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Home My WebLink About99-03851Q N 2 1 v j KIM V. LAROSA, Plaintiff V. PAUL J. LAROSA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 99-3851 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of October, 2002, it appearing that docket activity has occurred recently in the above-captioned case, the case is stricken from the purge list, and shall remain active. Henry F. Coyne, Esquire For the Plaintiff Court Administrator wcy ?5 Z Rv tha rrnirt_ KIM V. LaROSA, Plaintiff, VS. PAUL J. LaROSA, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 9q -s 3S I CIVIL TERM : IN 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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, 1 Courthouse Square, Carlisle, PA 17013 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, TO GET LEGAL HELP SHOULD CONTACT: Cumberland County Lager Referral Service 2 Liberty Avenue, Carlisle, Pennsylvania 1-(800)-990-9108 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 he court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. BY THE COURT: t Henry F. Coyne, Es ire Coyne & Coyne, P. 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa.. Supreme Ct. No. 06250 Attorney jar Plaintiff KIM V. LaROSA, Plaintiff, Vs. PAUL J. LaROSA, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 9'1- i ICIVILTERM IN DIVORCE COMPLAINT UNDER SECTIONS 3301(a)(6) OR 3301(c) OF THE DIVORCE CODE AND NOW comes the Plaintiff, KIM V. LaROSA, by her attorney, Henry F. Coyne, Esquire and files this Complaint In Divorce and avers the following in support thereof: 1. The Plaintiff, Kim V. LaRosa, is an adult individual residing at 301 2nd Street, West Fairview, Cumberland County, Pennsylvania. 2. The Defendant, Paul J. LaRosa, is an adult individual residing at the Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 12, 1986, at Harrisburg, Pennsylvania, and separated on or about February 11, 1999. 5. There have been no prior actions of divorce or for annulment between the parties except: None. 6. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 3 COUNT I - INDIGNITIES -- SECTION 3301(a)(61 Paragraphs I through 6 are incorporated herein by reference. 8. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree In Divorce, divorcing Plaintiff and Defendant. COUNT H - INDIGNITIES -- SECTION 3301(cl 9. Paragraphs Ithrough 8 are incorporated herein by reference. 10. The marriage is irretrievably broken. 11. Plaintiff has been advised of the availability of counseling and that the plaintiff may have the right to request that the Court require the parties to participate in counseling. Further, Plaintiff waives her right to request that the parties participate in marriage counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree In Divorce pursuant to Section 3301(c) to Plaintiff and Defendant as if they had never been married, Respectfully submitted: Dated: 13 L 2 0107 COYNE & COYNE, P.C. HENRY F. COYNJ, Esquire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiff The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verged subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated: ri c` - - ;_?. .. ; `_ , ? ;_: ? ; -? . . ?.. I ;; . L_ _-? - r\ U ?_r? r? HIM V. LaROSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. CIVIL TERM PAUL J. LaROSA, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To The Prothonotary: Kindly allow, KIM V. LaROSA, Plaintiff, to proceed in forma pauperis. I, Henry F. Coyne, Esquire, attorney for the party proceeding in forma pauoeris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Dated: ?, I QaM4 01. C? HENRY F. COYNE, E6QQ Coyne & Coyne, P.C. (6 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiff o'? i-? ?, KIM V. LaROSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. qq CIVIL TERM PAUL J. LaROSA, 6 Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. If you are presently employed, state 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) (b) '8' rO Employer. Aj 94 S Q7? hh /e_l Address: V ?rr O /? Salary or wages per month: Social Security Number: =?Q0 - 5-0 - "43,5- / Type of work:_ > -,/- a-e S 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 Other self-employment: Pension and annuities: Social Security Benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance- Other: (d) Other contributions to household support Husband If your husband is employed, state i Salary or wages per Type of work:- Contributions from (e) Property owned Cash: Checking Account:, Savings Account:_ Certificates of Dep, Real Estate (including home): Q Motor vehicle: Make U O L Year Cost Amount Owed^,?`" - U Stocks; (f) Debts and obligations Rent: Monthly Expenses: .30' 0'b ul (g) Persons dependent upon you for support Husband Children, if any: Age: 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 2 r v cv, I/IIII &?.L r „?, SHERIFF'S RETURN - REGULAR CASE NO: 1999-03851 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAROSA KIM V VS. LAROSA PAUL J DAVID MCKINNEY Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon LAROSA PAUL J the defendant, at 13:05 HOURS, on the 30th day of June 1999 at C C P 1101 CLAREMONT ROAD CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to PAUL J. LAROSA a true and attested copy of the NOTICE AND COMPLAINT IN together with DIVORCE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answ Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 omas ine, e i 006/01/1999 Sworn and subscribed to before me this ? day of 19? A.D. ?ro no a??y KIM V. LAROSA, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PAUL J. LAROSA, Defendant NO. 99-3851 CIVIL TERM ORDER OF COURT AND NOW, this 22" day of January, 2003, upon relation of the Cumberland County Prothonotary that the above-captioned case was erroneously placed on the 2002 purge list, when in fact the Defendant had died, the case is stricken from the 2002 purge list. BY THE COURT, Henry R. Coyne, Esq. 3901 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Ca?a? irwa? GuC . 113- o3 /-' :rc 03 P,:l 12: q o Cup` PENNSYI!Avj U'VTy