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Home My WebLink About07-0988r Robin L. Smith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 07- q CIVIL TERM Mark E. Smith 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 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 l Robin L. Smith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 9j?V CIVIL TERM Mark E. Smith Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff isr who currently resides at Cumberland County, Pennsylvania. 2. Defendant is who currently resides at IA.. 11 _1" 1 ?LI??Ni lt?. l )LL 3. Plaintiff has been a bona fide resident of the of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ?blae--C??? at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plai iffff,rProo Se verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa!. C.S. §4904. Date. Jainti_ff, Pro Se Assisted by: Lindsay Dare Baird, Esquire 37 S. Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5732 (7 ?.,, i ? ?°. D T..? - ""' -T.r CC' ? ? ?? Robin L. Smith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 9 ? CIVIL TERM V. Mark E. Smith Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Robin Lynn Smith , Plaintiff, to proceed in forma ap U?nens• I, Lindsay Dare Baird, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. c C j, 'ndsay Dare ail d, Esq. Attorney for Plaintiff 37 S. Hanover Street Carlisle, PA 17013 (717) 243-5732 cz? C=j c? ? `? . ?V Ts? C, } g 111 ROBIN L. SMITH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 07-988 CIVIL TERM MARK E. SMITH, : IN DIVORCE Defendant AFFIDAVIT OF SERVICE I, Niven J. Baird, being duly sworn according to law do depose and state that a certified copy of the Divorce Complaint was personally served on Mark E. Smith, at 37 South Hanover Street, Carlisle, PA 17013 on this 2Z,.t`' day of March, 2007, at Q.'40 o'clock P.M. Niven J. Baird Sworn and Subscribed to before me thi ?4" day of WNLt_"'c ? , 2007 tJ,0Ll Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Lindsay C. Band, Notary Public Carlisle Son), Cumbefl2nd County My Commission Expires Oct. 21, 2010 Member, Pennsylvania Association of Notaries a -s'? ?.-? ?? C"? r" _;? `, ,. .. t, _;?, ji . ?? ?j1 Robin L. Smith Plaintiff V. Mark E. Smith Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- l lg IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on ?i?/° 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authoriti Dater Signature: Robin mith, Plaintiff cri ci Robin L. Smith Plaintiff V. Mark E. Smith Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 9g,S2 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that 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: /3 d Signature: S X 't /Robin L. Smith, Plaintiff ?,.? "" 4"1 C,_. "'1 ?1 ?'? t' - -i_A ? ?'S r^-^ ,.' ? _ Y l l r r) ?? ,. «tj ... -. . -. ? ,_ __..... ??... F ? `., ? ...nn a _..2 ? ?? ?. • • '? '?..?1 G..??...5?. ??./ ?? .? Robin L. Smith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- /I!-U CIVIL TERM Mark E. Smith Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: L / a 7 Signature: Mark E. Smith, Defendant C.J Robin L. Smith Plaintiff V. Mark E. Smith Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- yX6 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that 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: Signature: Mark E. Smith, Defendant r 10 V [ Robin L. Smith Plaintiff V. Mark E. Smith Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 9?g CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on ?3 - 00 ' r?- 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code' by Plaintiff, -? - , 3 - fLa ; by Defendant, -i 1 L - cl'? 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:' (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: --)L -fl - c a_. Plaintiffs Social Security Number: Defendant's Social Security Number: ) I L -,5 - -) I0"S obin L. mith 0 1 _ i^1-a 3F tj,:) -"? ICA) CAD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff No. 07-988 VERSUS Defendant DECREE IN DIVORCE AND NOW, 2@07 IT IS ORDERED A&D DECREED THAT RDBIN L. SMITH , PLAINTIFF, AND MARK E. SMITH 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; PROTHONOTARY ^ r v w r-,7, W- -) Ae f ,,y, jv ?7 "?Or, r, Robin L. Smith Plaintiff V. Mark E. Smith Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- q S8? IN DIVORCE CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that Plaintiff in the above matter filed a Complaint in Divorce '121, ?a - hereby intends to resume and hereafter use her filed on d? ' A previous name of and gives this written notice avowing her intention in accordance with the provisions of e Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. bin Lynn 'th lill-16. F F -F F F I I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS On this, the /JY(a day of ?t 2007, before me, the undersigned officer personally appeared-- also known as A?Zw) known to me (or satisfactorily proven) to be the person whose name is subscribe to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,.a. ?-. SAL) Tit of Offic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Lindsay D. Baird, Notary Public Carlisle Boro, Cumberland 2ounl 0 My Commission Expires Member, Pennsylvania Association of Notaries ?lj ° 0 C3 v- ,? t-? G try j t