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Home My WebLink About98-03468 J I" I~ .~ ... ~, j) I (:// \ I (. . ~. ::.: . I .'. v '. It' "\, q, '\ ::s \, ~ \ ~ \ '", ~ \j I i I t I.! .....1 .5 '", j ~I I I 0..1 "I ~, ~I .1 o...J (j'-j ~1 , I , ~,~***~~*~***~,**,~,,~'~"~"~~'~':'~~:**~*'~~*':~ . -..-.-.-...- ...._.-,'-----~..~"_.---...-........-.---~- .,",".~ ~ _..~,-"'...,-_.,~ --,-- .-..,.... . ". , ,..., .. ...._---,.-.,.-..--'....,_., .",.._-.......--._--"..........~.~-.-.--- '., ~ ~ .' ~ DY~/T _ Co.ur~ ,/ ~ r(~ ~ . c:j.,2~ /i'.~7,/ /'~"'~7''''':i:. . J:, ~ ~.~ t7. C/" )~ ~,: ;,e . _C4 /' XJ Ii ',~, :? '~N4.. k~.?"'t?'~tl;~;;olal:Y ~ ~ " ~ ~ ~ -- ......----..---------------------.-...-,-,..--.--..--..... ~'-'.'~" .- ---~-~.......--------._------""-.._'..--~-_..~----,--....~_.,-~ .~ ~ ,~:;..._:._:._ _,:.;. .:+:. .:+;. .:.:. -:.;. -:+:- -:+:..:.:..:.:. -:+;. -:+:. <+;. .:+> .:+:. .:+:. -:+;, <+:. .:+;. -:+;. -:+:-.:..:- <~:.<+;. ,':~:' ':f1;' <o&;:---,:';';~.::+r ~ " l, :1 .,,( ~I ".( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY s , I~ STATE OF ;~~~~ PENNA, ~. '~J!:;""'''r ~ ',' $/ $ ,', ~ ~ ',' ~ ',' CAROLYN J. GUILLAUME PLAINTIFF i\ (), . . 3466 CIVIL 96 1<) ~ .. " V/'I':';U;; ~ CHRIS S. SPRINKLE DEFENDANT ~ ',' ~ ',' " ~ '.' ~ DECREE IN DIVORCE ~ ',' ~ '.~ ~ ~.' AND NOW, ' , , , , , , , , , , ??0,b~, ,,-?!,~ ,~" 19, ,9rP, " it is ordered and decreed that "',"',' ,C~~?,L,~N, ~:, ,G~I_L,~1?-U~,~. , , , , , , " , " "', plaintiff, and, .... .. .. _ , , , .. , , , ,~~,R:~1?, ~,...1?r~,I,l'!~~!'.. .. .. , , , , , , , _ , , ", 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; ~ ~.~ ~ ~-: ~ ~.~ NONE ",.... "..............,.., ........ ..""...,.',....,..",.. ............." ~ ,,' ~ t< ~ " :; ~ f.~ ,.',..,...,..,.....,.,.. ,... ,....,.,.. ,..'".....,'.". ~ ~.~ ~ ',' ~ $ ~ $ $ ~ ,,' $ * ~ ,,' ,', ~ ~ ... * * i., $ ~ ',' ~ ',' ~ ~.~ C' ~ ~ ~ ~.~ ~ ~.~ ~ ~.~ ~ "~ ~ * ~ ~ * ~ ~ * RECEIVED OCT 0 6 1998 CUMBERLAND LAW .JOURNAL 2 LIBERTY A VENUE CARLISLE, PA 17013 .. OCTOBER 2 1998 Cumbcrland Law Journal is publishcd CI'Cry Friday by thc Cumbcrland County Bar Association and is designated by the Court of Common Picas as thc official legal publication for Cumberland County and thc legal ncwspapcr for publication of legal notices, TO: Family Law Clinic RE: Carolyn J, Guillaume vs Chris S, Sprinkle Legal advertiscments must be reccived by Friday Noon, All legal advertising must be paid in advance. Makc all checks payable to: Cumberland Law Journal. Advertisement inserted on following dates: OCTOBER 2,1998 Advertising Cost $ 50.00 $ 0,00 $ 0.00 $ 50,00 ------------- $ 0,00 Proof of Publication Second Proof Request Payment received Total Amount Due Payment received SEPTEMBER 28, 1998 Beckv H, Morgenthal/Executive Director PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LA W JOURNAL (Under Act No, 587, approved May 16, 1929), p, L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : 55. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz OCTOBER 2. 1998 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are ~ 7J) l( Roger SWORN TO AND SUBSCRIBED before me this -L-dayof OCTOBER. 1998 NOTARIAL SEAL' lOl~ E. SmDER, Noiary Public Corlisl. 5ore, Cumbonand County, PA My Comnlilf.&iC'"JM ElI:pires March 5,2001 , CAROLYN J. GUILLAUME Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. CHRIS S. SPRINKLE Defendant : NO. 98-3468 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 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. 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. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. ~J N ~ ~ DONALD MARRIT Staff Attorney THOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorneys Marcia M. Ziegler Student Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 VERIFICATION Understanding that the making of any false statement would subject him to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities, the undersigned verifies that the allegations in the foregoing Petition are true and correct, to the best of his knowledge, information and belief. ~1/# 1u: rJ/;~c@a~ CAROL 1. UILLAUME Date: ~ /1f1/~R I , CAROLYN J. GUILLAUME Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW CHRIS S. SPRINKLE Defendant 9<!'3V~,i NO. 98- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS i ! To the Prothonotary: Kindly allow CAROLYN J. GUILLAUME, Plaintiff, to proceed in forma pauperis. I, DONALD MARRlTZ, of the Family Law Clinic, 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 service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Ju\K\t 21} lig ~ --c..-- Date: DONALD MARRI Staff Attorney ROBERT E. RAINS THOMAS M. PLACE KATHERINE C. PEARSON Supervising Attorneys Marcia M. Ziegler Student Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Disability payments:O Unemployment compensation and supplemental benefits: 0 Workman's compensation: 0 Public Assistance: Food Stamps $548.oo/month, WIC vouchers Other: 0 (d) Other contributions to household support Name: Tim Myers, father of Carolyn's children, lives in household If person is employed, state Employer: Self-employed, roofing subcontractor Salary or wages per month: $655.05/month (average since 1/1/98) Type of work: roofing Contributions from children: 0 Contributions from parents: 0 Other contributions: 0 (e) Property owned Cash: $15 Checking account:$150, subcontracting business account Savings account: $6, subcontracting business account Certificates of deposit: none Real estate (including home):none Motor vehicle: 1986 Dodge Caravan, nothing owed, value: $1500.00 Stocks; bonds: none Other: none (t) Debts and obligations Mortgage: 0 Rent: $550/month Loans: $2,500.00 to American General (consumer credit agency). Original payment was $150.oo/month, but has not been paid in several months Other: Electric: $loo.oo/month Phone: $25.00/month, $250.00 past due Gas: $lOO.oo/month Propane heat in winter: $80.oo/month Diapers: $50.00/month Non-food household goods, and food not covered by food stamps: $70.oo/month (g) Persons dependent upon you for support Children: Four Name: Tyler John Myers Age: 5 Jessi Jean Myers Age: 3 Melissa Joe Myers Age: 2 Amanda Jayne Myers Age: 1 Total Household Income: $655.05/month Total Household Expenses: $895.00/month 4. I understand that I have a continuing obligation to :1 Date Cd 11& hg , Petitioner ffJ tiw7Co/u ,\()/~ , inform the court of improvcmcnt in my financial circumstanccs which would permit me to pay thc costs incurred hcrein. 5. I vcrify that the statcmcnts madc in this affidavit are true and correct. I undcrstand that false statements hercin are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. , 8. Pctitioner has cngaged in numcrous good faith efforts to locate the Rcspondent, including: a. Petitioncr's counscl attcmpted to find Respondent through the United States Postal Systcm, by rcqucsting a forwarding address from the Jacksonvillc, Florida Postmaster. This was done pursuant to 39 CFR 265.6 (d)(6) (II), through a Requcst for Change of Address sent June 15, 1998. The request was returned to Petitioner's counsel on June 23rd, with no forwarding address available. The rcturned request and accompanying letter are attached and incorporated by rcference. b. On or about June 21, 1998, Petitioner's counsel, the Family 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 the Jacksonville area. The search for the name "Chris Sprinkle" rcsulted in no listings. Several othcr Sprinkles were listed, and Petitioner's counsel, on July 8, 1998, called each Sprinkle listed. Two were unrelatcd, all other phone numbers had been disconnected leaving no new phone number. One numbcr was unpublished. c. On July 8th, 1998, Petitioner's counsel also called information, (904) 555-1212, in Jacksonville. No listings were available for Chris Sprinkle. At the same time, Petitioner's counsel left a message for the unpublished phone number. No response was received. 9. Petitioner has no further information regarding the whereabouts of the Respondent and no way of obtaining such information. Petitioner knew Respondent for only two months before they wcre married, and was married to the Rcspondent less than one month before the parties were legally separated. Petitioner does not know any of the Respondent's relatives. , , , VERIFICATION I vcrify that thc statcmcnts madc in this Pctition arc truc and corrcct to the best of my ! '/ personal knowledgc and bclicf. I undcrstand that falsc statcmcnts hcrein are madc subject to the penaltics of 18 Pa.C.S. ~4904. rclating to unsworn falsification to authorities. Date: 1 II, jC/6 , . ii1i!Ydi/l1 Ii--L CAROLYN J. GUILLAUME, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE qo:-J4~ f : NO. -9lM4l16-CIVIL TERM CHRIS S. SPRINKLE, Defendant PRAECIPE TO REINSTATE COMPLAINT To the Prothonotary: Please reinstate the plaintiffs complaint in the above captioned matter. D (-;<1/- u1/ ate Y' I 1) h'uJJ (~\CG,\~ THOMAS M. PLACE ROBERT E. RAINS Supervising Attorney Donald Marritz Marcia M. Ziegler Student Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 '-. I '-. **'*ro~~~-~~*~'*~*~*****)"*:~~:~:;~:'."*'~~~Yl~ " .-.-......-.-..........-...-...---......---.-,..-..-.--- ,---- .....---------................------'--"'----------.. ,/ ~ . ~ y ~ ~ ~.~ ~ " ~ ... ~ ~." ~ ~ ~.' ~ ~ ?- $ IN THE COURT OF COMMON PLEAS ;,~ ~ ~ ,,' i, ~ ~ $ ~ ',' ~ .', ~ ~ ',' $ ~ .. ~ ~ ',' ~ * i;. * l~ . ~ ~ !~ /'" , ' !~ 1':' "~ ~ ~." ~ ~ $ ~ ~ ',' ~ I~ I,:. )~ ~ ~.' ~ ;L ~ s ~ .. Co." /;. .... !~ ~ C&vZZo r~~?/;;d~n"'~ J, I:: ~ .... ~&L. kc#~,..~ i~ ~ rolholtolary i ~ ri .........----.--..-. ~....._----.~,~__~.'~ _'..' _, .,._.-.~_-._.,~__________...._____...~........_'__. ........,.'" ,'..._ ~ "__~'--" "_ i ~ .~:....:-, .:+;. .:+:. .:+;. ':.:..:.:...~:.. -:+;. ':+:. -:+;. .:+;. <+;. .:+:- -:+;. ':+:. ,:+;. .:+;. ,:+;. ':.:. -:+:- ':.;, .:+>.:",;. ,:+;. .:+;. .:..:' <~:' .:+:. .:+:.' ~ ~ OF CUMBERLAND t.r.~ ;(.(}~11; , . L....-r:'~ . ~ ~ . ~ "":.I4J!~i-".#'r COUNTY s ~ ',' ~/ ~ STATE OF PENNA. ,', ~ ~ . CAROLYN J. GUILLAUME PLAINTIFF 1<) 3468 CIVIL 98 N (), ~ ~, Vt:I':ql:; ~ ',' CHRIS S. SPRINKLE DEFENDANT $ $ ~i ~' "'I ~I .. ~~ ': DECREE IN DIVORCE ~ ~" AND NOW, ,,' , , , . , , , , ?70,b?:, , ,,2,0,",, 19, ,9"'. " it is ordered and decreed that"""", ,CARO,L~N, J:. ,GUI,LLAUM,E"".",.""", plaintiff, and, .. .. , , , , , , , , .. , , , ,~H,~~1?, ~,...SPR,I,t-!~~l', , , , , , , , , , " , .. ''', 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; NONE .,..,,'.., ...,."., ,...,..,." ,......... ,..."...,.,.......,...., "', ,..,....,.....,."".,.........".." ',....".,....., '" ~