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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF t; : PENNA.
KATHLENE H VARNER
PLAINTIFF
Versus
DOUGLAS M VARNER
DEFENDANT
DECREE I
}- DI VORCE
AND NOW, ... Sc.? 1 c »..?cT.. Z '1?.... • 191.`
decreed that ...........KATHLENE H VARNER
................
and ..................... DOUGLAS .......... M VARNER
......
are divorced from the bonds of matrimony.
The court retains jurisdiction of the followi
been raised of record in this action for which a f
been entered;
NONE
.....................................................
. ..................................
By The Ccl:
Attest:
3595 CIVIL 1999
.................
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it is ordered and
, plaintiff, ••,
......... , defendant,
ig claims which have
nal order has not yet
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.....................
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Prothonotary
1
Kathleen H. Varner,
Plaintiff
V.
Douglas M. Varner, Sr.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 99-3595 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:
Ground for divorce: irretrievable breakdown under §3301(d) of the Divorce Code.
2. Date and manner of service of the complaint: The Family Law Clinic mailed the
divorce complaint to the defendant by certified U.S. Mail. The green return receipt was signed
by the defendant and returned to the Clinic on June 18'", 1999. A vertification of service was filed
with the court on June 23°', 1999.
3. (a) Date of execution of the affidavit required by §3301(d) of the Divorce Code:
June 22, 1999.
23, 1999. (b) Date of filing and service of the plaintiffs affidavit upon the respondent: June
.
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: The Family Law Clinic mailed a true copy of the notice of
intention to file praecipe to transmit record to the defendant by placing the same in the U.S. Mail,
on a 20th y f Wui--'?99, addressed as follows: 461 North Pitt Street, Carlisle, PA 17013.
lk? Tl Donald Marritz Jef*e'. Addis
Supervising Attorney Certified Legal Intern for the Plaintiff
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968 Date: L 1
Kathlene H. Varner,
Plaintiff
V.
Douglas M. Varner, Sr.,
Defendant
TO: Douglas M. Varner, Sr.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 99-3595 CIVIL TERM
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the plaintiff's affidavit. Therefore, on or after , August 13, 1999, the
plaintiff 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. 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.
A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY
OF THE COURT IS ATTACHED TO THIS NOTICE.
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
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.
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Kathlene H. Varner : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
: DIVORCE
Douglas M. Varner, Sr. -2S9S
Defendant : NO. 99- CIVIL TERM
COMPLAINT
The plaintiff, Kathlene H. Varner, 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 Kathlene H. Varner, who currently resides at 1526 Holly Pike,
Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Douglas M. Varner, Sr., who currently resides at 461 North Pitt
Street, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff has been bona a 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 October 18, 1985, in Cumberland
County, Pennsylvania.
5. Plaintiff and defendant have lived separate and apart since August 8, 1990.
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 (o ?y q9
Je S. Addis
Student Attorney
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THOMAS M. PLA
ROBERT E. RAINS
KATHERINE C. PEARSON
Supervising Attorney
DONALD MARRITZ
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
7171240-5204
VERIFICATION
I verify that the statements made in the foregoing 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:
athleen H. Vamer
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Kathlene H. Varner,
Plaintiff
V.
Douglas M. Varner, Sr.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
NO. 99- 3S_?S CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERi
To the Prothonotary:
Kindly allow Kathlene H. Varner, Plaintiff, to proceed in forma pauperis.
I, Jeffrey S. Addis, of the Family Law Clinic, Certified Legal Intem for the parry
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.
Date: t'o 114111
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
THOMAS M. PLACE
KATHERINE C. PEARSON
Supervising Attorney
DONALD MARRITZ
Staff Attorney
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Kathlene H. Varner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
Douglas M. Varner, Sr., yg?
Defendant : NO. 99- 3 CIVIL TERM
AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE
TO PROCEED IN FORMA PAUPERI
1. I am the Plaintiff in the above matter and because of my financial condition am
unable 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: Kathlene Vamer
Address: 1526 Holly Pike, Carlisle PA 17013
Social Security No.: 196-48-3305
(b) Employment
If you are presently employed, state
Employer:
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: May 1997
Salary or wages per month: $1061 per month, gross
Type of work: nurse's aid
(c) Other income within the past twelve months
Business or profession:
Other self-employment:
Interest:
Dividends:
Pension and annuities:
Social security benefits:
Support payments:
Disability payments:
Unemployment compensation and supplemental benefits:
Workman's compensation:
Public Assistance: application pending
Other:
(d) Other contributions to household support
Boyfriend's Name: Donald Stoerzinger
If your boyfriend is employed, state
Employer: Village Farm Landscaping
Salary or wages per month: $1213 per month, gross
Type of work: landscaping
Contributions from children:
Contributions from parents:
Other contributions:
(e) Property owned
Cash:
Checking account:
Savings account:
Certificates of deposit:
Real estate (including home):
Motor vehicle: 1983 Ford ranger
Stocks; bonds:
Other:
(f) Debts and obligations
Mortgage:
Rent: $200 per month
Loans:
Other: food - $200 per month gas - $80 per month
electric - $100 per month phone - $60 per month
satellite TV - $78 per month
(g) Persons dependent upon you for support
(Wife)(Husband) Name:
Children, if any:
Name: Age:
Other persons:
Name: Jeremy Stoerzinger (stays with plaintiff for three months in the summer)
Relationship: boyfriend's son
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.
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:9 Petitioner.
Kathlene H. Varner
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Kathleen H. Varner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
Douglas M. Varner, Sr.,
Defendant : NO. 99-3595 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 on August 8, 1990, 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 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 ?9
Kathlene H. Vamer
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Kathleen H. Varner : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
V. : IN DIVORCE
Douglas M. Varner, Sr.
Defendant : NO.99-3595 CIVIL TERM
VERIFICATION OF SERVICE
Understanding that the making of any false statement would subject Jeffrey S. Addis to
the penalties of 18 Pa. C.S. §4904 (relating to unworn falsification to authorities), the
undersigned verifies that Jeffrey S. Addis mailed a true copy of the divorce complaint on the
Defendant by placing the same in the U.S. Mail, certified no. 332848789, restricted delivery,
return receipt requested, postage prepaid, on the 14th day of June, 1999, addressed as follows:
461 North Pitt Street
Carlisle, PA
17013
Sender's receipt no.Z332848789 is attached hereto and incorporated by reference.
On the 18th day of June, 1999, green return receipt no. Z332848789 was delivered to the
Family Law Clinic, bearing the signature Douglas M. Varner and showing a date of service of
June 17th, 1999. The return receipt is attached hereto and incorporated by reference.
Dated:
d
effrey S. Addis
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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Kathlene H. Varner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : IN DIVORCE
Douglas M. Varner Sr.,
Defendant : NO. 99-3595 CIVIL TERM
CERTIFICATE OF SERVICE
Understanding that making any false statement would subject me to penalties of 18 Pa.
C.S. §4904 (relating to unworn falsification to authorities), the undersigned verifies that I mailed
a copy of the Notice of Intention to Request Entry of Divorce Decree to the Defendant and the
Defendant's Counter-Affidavit, both of which are attached hereto, by placing the same in the U.S.
Mail, on the 20th day of July, 1999, addressed as follows:
Mr. Douglas M. Varner, Sr.
461 North Pitt St.
Carlisle, PA 17013
J r . Addis
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
Dated: q 12,41 Ci I
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Kathlene H. Varner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
: IN DIVORCE
Douglas M. Varner, Sr.,
Defendant : NO. 99-3595 CIVIL TERM
TO: Douglas M. Varner, Sr.
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the plaintiff's affidavit. Therefore, on or after , August 13, 1999, the
plaintiff 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. 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.
A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY
OF THE COURT IS ATTACHED TO THIS NOTICE.
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
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.
Kathlene H. Varner, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN DIVORCE
Douglas M. Varner, Sr.,
Defendant NO. 99-3595 CIVIL TERM
DEFENDANT'S C.QUNTEg_AFFyDAyIT UNDER §3301(d)
OF THE. DIVOR . COD F
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 parry. 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 unworn
falsification to authorities.
Date
Douglas M. Varner, Sr.
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 A4.t file this counter-affidavit.
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Kathlene H. Varner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : IN DIVORCE
Douglas M. Varner Sr.,
Defendant : NO. 99-3595 CIVIL TERM
CERTIFICATE OF SERVICE
Understanding that making any false statement would subject me to penalties of 18 Pa.
C.S. §4904 (relating to unworn falsification to authorities), the undersigned verifies that I [nailed
a copy of the Praecipe to Transmit the Record and the Vital Statistics Form to the Defendant by
placing the same in the U.S. Mail, on the 24th day of September, 1999, addressed as follows:
Mr. Douglas M. Varner, Sr.
461 North Pitt St.
Carlisle, PA 17013
Je re S. Addis
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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Kathlene H. Varner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
V. : IN DIVORCE
Douglas M. Varner Sr.,
Defendant : NO. 99-3595 CIVIL TERM
CERTIFICATE OF SERVICE
Understanding that making any false statement would subject me to penalties of 18 Pa.
C.S. §4904 (relating to unworn falsification to authorities), the undersigned verifies that I
mailed a copy of the Plaintiff's Affidavit to the Defendant by placing the same in the U.S. Mail,
on the 23rd day of June, 1999, addressed as follows:
Mr. Douglas M. Varner, Sr.
461 North Pitt St.
Carlisle, PA 17013
J fre . Addis
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
Dated: 23 9
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Kathlene H. Varner, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN DIVORCE
Douglas M. Varner, Sr.,
Defendant NO. 99-3595 CIVIL TERM
NOTICE OF ELECTION TO RETAKE, FORMED NAME
Notice is hereby given that the Plaintiff in the above matter, having been granted divorced
from the bonds of matrimony on the 28" day of September, 1999, hereby elects to retake and
hereafter use her previous name of Adams, and gives this written notice avowing her intention to
do so pursuant to the provisions of 54 Pa. C.S;'7
.Kathlene H. Varner
Wishes To Be Known As:
Kathlene H. Adams
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND SS,
On the t??day of 19', before me, a Notary Public, personally appeared
Kathlene H. Varner, known to me to be the person whose name is subscribed to the within
document, and acknowledged that she executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal.
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