The URL can be used to link to this page

Home My WebLink About97-01063 >- C") rr ;.. j.-.:. c. UIC: Co'; ..: r. 1 -, 1.1: , -, , u. ,- C.)' ....j ~, ~ ;,- , .-.:'1 , , , l.. . , .:,j c',. ~C ~.l.. " !- ",J '- ':f' - J Doris Ludington. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE John E, Love. Defendant : NO, 97-' ""',, CIVIL TERM 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 arc warned thm if you fail ILl 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. Cumberland County Courthouse. 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, 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. Court Administrator Cumberland County Courthouse Carlisle. pA 17013 717/240-6200 Doris Ludington, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE John E, Love, Defendant : NO, 97- n'<.-J CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admilled, PLAINTIFF'S AFFIDAVIT UNDER SECTION 330Hdl OF THE DIVORCE CODE 1. The parties to this action separated in 1987 and have continued to live separate and apart for a period of at least 2 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, ~4904, relating to unsworn falsification to authorities, Dat~ - ~ Co - c:r 7 ~ cnu 0~ Doris Ludington ~u , I ,-- r.- -. ; : Li HIt .. ('/; ,., ~I"l (, '-. '..,- ~ - , ,:: , c,' " C' r"j ,} l.q L_.: I'. ,) .j C:, ,. t 4. ~ :) I", L... "- ~ U r- U' ,) ;.J Doris Ludington, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW IN DIVORCE 10hn E. Love, Defendant NO.97- lol3 CIVIL TERM AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending 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: Doris Ludington Address: 102 North Pitt Street, Carlisle, Pennsylvania 17013 Social Security No.: 166-52-1957 (b) Employment If you are presently employed, state Employer: Center for Industrial Training Address: 262 Silver Springs Rd., Mechanicsburg, PA 17055. Salary or wages per month: Petitioner works approximately 27 hours every two weeks at the rate of $2.40 per hour. Type of work: assembly work If you are presently unemployed, state Date of last employment: None Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: None Other self-employment: None Interest: None Dividends: None Pension and annuities: None Social security benefits: None Support payments: None Disability payments: SSI-$497,oo/mo, This umount Iluctuutes, It is reduced hy the earnings in excess of $85,oo/mo, Unemployment compensation and supplemental benefits: None Workman's compensation: None Public Assistance: None Other: None (d) Other contributions to household support (Wife)(Hushand) Name: If your (wife)(husbund) is employed. stute Employer: Salary or wuges per month: Type of work: Contributions from children: None Contrihutions from purents: None Other contrihutions: None (e) Property owned Cash: None Checking account: None Savings account: None Certificates of deposit: None Real estate (including home): None Motor vehicle: None Stocks; bonds: None Other: None (I) Debts and ohligations Mortgage: None Rent: HUD-$86/mo, Utilities: Electric-$40/mo, Other: Cable-$25/mo, Telephone-$70/mo, Transportation-$15/mo, Laundry-$40/mo, Clothing-$40/mo, Food-$80/mo, beyond food stamps Loans: UGJ-$lO/mo, on outstanding halance of $90, MHMR Housing Fund-$50/mo, on outstanding balance of $550, (g) Persons dependent upon you for support (Wife)(Hushand) Name: Children. if any: Name: Age: Other persons: Name: Relationship: '- i; -, .. . , C-l l! , ~ CJ: r: ~ ~ , ,,- " , " C ') I' ~) Cl, l'_ I,' I .1,. (:.~ '>1 i.... "J 1;- L~ . j II. I- 0 ell \...; 8, Petitioner has engaged in numerous good faith etTorls to locate the Hespondem, including: a, On September 24, 1996, Petitioner's counsel, the Family Law Clinic, contacted directory assistance in Cumberland County, which is the last place that Petitioner saw Respondent roughly ten years ago, There was no listing for a John E, Love, b, On or about November 19. 1996, Petitioner's counsel, the F,nllily Law Clinic, utilized a service available on the Internet which provides the addresses and telephone numbers of any person with a given name, who is listed with telephone directory assistance in every state in the United States, The search for the name "John E, Love" resulted in 44 listings, (Exhibit "A") On November 19, 1996, Petitioner's counsel. the Family Law Clinic, sent a letter addressed to each of the "John E, Love"s listed, (Exhibit "8") Listing numbers 32 and 33 were returned "undeliverable" due to insufficient addresses, (Exhibit "C") The telephone numbers provided with the addresses obtained from the internet were disconnected, Directory assistance did not have updated listings for a "John E, Love" residing in their vicinity and could not provide the full address, The United States Postal Service in these cities could not provide us with more information regarding the addresses than we already had, Listing numbers 3. 5. 12, and 37, responded by telephone in the negative, (Exhibit "0") Listing number 35 replied by letter in the negative, (Exhibit "E") c, Petitioner's counsel, the Family Law Clinic, has not received any other replies to its correspondence, , ( - .. " , In \ .fl . In #: cr, . #: W If} in ~ - I/) I/) -0 .. .... .... "'0 -= (0 ~') In ..... - 0 .. 0 C .. 0.' .. 0 .- . 0 u N .- -: (IJ - - - .....- \D '0 :-.' .. G'\ . G'\ .., -: , \ C:' - ,1\ -- .1\ . '"' '"' , - , '"' .... - ... ... - 0 0 . ~- ~- I '"' - '"' ClC <]: - ,]: ... - ll. ~ - ll. - '-' '-' -< 0:: ~tS 0:: ~tJ :J ~ :J oD oD S~ r I/) Slil If} (Ill' ... ... (IIr 0:: ~o (II 0:: ;~ (II~ 0:: , 0:: " ~~ oil - <I <I .. (::~-:I 00 :c .. ~?r) 00 I'l '~J g...:l lon' ...tJ .s .\) ." .s<t ,'(II " .. \ (IIr ':../:..s~_ :/ I " I I,.,..) , l' . ' ; ~.~ .. " , , " ',' ~ .. tJ '< ~r~ ...:l-M tJH.... g .. g ~fIl.... " ~fIl.... :j::: :j::: '. < " '. < p.,p., p.,p., ~~ u ~~ u ~;;; 0;;; .. z= .... lo.~a lo.~a N.i~\f 2 \9~~~. t r \ " ' J:~ II. ," " ,': John E. Love P,O. Box 188 Garfield, WA 99130 November 22, 19116 Mr, Michael Levinson Femlly Law Clinic 45 North PI<< SI. Cartlsle, PA 17013-2943 Re: Your lellerdated November 19,1998 Good morning Michael: I am not the John E, Love you are seeking and I regret that I am unable to advise you as to the where abouts of any other person by the seme name, Best wishes to you In your endeavors to assist Ms, Doris Ludington, Sincerely, JEUlap "EXHIBIT E" NOTICE TO I>EFENI> ANI> CLAIM RIGHTS In the Court of COllllllon Pleas of Cumberland County, Pennsylvania No. 97- Civil Term Doris Ludington, Plaintiff v, John E, Love, Defendant DIVORCE TO: John E, Love You have been sued in court. If you wish to defend, you must enter a wrillen appearance personally or by allorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so the case may proceed without you and a decree of divorce may be entered against you without further notice for the relief requested by the plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, CONTACT THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 "EXHIBIT p" / ,. >. .:s L.': I .-- \1.1'; (".: l.~ i r' 't: .:,., to,' (~> r:-'J (" . u.:' ( :-J ,- ,. ,. ~. t', r- v ,;" -'