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Home My WebLink About03-1435CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. OJ- 1935' CIVIL TERM · 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 will proceed without you and a d~cree of divorce or annulment may be entered against you for any 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, i 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 Prothonota at C~umberland ry . County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 PAPERiTO 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, Pennsylvania 17013 717-249-3166 CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03- CIVIL TERM ·DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Christina Marie Taverna, an adult individual currently residing at 25 East North Avenue, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant is Joseph Charles Taverna, an adult individual currently residing at 3 Richard Lane, Apartment 207, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married September 3, 1999 in Harrisburg, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither Plaintiff nor Defendant is a member of the United States Armed Forces or its Allies. 7. 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 your Honorable Court to enter a divorce pursuant to 23 P. S. Section 3301 (d) of the Domestic Relations Code. Respectfully submitted, Marga~t M. Simok Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 VERIFICATION The above named Plaintiff, Christina Marie Tavema, verifies that the statements made in the above Petition are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: Christina Marie Tav~m-a - - CHRiSTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03- f~35"' CIVIL TERM · DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Christina Marie Tavema, Plaintiff, to proceed in forma pauperis. I, Margaret M. Simok, attorney for the party proceeding i_n forma pauperis, certify that I believe the party is unable to pay costs and that I am providing free legal service to the party. Margg/et M. Simok Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03!- J ~35~ CIVIL TERM · DIVORCE AFFADAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on! March 15, 2001, and have continued to live '2 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. 4. 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. ~c~nr]stina Marie Tax;ea;ffff - Plaintiff CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 - 1435 CIVIL TERM · DIVORCE ACCEPTANCE AND ACKNOWLEDGMENT OF SERVICE I, Joseph Charles Taverna, Defendant in the above captioned proceeding accept and acknowledge service of the Complaint Under Section 3301 (d) of the Divorce Code and the Affidavit Under Section 3301(d) of the Divorce Code filed in this action by the Plaintiff, Christina Marie Taverna. I also waive any defects in any form or manner of service. Date ,0"os~h Charles-Tavern~- ' Defendant Mailing Address: c/o JoeBeth Tavema 3 Richland Lane Apartment 207 Camp Hill, PA 17011 CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 - 1435 CIVIL TERM 'DIVORCE ACCEPTANCE AND ACKNOWLEDGMENT OF SERVICE I, Joseph Charles Taverna, Defendant in the above captioned proceeding accept and acknowledge service of thc Notice of Intention to Request Entry of § 3301 (d) Divorce Decree and thc Counter-Affidavit Under § 3301 (d) of thc Divorce Code filed in this action by the Plaintiff, Christina Marie Taverna. I also waive any defects in any form or manner of service. Date 711l ~sel~ff Charles T~vema - ~ Defendant Mailing Address: c/o JoeBeth Tavema 3 Richland Lane Apartment 207 Camp Hill, PA 17011 CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 1435 CIVIL TERM : DIVORCE COUNTER-AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE Check either (a) or (b): ~(a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: (Check (i) or (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. __ (ii) The marriage is not irretrievably broken. Check either (a) or (b): ~(a) I do not wish to make any claims for econonfic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expense ifI do not claim them before a divorce is granted. __ (b) I wish to claim economic relief which may include alimony, division or property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. IfI fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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 unswom falsification to authorities. Date: O,~end~nt "~ ' ......... CHRISTINA MARIE TAVERNA, Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 1435 CIVIL TERM : : DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of divorce decree: I. Ground for divorce: Irretrievable breakdown under § 3301 (d) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgement of Service form on March 31, 2003. 3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code: March 25, 2003. 4. There are no related claims pending. 5. Date and manner of service of the notice ofintention to file, a copy of which is attached: April 22, 2003 - served by United States Postal Service. Plaintiff's Social Security Number: 565-65-2601 Defendant's Social Security Number: 206-48-2254 MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 CHRISTINA MARIE TAVERN& Plaintiff VS. JOSEPH CHARLES TAVERNA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 1435 CIVIL TERM DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301 (d) DIVORCE DECREE To: Joseph Charles Tavema 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 May 12, 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 fbr 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 iN THE COURT OF COMMON Of CUMBERLAND COUNTY STATE OF ~ii~ PENNA. CHRISTINE MARIE TAVERNA PLEAS N o. 2003 1435 Plaintiff VERSUS JOSEPH CHARLES TAVERNA Defendant DECREE IN DIVORCE AND NOW, DECREED THAT Christina Marie Taverna AND Joseph Charles Taverna ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT l$ ORDERED AND PLAINTIFF, _. DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOL~-OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ATTEST: *.-. ~ ~ j. ~/~ ROTH O NOTARY n~ T~ COUaT OF COMMON pLEAS CLrMBERLAND COUNTY, pENNSYLV AIqlA civIL TERM · . · e above captioned Divorce Action, that the plaintiff tn th _c/~. a~.T- ~~-' ~otiCe ls h~e ~ .... ha o~evtu hereb7 Meets to retie ~d hereaner u~ ~er ~ · .. ss'. 3 - -- a Notary public. Commonwealth of pennSylvama: County of Cumbedana . ~x, ~ ~~' g0~, be~or~ .~ be the person On the ~ ,, ~ q~ · -~ that she execm~ .... d ~~-~* and ac~OWt~g~ whOSe ~[~ ' ' ' ' ~e Cregoing for ~e p~ose th~em contmn~ set mY h~d ~d Not~ Se~. ~ ~SS ~OF, I have here~to ~ CHRISTINA MARIE TAVERNA, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH CHARLES TAVERNA, III, DEFENDANT : 03-1435 CIVIL TERM ORDER OF COURT AND NOW, this '~-~ day of July, 2003, a corrected divorce decree Margaret M. Simok, Esquire Joan Carey, Esquire For Plaintiff is entered to reflect that the name of defendant is Joseph Charles Tavema, III, rather than Joseph Charles Taverna. Joseph Charles Taverna, III - 7'/¢,-~,~ ~ c/o JoeBeth Taverna 3 Richland Lane Apt. 207 Camp Hill, PA 17011 :sal INTHE COURT OF COIVliViON OF CUMBERLAND COUNTY STATE OF ~~~ PENNA. CHRISTINA MARIE TAVERNA, PLAINTIFF VERSUS JOSEPH CHARLES TAVERNA, III, DEFENDANT NO. PLEAS 03-1435 CIVIL TERM co~c~ DECREE IN DIVORCE DECREED THAT AND CHRISTINA MARIE TAVERNA JOSEPH C~LARLES TAVERNA, III ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH~S ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE ATTEST: J. --~~:~ P R OTH O NOTArY