The URL can be used to link to this page

Home My WebLink About03-0239 A/ViANDA BAKER CLINE, Plaintiff v. GLENN ALLEN CLINE, Defendant IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTy, PENNSYLVANIA CIVIL ACTION _ LAW 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 Courthouse, Carlisle, PA 17013. 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 W~ERE YOU CAN GET LEGAL HELP. Cumberland Count Bar Association 2 Libert Avenue Carlisle PA 17013 AMANDA BAKER CLINE, Plaintiff V. GLENN ALLEN CLINE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION : - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is Amanda Baker Cline, an adult individual, who currently resides at 4822-B East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant in this action is Glenn Allen Cline, an adult individual, who currently resides at Dauphin County Prison, DCP #053013, Mall Road, Harrisburg, Dauphin County, Pennsylvania 17111. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on June 14, 2002, in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds Upon Which this action is based is that the marriage between the Parties hereto is irretrievably broken. 7. The Plaintiff avers that One child has been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the COurt require the Parties to Participate in counseling. 9. The Plaintiff requests the court to enter a decree of VOrce. t 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 P.C.S. to authorities. ~4904, relating to unsworn falsification Oate:~ ....... ~ SAKER C~~ STONE LaFAVER &' SHEKLETSKi 4t"4 Brid~'~ ~' ID #60251 "New ,'~ /~creet, p ' Cu qfland .0. Box E ...... Telep:/~ ~ ~A 17070 Attorneys for ~, . :zazntiff .. , ~~ ~. W ~ -- t ---~.. ~~ 'i ~~ / G c ~~ ~~ C Cr"_3 ~~ u ~_ t R-= ,r.~ ;.~. =-r J .f ` I j L.__ t.~ :; ."r~- ~~' «~ --~ -+ ~_, '`, .;r~ ;_-, ~, ~-, „~~:~ 3 AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-239 CIVIL TERM : CIVIL ACTION - LAW IN DIVORCE AZFIDAVIT OF SERVICm COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Glenn Allen Cline, at Dauphin County Prison, Mall Road, Harrisburg, PA 17111, by United States Certified Mail, postage prepaid, restricted delivery, on January 21, 2003, as evidenced by the attached Certified Mail return receipts. SWORN TO AND SUBSCRIBED before me this ~ day of ~~z~/ , 2003. ~ ~',~OTARIAL SEAL (. v~ ;. U. i6k'EY, H~ry Pu~ic EZZZ, ' E? B:' S ONE Attorney at, Law / Postage r-~ Certified Fee Retum Receipt F~ . . ,,, AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA CIV1L ACTION - LAW IN DIVORCE :NO. 03-239 CIVIL TERM PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the Family Law Clinic on behalf of the Defendant, Glenn Allen Cline, in the above-captioned matter. Date: ~/~. ~'/0~ / -I Michael Parker Certified Legal Intern ROB~E~ E 3 · t~INS THOMAS M. PLACE Supervising Attorney LUCY JOHNSTON-WALSH Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE Defendant : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · CIVIL ACTION - LAW · IN DIVORCE :NO. 03-239 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Parker, Family Law Clinic, hereby certify that I am serving a tree and correct copy of the Praecipe to Enter Appearance on Elizabeth B. Stone Esq. 414 Bridge Street Post Office Box E New Cumberland, PA 17070, by depositing a copy of the same in the United States ma/l, first class, postage prepaid, this ]ff~ day of April, 2003. Date: /)'///6'~-/~9 -~ Michael Parker Certified Legal Imem FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 C~ c~ •-~' -l, ~~ <(. `~ ~ f`Fl r.,,... _. ~ .-.~ . ,_. ~i ~- -- ; ; -- cr ~ r.... . ~ E ) ~~« ~~ fl\div~lconsentaffidavit AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUIqTY, PENNSYLVANIA NO. 03-239 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on January 16, 2003, and served January 24, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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 the decree. 4~ 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 correct. I understand to the penalties of 18 tion to authorities. statements made in this affidavit are true and that false statements herein are made subject Pa. C.S. § 4904 relating to unsworn falsifica- Date AMANDA BAKER CLINE, Plaintiff f!\div\lconsentaffidavit AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-239 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on January 16, 2003, and served January 24, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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 the decree. 4. 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 correct. I understand to the penalties of 18 tion to authorities. statements made in this affidavit are true and that false statements herein are inad~ subject Pa. C.S. § 4904 relating to unsworn falsifica- Date GLENN ALLEN CLINE, Defendant AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-239 CIVIL TERM CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(C) OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without division of property, lawyer's fees before a divorce is granted. 3. I understand that I will not decree sent I understand that I may lose rights concerning alimony, or expenses if I do not claim them be divorced until a divorce is entered by the Court and that a copy of the decree will be to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are correct. I understand that false statements herein are made to the penalties of 18 Pa. C.S. tion to authorities. Date true and subject 4904 relating to unsworn falsifica- AMANDA BAKER CLINE, Plaintiff AMANDA BAKER CLINE, Plaintiff GLENN ALLEN CLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-239 CIVIL TERM CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY notice. 2. I consent to the entry of a final decree of divorce without division of property, lawyer's fees or expenses if I before a divorce is granted. 3. I understand that I will I understand that I may lose rights concerning alimony, do not claim them 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 fa]se statements herein are made subject to the penalties of tion to authorities. F-IO - 03 Date 18 Pa. C.S. § 4904 relating to unsworn falsifica- GLENN ALLEN CLINE, Defendant fl\div\ltransmitpraecipe\7 97 AMANDA BAKER CLINE, GLENN ALLEN CLINE, Plaintiff : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-239 CIVIL TERM ACTION 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 § (3301(c)) (3301(d) (1)) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: CERTIFIED MAIL, RETURN RECEIPT REQUESTED, POSTAGE PREPAID ON JANUARY 21, 2003 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff SEPTEMBER 22, 2003 ; by Defendant SEPTEMBER 10, 2003 . (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: ; (2) A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: ALL CLAIMS SETTLED 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: ~-~6-~3/. Date Defendant's Waiver of ~~~ Notice in § 3301(c) iv ce was filed with the Prothonotary: q-~) Attorney for Supreme~r~//~0251~'~/~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF !~~' PENNA. AMANDA BAKER CLINE, Plaintiff NO. 03-239 CIVIL TERM VERSUS GLENN ALLEN CLINE, Defendant DECREE IN DIVORCE AND NOW, DECREED THAT AND AMANDA BAKER CLINE GLENN ALLEN CLINE , ~d~, iT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE D~VORCED 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; ~ROTHONOTARY