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HomeMy WebLinkAbout03-3077IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION o LAW Plaintiff : : No. O3- V. Defendant : Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS YOUHA FE 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 ammlment may be entcrcd against you by thc 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, 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 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) ¢4973166 Ee han demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentor una aporiencia 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 torte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI US"lED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO 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 Defendan/] : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 20o~,- JoV~ : CIVIL ACTION - LAW : : IN DIVORCE COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiffis/~CCCk I. ~eCL~k'Lk~ , who cu~ently resides at ~mberland Count, Pe~sylvania. 2. Defendant who cun'ently resides at 3. Plaintiff has been a bona fide resident of the Co~onwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff' and Defendant were married on ~¢~,~th~2~c__ ~) 5. The manage is i~etrievably broken, and ~e p~es separated on 6. There have been no prior actions of divorce or ~ulment be~een the parities. at 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. Plaintiffhas been advised of the availability of counseling and that Plaintiff may have the fight to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date , 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 Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243 -9400 vii. Defendant ': : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 200 : CIVIL ACTION - LAW : 1N DIVORCE PETITION TO PROCEED 1N FORMA PAUPERIS The Petitioner, ~(-CO. L. V~)~ [-~L/ , is the Plaintiffin this action. On her behalf, I, Joan Carey, attorney for MidPenn Legal S~ervices, do hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn 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 submitted: Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 Plaintiff VS. Defendants : IN TI-[E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM AFFIDAVIT IN SUPPORT OF PETITION FOR LE^W TO PROCEED IN FO~ PAUPmS am the COt; Cc~i~-'in the above matter and because of my financial condition am unable to pay 1. I 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 hfigafion. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. C.~,~r ~) Soci~ S~u~ty Numbs: If you ~e presently employed, s~te Employer: Salary or wages per month: [X3[/q Type of work: ~,~//2t If you are presently unemployed, state ~,ateof,ast~mployment: ¢0% ~OO3 Salm-y or wages per month: ~ (s:~'0° ~' Type of work: pceCo-roJ-; r (e) Other income within the past twelve months Business or profession: Other self-employment: Interest: ~ [ I~ Dividends: ~q ] ~ Pension and annuities: Social Security benefits: Support payments: ~ 30 Disabi~ paymenB: ~/~ Unemployment com~nsafion supplemenm benefits: ~/~ World's compensation: Pubhc Assismce: N/~ Other: (d) Other conffibufions to household suppoa If your ~usb~d) (wife) is employS, state Employer: ~ ~O~ ~ S~ or wages per month: Type of work: Conffibutions from c~ldren: (e) Property owned Cash: Checking Account: ~ O. Savings Account: ~/0. Certificates of Deposit: Real Estate (including home): /~,J/~ Motor vehicle: Make ~_~__ Year Cost /~J//q Amount owed Stocks; bonds: ~/~ Other: (f) Debts and obligations Mortgage: ~,}/~ Rent: Loans: Monthly Expenses: (g) Persons dependent upon you for support (Wife) (Husband) Name: ~J/~ Children, if any: Name: ~--__~O~CCe~+JC k'l)e, oJfte.~ 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 tree 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:~tme [0, ~OO~ Arra L. Yeakley, Plaintiff VS. Daniel D. Yealdey, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUI~rY PENNSYLVANIA No. 03- 3077 CIWL TERM : IN DIVORCE AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE I, ~f~ CO- L.. ~'),Q_~"/x[ ~_~, do hereby swear that I have served ~,,,~CxghiC[ '~o ~)~-N~U~O ~withaDivorce Complaint under Section 3301(c) ofthe Divorce Code by personally handing him a copy at (Street, Number and Address) - I ~(City) O (State) 'd (Zip) at ~',~,5 ~_.m. ontheE~O~r~d~r~ dayof~--UL[[J~ (Time) T (Date)k3 (Month) (~qameofpersonwhope ed¢ ' ) ,200 (Year) , verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Arra L. Yeakley, Plaintiff VS. Daniel D. Yeakley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03- 3077 CIVIL T~RM IN DIVORCE ACCEPTANCE OF SERVICE I [.~C07/~[ ]~/ I]?°.X3~[(~/~)/ , 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. Dat~ [ angel D. Yeakley, Defend~a~.~ Arra L. Yeakley, Plaintiff VS. Daniel D. Yeakley, Defendant WAIV~ DIV( 1. I consent to 2. I understanC fees or expe 3. I understanc and that a c, Prothonotar I verify tha false statem~ to unswom Date: IN THE COURT or COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 03- 3077 C~VIL TERM IN DIVORCE R OF NOTICE OF INTENTION TO REQUEST ENTRY OF A )RCE DECREE UNDER §3301(c) OF THE DWORCE CODE the entry of a fmal decree of divorce without notice. that I may lose rights concerning alimony, division of property, lawyer's ases ifI do not claim them before a divorce is granted. that I will not be divorced until a divorce decree is entered by the Court ~py of the decree will be sent to me imrnediately after it is filed with the tatements made in this affidavit are tree and correct. I understand that '.nts herein are made subject to the penakies of 18 Pa.C.S. §4904 relating alsification to authorities. Daniel D. Yeakley, Defendant"--~ Arm L. Yealdey, Plaintiff VS. Daniel D. Yeakley, Defendant 1. A complain 2003. 2. The marriag elapsed fi.on 3. I consent to intention to I verify that the false statements relating to unsw Date: t O/t ~). / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03- 3077 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT in divorce under §3301(c) of the Divorce Code was filed on June 30, e of plaintiff and defendant is irretrievably broken, and ninety days have the date of filing and service of the Complaint. Ihe entry of a final decree of divorce after service of notice of · equest entry of divorce. statements made in this affidavit are true and correct. I understand that herein are made subject to the penalties of 18 Pa.C.S. Section 4904 ~[~J~rn falsificatiOnsignature:tO authorities.0~~~a~' ~/r/ ~(22~ ~ t ~/~/~~ Daniel D Yeakley, Defend~}~ Arra L. Yeakley, Plaintiff VS. Daniel D. Yeakley, Defendant WAIV[ DIV( 1. I consent to 2. I understand fees or expe 3. I understand and that a o Prothonotav I verify that false statem~ to unswom Date:~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 03- 3077 CIVIL TERM IN DIVORCE R OF NOTICE OF INTENTION TO REQUEST ENTRY OF A )RCE DECREE UNDER §3301(c) OF THE DIVORCE CODE the entry of a final decree of divorce without notice. that I may lose rights concerning alimony, division of property, lawyer's ases if I do not claim them before a divorce is granted. that I will not be divorced until a divorce decree is entered by the Court ~py of the decree will be sent to me immediately after it is filed with the tatements made in this affidavit are tree and correct. I understand that nts herein are made subject to the penalties of 18 Pa.C.S. §4904 relating ~lsification to authorities. Arr~ L. Yeakley, q~intiff ~' Arra L. Yealdey, Plaintiff VS. Daniel D. Yeakley, Defendant 1. A complain 2003. 2. The marriag elapsed fi.on 3. I consent to intention to I verify that the false statements relating to unsw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03- 3077 CIWL TERM IN DIVORCE AFFIDAVIT OF CONSENT in divorce under §3301(c) of the Divorce Code was filed on June 30, e of plaintiff and defendant is irretrievably broken, and ninety days have the date of filing and service of the Complaint. the entry of a final decree of divorce after service of notice of :equest entry of divorce. statements made in this affidavit are tree and correct. I understand that herein are made subject to the penalties of 18 Pa.C.S. Section 4904 >m falsification to authorities. Signature: ~d.~,~ ~, 0~~t - a L. Yeakley, l~aintiff d Arra L. Yeakley, Plaintiff VS. Daniel D. Yeakley, Defendant To The Prothonotary: Transmit the entry of a divorce de 1. Ground ft Divome Code. Date and i defendant the I Service was fil 2. Complete e (a) Date of ex the Divorce Code: by (b)(1) Date of of the Divome Code: (2) Date ol 3. Related clai IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUI,rrY PENNSYLVANIA : NO. 03- 3077 CIVrL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD :cord, together with the following information, to the Court for ee ~ divorce: Irretrievable breakdown under Section 3301(c) of the ianner of service of the Complaint: Plaintiffpersonally handed the ~ivorce Complaint on July 8, 2003. An Affidavit of Service For Personal :d with this Court on July 17, 2003. [ther paragraph (a) or (b). ,~cution of the Affidavit of Consent requh'ed by Section 3301(c) of )laintiff, October 12, 2003; by Defendant, October 12, 2003. execution of the Plaintiff,s Affidavit required by Section 3301(d) ~/A filing and service of Plaintiff's Affidavit upon Defendant: N/A ns pending: There are no outstanding claims IN THE ARRA L. YEAKI PLAI5 VEF DANIEL D. YEA DEFE AND NOW DECREED THAT AND DANI ARE D~VORCED FI THE COUrt ri BEEN RAISED OF YET BEEN ENTER COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. EY TIFF SUS KLEY DANT DECREE IN DIVORCE N o. 03-3077 CIVIL ARRA L. YEAKLEY L D. YEAKLEY ~OM THE BONDS OF MATRIMONY. __., IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ALL CLAIM HAVE BEEN RESOLVED. BY,.....~ ~"/,~t · ,,~/THE COURT: ATT/~: PROTHONOTARY ;TAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT ED;