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HomeMy WebLinkAbout01-04325 IN-THE COURT OF COMMON PLEAS RHONNDA CLARK Plaintiff VERSUS WILLIAM M. CLARK Defendant N O. 01-4325 DECREE IN DIVORCE AND NOW, ~~;~ ~~ , ~~f, IT I5 ORDERED AND DECREED THAT Rhonnda Clark ,PLAINTIFF, AND William Clark ,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; Nothing pending. ,, ~~ I ~ .~ RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNA NO. 01-4325 CIVIL TERM CIVIL ACTION-LAW PRAECIPE TO TRANSMIT THE RECOR® To the Prothonotary: Transmit the record, together with the following information, to the court fox entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~(3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint July 27, 2001 by first class mail return receipt requested. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff November 4, 2001; by defendant December 4, 2001, 4. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: Decembe4 4, 2001. i `' '1 Date: December 13. 2001 Respectfully submitted, ABOM & KUTUL[~HIS, L.L.P. Jas n P. Kutulakis, Esquire A ' rney ID No. 77961 8 South Hanover Street Suite 204 Carlisle, PA 17013 Attorney for Plaintiff ,, G 0 V~ .~ c-, -, ~- - -,. _ --~ ~-~ -> ~~ __ __ z; _ ..- ~~.r -- _ :c. - -,- _~. ~.~- y ~_: :: ~° - _~ :,~ ~„ ~O i i '~ ~.-c~~a . ~ _ svm ~-s w , - :r,,. ~ rim :..:..,,: .. : ,- am= ~o-a~~m~".Ar_'~F9'~r RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO.bI-~4~~ CIVIL TERM CPJIL ACTION-LAW NOTICE TO DEFEND AND CLAIMS 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 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, One Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 Lawyer Referral Service 2 Liberty Street Carlisle, Pennsylvania 17013 (717) 249-3166 RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. CIVIL TERM CIVIL ACTION-LAW NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT You have been named as a Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with X3302 (c) or (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by 'the Court. A list of professional marriage counselors is available at the Cumberland County Courthouse, Cumberland County, Pennsylvania. You'xe advised that this list is kept as a convenience to you and you're not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ~~ , ~ _ _ RHONNDA L. CLARK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA vs. NO WILLIAM M. CLARK Defendant CIVIL ACTION-LAW COlO~IPLAINT 1. Plaintiff is Rhonnda L. Clark, who currently resides at 251 York Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is William M. Clark, is an adult individual, who currently resides at 113 Hope Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The Plaintiff has been a bona fide resident(s) in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 16, 1986, In Toledo, Lucas County, Ohio. 5. There have been no prior actions of divorce or fox annulment between the parties. 6. The Plaintiff in this action is not a member of the Armed forces. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to the divorce decree being handed down by the court. 9. The Plaintiff is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree in divorce. Respectfully submitted, Abom & Kutulakls, L.L.P. Date: July 16, 2001 son P. Kutulakis, Esquire ttorney I.D. No. 80411 Suite 204 8 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, hereby verify that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. X4904, relating to unsworn falsification to authorities. Date: ~,~,\. ~`~ C Q~ Rhonnda Clark ~S f~'p + --- ~ _ ^'COmplete items 1, 2, and 3. Also complete A. Received 6y (Please PNnt Cledyy_) B: Dafe or Delivery - item 4 if Restricted Delivery is de,;ired. (r,l (f1 ; ~„ [r ~ C ~{~~ •- 1 i(_ ^,Print your name and address on the reverse -~ ~ _ '.~ ~ thpt we can return the card to you. 4 S)igna~tu~re^~ rn~~ rn/ 3 ; :_- r ^ P~ttach this card to the back of the mailpiece, X UV.',-'~~-'~- ~ , l u Agent : ' or on the front if space permits. _ "~-'!7 Addressee - -- D. Is delivery address different tr~~Rem ? _ -es - 1. Article Addressed to: Ii VES, enter delivery atldress blow:=.,,P- No w~~t;a~, GarK * t iii, f-Dope ~ n,(~ ^7 I~~~1~A ~~~~Q S~ C'I't ~ IOO~ 3. S is -.... - -._"'S J J ~"e fi '~~`~ ~I TED _ -_ ^ Re e urn r mhandise " , ° ^ Ins Mail 4. Restric .:( 2Fge1„-.. ~.__ ®'V~S' ' i 2. Article Number-(Copy from service fa - - -- ~~ ~ - ~oa~ ~aao ooQ`~ rs~~ ~~ PS Form 3811, July 1999 - - Domestic Return Receipt 102595-oaM~0952 RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNA NO. D~"y3~~CIVIL TERM CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I, Jason P. Kutulakis, hereby certify that I served a true and correct copy of the Complaint Under Section 3301 (c) of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached receipt card. [attach green receipt card here) ~' Respectfully submitted, ABOM & KUTULASIS, L.L.P. }~ ~. Date: July 31. 2001 Ja~on P. Kutulakis, Esquire A orney I.D. No: 80411 8 S. Hanover Street Carlisle, PA 17013 Attorney for Plaint © n C'' ' C - r _ ya ~L7' Z ~A, _ ,~} i Q ~ ti ~~ Mf m. .... w-u,,,,~-v.. ~'nacy~~'~4 ass . ~aarx+s.~~~:~~ea~ ,..... '~ M RHONNDA L. CLARK : IN THE COURT OF COMMON Plaintiff :CUMBERLAND COUNTY, PENNA vs. NO. 01-4325 CIVIL TERM WILLIAM M. CLARK Defendant CIVIL ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on July 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein axe made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Date: ~'c - _ ! ~pv~rula~ ~ C.Q.~tatiA._~ Rhonnda L. Clark f ~, RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNA NO. 01-4325 CIVIL TERM CIVIL ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under 93301 (c) of the Divorce Code was filed on July 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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. 94904 relating to unsworn falsification to authorities. Date: y ~. • ~ (1/,.,c~-- r"' ~~`~-~- William M. Clark 0 C7 :~; ~ ~ Cw ~' J `". O riri -1 _ - d ' ' ` ~ n l~ -- E', -' _ _-. i~~ -F c_ , - _~ "~i r,_ =! v~ 3 ~5 fa x~mw f ~ ;:, ._r. a W .~,r,.rar ^~ sn,~r-=-~vR*~s,~s:[aasra+a^s~~~imYaeeLt.aaaTa.-. RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNA NO. 01-4325 CIVIL TERM CIVIL ACTION-LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will 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 false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: ~1rLl_o~ (~r,~,r.~. ~. c~a.~ Rhonnda L. Clark f7 4~7 l., "- -i J C: C~ _ r ." ~ i- -4 ..-. _, nl' ~' l_ ~.k ~~ ~' RHONNDA L. CLARK Plaintiff vs. WILLIAM M. CLARK Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNA NO. 01-4325 CIVIL TERM CIVIL ACTION-LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will 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 false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: L~ ~ Q C_, ~ ~ ln.C.lJ~- j'am`, \~'~' William M. Clark .. iJ f;? ~ C. r 'O C.Y, ~Si - - ~ e r ( 5 f~ C_ I` ~~.J ~ ~../ ~ e~ ~ll ~'^ `{ JY T £~) SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. ~4304.1(a)(3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBERS PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: 12/13/01 DOCKET NUMBER: 01-4325 PLAINTIFF/PETITIONER SS # 302-60-3281 NAME: Rhonnda L. Clark DEFENDANT/RESPONDENT SS # 228-98-9935 NAME: William M. Clark RHONNDA CLARK, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : OF CUMBERLAND COUNTY, PENNSYLVANI~~~ O ~ 200 V. : NO. al-~3~s'Civ;1 Term WILLIAM M. CLARK, :CIVIL ACTION -EQUITY Defendant/Respondent ORDER AND NOW, this day of 2006, upon consideration of Plaintiffs Petition for Special Relief, a RULE is hereby issued upon respondent, William M. Clazk, to show cause, if any he should have, why the relief requested in the attached petition should not be granted. RULE RETURNABLE within days of service of this Order and Petition upon William M. Clark. cc: Jane Adams, Esquire J. Hubert X. Gilroy, Esquire RHONNDA CLARK, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : OF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. ©i-432.~ Civil Term WILLIAM M. CLARK, :CIVIL ACTION Defendant/Respondent ORDER AND NOW, this day of hereon is scheduled for the A.M./P.M in Courtroom No. Carlisle, Pennsylvania. cc: Jane Adams, Esquire, for Plaintiff day of 2006, a hearing 200 at of the Cumberland County Courthouse in J. Hubert X. Gilroy, Esquire, for Defendant RHONNDA CLARK, Plaintiff/Petitioner V. WILLIAM M. CLARK, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.~1-t{3~Civi1 Term CIVIL ACTION PLAINITIFF'S PETITION FOR RELIEF 1. Plainfiff/Petitioner is Rhonnda Clark, of 32 Montesera Road, Carlisle, Cumberland County, Pa., 17013 2. Defendant/Respondent is William M. Clazk, of 113 Hope Drive, Boiling Springs, Cumberland County, Pa., 17007. 3. Plaintiff and Defendant were married on August 16, 1986. 4. During the course of the marriage, the parties acquired a home, located at 113 Hope Drive, Boiling Springs, Cumberland County, Pa. 17007. 5. The parties were divorced on December 17, 2001. 6. During the divorce, the parties did not enter into a marriage settlement agreement which provided for a disposition of the marital home, and the deed to the home and the loan obligation is still in joint names. 7. Plaintiff has been requesting that Defendant assist in obtaining an appraisal of the home since August 2005. 8. Defendant has not offered to cooperate with an appraisal of the home. 9. The parties have been unable to agree on the terms for an orderly distribution and partition of the home. WHEREFORE, Plaintiff requests that this Honorable Court enter an Order providing that the home be appraised and that Plaintiff receive payment for her portion of the equity in the home, as well as any other such relief as the Court may deem appropriate. Respectfully submitted, Date: ~ ~ ~ ~o Adams, Esquire vo. 79465 Guth Pitt St. sle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I 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 I8 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~ _ ~ ~_~ ~~ ~ C~- Rhonnda L. Clark, Plaintiff ^y '#}~5~ ~ '-'. .' 2a. -(' ,~ ; - w z,,.,, 'r~ <';; _ r 7- ~ 4_. :,~..~~ i 1 :- \ (fj At Q ~~ '9fl1_ Cg9AF_ 3~`~*:~Fet a-E.+ •, -:",- ..=e?m .arsn„-n aros rx a~at±ittq~kA.~i.F+~YZf RHONNDA CLARK, Plaintiff/Petitioner v. WILLLAM M. CLARK, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Ol - 4235 Civil Term FEB 012Q06„h~-~ CIVIL ACTION -EQUITY ~` ORDER AND NOW, this day of 2006, upon consideration of Plaintiffs Petition for Special Relief, a RULE is hereby issued upon respondent, William M. Clark, to show cause, if any he should have, why the relief requested in the attached petition should not be granted. RULE RETURNABLE within upon William M. Clark. cc: Jane Adams, Esquire, for Plaintiff days of service of this Order and Petition J. Hubert X. Gilroy, Esquire, for Defendant r~ RHONNDA CLARK, Plaintiff/Petitioner V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 4325 Civil Tenn WILLIAM M. CLARK, :CIVIL ACTION Defendant/Respondent ORDER AND NOW, this day of hereon is scheduled for the A.M./P.M in Courtroom No. Cazlisle, Pennsylvania. day of 2006, a hearing 200_, at of the Cumberland County Courthouse in J. cc: Jane Adams, Esquire, for Plaintiff Hubert X. Gilroy, Esquire, for Defendant RHONNDA CLARK, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : OF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. Ol - 4235 Civil Term WILLIAM M. CLARK, :CIVIL ACTION -EQUITY Defendant/Respondent ORDER AND NOW, this day of , 2006, upon consideration of Plaintiffs Petition for Special Relief, a RULE is hereby issued upon respondent, William M. Clazk, to show cause, if any he should have, why the relief requested in the attached petition should not be granted. RULE RETURNABLE within upon William M. Clazk. days of service of this Order and Petition J. cc: Jane Adams, Esquire, for Plaintiff Hubert X. Gilroy, Esquire, for Defendant r' ~,. RHONNDA CLARK, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01 - 4325 Civil Term WILLIAM M. CLARK, :CIVIL ACTION Defendant/Respondent ORDER AND NOW, this day of hereon is scheduled for the A.M./P.M in Courtroom No. Cazlisle, Pennsylvania. day of 2006, a hearing 200_, at of the Cumberland County Courthouse in J. cc: Jane Adams, Esquire, for Plaintiff Hubert X. Crilroy, Esquire, for Defendant