Loading...
HomeMy WebLinkAbout03-0412DIANE J. CHRISTY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE BRUCE A. CHRISTY : o_Y- ,//,a ~;~5~z~'77~ Defendant : NO. 0;~- 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 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 child. 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. 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 inlbrmation 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. DIANE J. CHRISTY Plaintiff BRUCE A. CHRISTY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE NO. 0~-.. q/2. CIVIL TERM COMPLAINT The Plaintiff, Diane J. Christy, by her attorneys, the Family Law Clinic, sets forth the following cause of action: DIVORCE UNDER 23 Pa.C.S. SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Diane J. Christy, who currently resides at 20 E. Pomfret Street, Carlisle, Pennsylvania, 17013. 2. Defendant is Bruce A. Christy, who currently resides at 225 West Bryon Street, Douglas, Georgia 31533. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 20, 1992 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since the summer of 1997. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree in divorce dissolving the marriage. Date }/,-L~4105 Ldah M. Dav6nport / Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 VERIFICATION I verify that the statements made in the Ibregoing divorce complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: Diane J. Christy, Plaintiff Bruce A. Christy, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 1N D1VORCE : NO. 0K- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Diane J. Christy, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Resp,~ctfully su/amitted, Leah M. i3a/qenport Certified Legal Intern THOMAS~ l~I. J~LACE ROBERT ~. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 DIANE J. CHRISTY Plaintiff BRUCE A. CHRISTY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · DIVORCE : NO. 0~- ~q,,t CIVIL TERM 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. AFFIDAVIT UNDER SECTION 3301(d) OF THE D1VORCE CODE 1. The parties to this action separated in the summer 1997 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 ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are tree 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 Diane J. Christy, Pl~ff DIANE J. CHRISTY Plaintiff BRUCE A. CHRISTY Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · DIVORCE · NO. 03-412 CIVIL TERM AFFIDAVIT OF SERVICE I,._}~Q.'~ c~h w ~. ~ ~L~__2~q_, hereby certify that I am a competent adult and that I served a tree and correct copy of the Complaint for Divorce on the Defendant, Bruce A. Christy, at the Coffee County Jail, 225 West Bryon Street, Douglas, Georgia 31533· Service was complete upon receipt by Bruce A. Christy on the ! (5day of February, 2003. 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. C2S. 4904, relating to unsworn falsification to authorities· DIANE J. CHRISTY Plaintiff BRUCE A. CHRISTY Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : CIVIL ACTION - LAW : DIVORCE : : : NO. 03-412 CIVIL TERM 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: February 10, 2003, by Affidavit of Service. 3. Date of execution of the Plaintiff's Affidavit required by § 3301(d) of the Divorce Code: January 28, 2003; Date of service of the Plaintiff's Affidavit upon the Defendant: February 10, 2003. 4. Related claims pending: None. 5. Date and manner of service of the notice of intemion to file praecipe to transmit record, a copy of which is attached: United States mail, first class, postage prepaid on March 20, 2003. Date ~e~. Da4enpo~t- Certified Legal Imern LUCY ~3bl~STON-WALSH ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 DIANE J. CHRISTY Plaintiff Mo BRUCE A. CHRISTY Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE NO. 03-412 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT: 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 April 14, 2003, 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 TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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. IN THE COURT OF COMMON PLEAS CF CUMBERLAND COUNTY ST~'rE OF ~. DIANE J. CHRISTY Plaintiff VERSUS A. CHRISTy Defendant BRUCE PENNA. N O. 03-412 DECREE IN DIVORCE AND NOW, f11~ /2~ DECREED THAT Diane J. Christy 2003 , IT IS ORDERED AND , PLAINTIFF, AND Bruce A. Christy , 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; N/A BY THE COURT: / ATTE ~T~~~ "~~ PROTHONOTARY