HomeMy WebLinkAbout03-3075IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Vo
Plaintiff :
:No. O3- 3075
~o~ c~.~o~,~ -~ : IN DIVORCE
Defendant :
Civil Tern~
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HA VE 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 properly 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, 1 Courthouse Square, 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 LA'WYER 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) ..2~9~3166
Ee han demandado a usted a la cone. Si usted quiere defenderse en contra estas demandas
expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la feeha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en
contra suya.
Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una
orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en
la peticion do demanda. USTED PUEDE PERI)ER DINERO O PROPIENDADES O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Plaintiff
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 200
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE
, who currently resides at
who currently resides at
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on -~u~t ~ ,qetq at
5. The marriage is irretrievably broken, and the parties separated on
6. There have been no prior actions of divorce or annulment between the parities.
7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
given in Paragraph 2 above.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
Date Plaintiff, Pro Se
I, ~) t~ ~. e~ ~.~n t ~ t--e- ~- , verify that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 Pa. C.S. §4904.
Date mlai~nfi~
Assisted by:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Plaintiff
vii.
Defendant :
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 20o -3
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION TO PROCEED IN FORMA PAUPERIS
The Petitioner, ~ ~ A,~ ae~ c~keorx,5,C,~'~ , is the Plaintiffin this action. On
her behalf, I, Joan Carey, attorney for MidPenn Legal Services, do hereby certify that the
Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPerm
Legal Services is assisting the Petitioner in filing a divorce casepro se. The Petitioner's
Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner
requests leave to proceed without payment of fees or costs.
Respectfully sub~
Pro Se Divorce Clinic
8 Irvine Row
Carlisle, PA 17013
VS.
Plaintiff
Defendants
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am theP/~, ,.% ,e~ 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.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of
litigation.
3. ! represent that the information below relating to my abitity to pay the fees and costs is true and
cOlTeCt.
(a) Name: t~3~*- c~k~°~$~'~'
Address: Il't*- ~t~,o4 ffo44o~, ~zd
(b) Social Security Number: v1 g- *'o~*"l~-qq
If you are presently employed, state
Employer: mt,,, ~o~o~.r
Address: c ~,-t,51 ~-.
Salary or wages per month:
Type of work: 51~---I-
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:
Other self-employment: ~//
Interest:
Dividends:
Pension and annuities: d/-4
Social Security benefits: ~[/
Support payments:
Disability payments:
Unemployment compensation and /ti/.,{
supplemental benefits:
Workman's compensation:
Public Assistance:
Other:
(d) Other contributions to household support
(Wife)(I-Iusband) Name:
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
(e) Property owned
Cash:
Checking Account: O
Savings Account: O
Certificates of Deposit:
Real Estate (including home):
Motor vehicle: Make_2~_d~ Year
Cost Amount owed
Stocks; bonds: o
Other: o
(f) Debts and obligations~
Mortgage: o
Loans; o
Monthly Expenses: o
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: t/oa ~
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 here'm.
5. I verify that the statements made in this affidavit are true and correct. ! understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unswom falsification to
authorities.
Date: ~- ~-o5
Wayne Chronister,
Plaintiff
VS.
Susan Chronister,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 03- 3075 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I ~ ',.~_~ tO ~-~"x ~'~ ~ 6"K'e.~-,, , accepted service of a tree and correct copy of the
Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904,
relating to unswom falsification to authorities.
Susan Chronister, Defendant
Wayne Chronister,
Plaintiff
VS.
Susan Chronister,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 03- 3075 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE
I, CO~En < C.~,.,-e,q ~-, do hereby swear that I have served
~.X/~&~3 C_~3~'x.~-"eog:_ with a Divorce Complaint under Section 3301(c) of the
Divorce Code by personally handing her a copy at
t~3~5~X~,- (Street&tuber and Address)
(City) (State) (Zip)
at [ , /~ _]~_.m. onthe ? day of ~--~l~ ,200
(Time) (Date) (Month) ~'~ (Year)
I, [~t 3..4~ ,~ ~ c~L~3~xxq ~ q ~-
(Nme bfperson who performed service)
, verify that the statements made in this
Affidavit of Service is tree and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date: 7-9-~ Signature:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~¢ , PENNA.
WAYNE CHRONISTER
PLAINTIFF
VERSUS
SUSAN CHRONISTER
DEFENDANT
N O. 03-3075
CIVIL
DECREE iN
DIVORCE
DECREED THAT WAYNE CHRONISTER
It IS ORDERED AND
, PLAINTIFF,
AND SUSAN CHRONISTER , 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;
ALL CLAIMS HAVE BEEN RESOLVED.
t~~~ r, J,
- /ROT.ONOTARY