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Home My WebLink About00-07947a IN THE COURT OF COMMON PLEAS JENNIU M M. Il(1NN M, VERSUS RONALD L. DONNELL, DEGREE IN DIVORCE AND NOW, 2001 IT IS ORDERED AND DECREED THAT JENNIFER M. DONNELL , PLAINTIFF, AND FMALD L. DONNELL 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; No. 00 - 7947 ATTEST: Q J. PROTHONOTARY e ? t ?? ? ?? JENNIFER M. DONNELL Plaintiff v. RONALD L. DONNELL Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 00-7947 CIVIL TERM PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: On November 14, 2000, the defendant was served by U. S. Mail, Certified, Restricted Delivery, return receipt requested, postage prepaid. 3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code: November 2, 2000; Date of filing and service of the plaintiffs affidavit upon the respondent: Filed on November 9, 2000. Served on November 14, 2000. 4. Related claims pending: NONE. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: November 13, 2000 by first class U.S. Mail. ? ?yZiL R. Brad Balaban Certified Intern for Plaintiff ROBEP.TZ RAINS THOMAS M. PLACE TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 C) G 7 C - ;a C -71 Rpm -C - ?'J V:?'ft .. .? _ Few`r=€su,.,vw.°,rmv?ga'm59eamr?'m...aaze?am?aasse?ni JENNIFER M. DONNELL, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE RONALD L. DONNELL, SR., Defendant :NO. 00- 7 9 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. 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 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. JENNIFER M. DONNELL, Plaintiff V. RONALD L. DONNELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 00- 79y'7 CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. H 3301(d) OF THE DIVORCE CODE The plaintiff, Jennifer M. Donnell, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Jennifer M. Donnell, who currently resides at 2330 Dusty Lane, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant is Ronald L. Donnell, Sr., who currently resides at 17 North 7' Avenue, Coatesville, Pennsylvania, 19320. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on August 17, 1991, in Parksburg, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since June, 1996. 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 or defendant 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 of divorce dissolving the marriage. Date k\-2-'®O rnk-KKN?C??• 1xW p Melinda Davis Certified Legal Intern UK, THOMA M. PL CE ROBERT E. RAINS Supervising Attorney TERI L. HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 717/243-2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me tot he penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date &- 2---o v Loee?l aintifi O, , GUI;iU' l?,14- v' PE%SYL,IANA JENNIFER M. DONNELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE RONALD L. DONNELL, SR., Defendant : NO. 00- 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 admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in June 1996, and have continued to live separate and apart for a period of almost four and a half (41/2) 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 unworn falsification to authorities. Date / a ; ennife . Donnell ul -Q 6* OZ C`?ft'?FEN;?SYi `1AN1A 1 G= 'J t1 C J e JENNIFER M. DONNELL, Plaintiff V. RONALD L. DONNELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 00-7947 CIVIL TERM CERTIFICATE OF SERVICE I, Melinda A. Davis, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Ronald L. Donnell, Sr., residing at 17 N. 7' Ave., Coatesville, Pennsylvania, 19320 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Ronald L. Donnell, Sr., on the 14' day of November, 2000 as evidenced by his signature on the attached green card. Date: November 27, 2000 Mu4u. Q` Melinda A. Davis Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 -ID c7= - - -? :- 7- i ?' Ry - r - ; ,cf ¦ Corgplete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: L. ???ell Ooa lg-Svi'9k PA 2. 1999, ' A. Rimed `PleAse.erint Clearly) le. D& of t allvery C. StI , X ( ? Agent ? drassee D. I delivery address different from item 1? ? - , If YES, enter delivery address below: 3. S ice Type a/(,f ,Certified Mail ? Express Mall ? Registered )R;Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes Receipt 102595-99-M-1789 JENNIFER M. DONNELL, Plaintiff V. RONALD L. DONNELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 00-7947 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 January 8, 2000, the other parry 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 2 Liberty Avenue 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. 1. 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), (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. 2. Check either (a) or (b): () (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of 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. If I 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 delay. 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 unsworn falsification to authorities. Date NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. <? -71 e? :K ?_ .. _ _. _-sae W.ufls.•wH?riumrz»nm?wweAS?w??a??as!:nw:m ?v?.. ?cm=m ?,?u5a ?e?x=.,+raC?.av -an?rx;?e3wR;?4w!ae?ra,vm?a?q,. JENNIFER M. DONNELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : IN DIVORCE RONALD L. DONNELL, SR., Defendant : NO. 00-7947 CIVIL TERM PROOF OF SERVICE I, Teri Henning, hereby certify that the Family Law Clinic served a true and correct copy of the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code on Ronald L. Donnell, Sr., residing at 17 N. 7h Ave., Coatesville, Pennsylvania, 19320 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Ronald L. Donnell, Sr., on the 14' day of November, 2000 as evidenced by his signature on the green card, a copy of which is attached. Date: February 15, 2001 L enning Att ey for Plaintiff FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 m r7 ti ? 1 - _ - - - ?4R-tlR9 -?i???"?!z?aagrsi+fvsi? mw*z?nsa.U ? •3 _rqi u^ ? .??3?a ,ao ?+t?,.cnb'trs ,tiaw= tt€?mf4`TtR -?+' ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the back of the mailpiece, or on the from if space permits. 1. Article Addressed to: ?njAz-0 L. A r?E?e Il , l'7 Ai - Wh At%. Coa,kns '/k IAA /9'a C 2. A. C. Slgnaf u 13 Agent X L9zj!--jOAddre D. I delveryaddress different from item 17 ? If YES, enter delivery address bebw: l 73 3. 5 Ice Type v y S y-1' erfified Mail XG ? Express Mail ? Registered )Oetum Receipt for Merchandise ? Insured Mail O C.O.D. 4. Restricted Delivery? (Extra Fee) Yes PS Form 3511, July 1999 Domestic Retum Receipt x12595-99-M-1789 ? _ ? -. _ 'Tl _ ? 'C (i _ { ? _? - ?_ j;l ' Ci??' i-." J ?yC:: , C) ?? -_ ? _ ..? I A? I ??? ?Y-e ?. i??,] _ I ? --) _, _ -. ,- _ ._ ..iRM?'?9l9R0?N1a}£^..t 41e?5?.aYb1-: N' N..'.e14?9 Y _.. +r?s? F?i'Wh4IFtFl?'A?F'-?53?'0.W1?. JENNIFER M. DONNELL, Plaintiff V. RONALD L. DONNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 00 - 7947 CIVIL TERM CERTIFICATE OF SERVICE I, R. Brad Balaban, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit Record and Vital Statistics form on Ronald L. Donnell, Sr., residing at 17 N. 7' Ave., Coatesville, Pennsylvania, 19320 by depositing a copy of the same in the United States mail, First Class, this 15th day of February 2001. R. Brad Balaban Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. C-) c, PA 17013 Carlisle C- , 717-243-2968 C) Jennifer M. Donnell, Plaintiff V. Ronald L. Donnell, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 00- 79 `/'1 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Jennifer M. Donnell, Plaintiff, to proceed informa pauperis. I, Melinda Davis, Certified Legal Intern in the Family Law Clinic, for the party proceeding informa 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 parry's affidavit showing inability to pay the costs of litigation is attached hereto. Melinda A. Davis j Certified I Intern ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney TERI L. HENNING Staff Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Jennifer M. Donnell, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Ronald L. Donnell, Defendant NO. 00- CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS I amtheplaintiff inthe above matter andbecause of my financial condition amunable 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: Jennifer M. Donnell Address: 2330 Dusty Lane Social Security No.: 175-66-7360 (b) Employment If you are presently employed, state Employer: West Shore Rehab Address: Salary or wages per month: $800.00 Type of work: Nurse If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: $0 Other self-employment: Interest: Dividends: $0 Pension and annuities: $0 Social security benefits: $0 Support payments: $0 Disability payments: $0 Unemployment compensation and supplemental benefits: $0 Workman's compensation: $0 Public Assistance: $0 (d) Other contributions to household support (Wife)(Husband) Name: If your (wife)(husband) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: (e) Property owned Cash: $0 Checking account: $10 Savings account: $10 Certificates of deposit: Real estate (including home): None Motor vehicle: 1993 Buick Century 1990 Chevy Truck Cost, Amount Owed $0 Stocks; bonds: None Other: (f) Debts and obligations Mortgage: $0 Loans: $290.00 Other: DEBT AMOUNT Heat $50 Electric $100 Medical $40.00/Have past medical bills in the amount of $750.00 Car Insurance $165 Car Repairs $400 in repairs right now Transportation/Gas $100 Household Supplies $200 Food $400 Cable $75 Phone $50 Entertainment $75 Student Loans $290;Some of loans are in default. School Supplies/School Activities $25 Girl Scout/Boy Scout $80 for the year/$10 a month Babysitter $100 Past PPL bills $400 Clothes (summer, winter, shoes)/haircuts $125 Persons dependent upon you for support (Wife)(Husband) Name: Children, if any: Name: Age: Other persons: Name: Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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 unswom falsification to authorities. Date 11-1?-ev etitio r , C> C. l _ w r: f - . ; ' - y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. aO - 79q7 IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated a -a1- Of , hereby elects to resume the prior surname of Gavin , and gives this written notice avowing his / her intention pursuant to t provisions of 54 P.S. 704. Date: Signature S; ? e of name being resumed COMMONWEALTH OF PENNSYLVANIA ) Je''?G?K COUNTY OF On the 9 day of , 200Y before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL PROTHONOTARY; NOMY Mo CARLISLE CW08V X10 COoW fY COURYFfM W COMMISSION EXPIRES JMWiRY S,2010 Prothonotary or Notary Public A_1 y