ~ Serena A. Marlowe Jiiill H - ~HQdllmlilill ~1illIl:fi~!!i~'~"""~"'~ .~. ~ .' ,..;. 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