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HomeMy WebLinkAbout07-2206. .. CONNIE TIDD, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE JAMES TIDD, : Defendant : N0.07- aa0(o CIVIL TERM 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 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 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 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. CONNIE TIDD, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE JAMES TIDD, ~~~~ Defendant : NO.07- CIVIL TERM DIVORCE COMPLAINT The plaintiff, Connie Tidd, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. § 3301(d) OF THE DIVORCE CODE Plaintiff is Connie Tidd, who currently resides at 147 E North Street, Apartment 2, Carlisle, Cumberland County, PA 17013 since March 1, 2007. 2. Defendant is James Tidd, who currently resides at 1343 Oak Grove Avenue, Rear, Steubenville, Jefferson County, OH 43952 since November of 2005. 3. Plaintiff has been a bona 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 August 19, 2000 at Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since March of 2005. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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 of divorce. Candace McCauley " Certified Legal Intern ROBE T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing 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 ' ~ D `7 Plaintiff ~' ~~ Connie Tidd '~ ~~; ~•~ = ~ r-~ -- ._> ->~ --~ = ~ :~ -r~ - ~ ~ : +-. . ~~~ -- -~ ''-,i _'.~` ~ ; Connie Tidd, Plaintiff v. James Tidd, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE N0.07- o?o1p(o CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Connie Tidd, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date 4 ~ ~ ~ ~ (~ ~T Candace McCauley Certified Legal Intern ROBER E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C. ? ~ C~ ~ ~ .. _., _ ~_ ~. -- --- --,i`; ;~'-, G.~ ~.~ _~: -- -r. _. _ : C. _: i; " ~,;L -G CONNIE TIDD, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE JAMES TIDD, : Defendant : NO.07- aa0(o 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 (20) 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 in March of 2005, and have continued to live separate and apart for a period of at least 2 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 unsworn falsification to authorities. Date ~=~~ ~-~1'l_-~~A c.~ , ~ C~S~.. Conroe Tidd Plaintiff S'^-7 i.~ F c.:~ ~"s1 a" .~^ ' '~~ i ':. i' .:; ii i `'fit .. _~ ~ ~~° CONNIE TIDD, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE JAMES TIDD, Defendant : N0.07-2206 CIVIL TERM CERTIFICATE OF SERVICE I, Candace McCauley, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the divorce complaint on James Tidd, residing at 1343 Oak Grove Avenue, Rear, Steubenville, Ohio 43952, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by James Tidd on the 21st day of Apri12007 as evidenced by the attached green card. C ~~ Candace Mc auley Certified Legal Intern Meg 'esmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r ~_ C;': ~.-: ', F~~; ~. --! ^ so t!~ wi- o~n nrMtrn ~ olyd ~ ~ ~ A~ ~ cand b !fN book d ~ n a a~ lMr thont 1~ 1~ - a. ~ri~a. 4Q~'rtL~'t,- l~r sz~t~ Sf~~b~nvl~-i a~ Ja ~39.~.~ 2. Arr~_~..~,,...~,e. ~( O /1grK Q ~ by (~Mrd N~n~1 G. ~ rsi Q Ir d.~ry ae~wa ~ ~ ~ ~. ~- Y ads bMkiw: D No ,~ ~~ o O wau.a ~ ~ c ~Of ~°'d,ana~e a: as.a~cced n rF,caa Fe.~ ~'~ N c-_~ ~..~ .''.°: ~. ... y 1` +a ~~ 705 X390 0003 2632 556 PS Form 3811, February 2004 - 102595-02-M-1540 _1_I ~~ t,lr=-- '°-t :T ~ t~ ~_~ `':~ ti 7 '.n~ :~ --C Connie Tidd, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW DIVORCE James Tidd, Defendant : NO: 07-2206 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file acounter-affidavit to the § 3301(d) affidavit. Therefore, on or after June 12, 2007, the other party 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 acounter-affidavit by the above date, the court can enter a final decree in divorce. Acounter-affidavit which you may file with the prothonotary of the court is attached to this notice. 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. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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. ~ ~ `.~ ~~~ ~ ~~ !'~'~.. Cf? ~° N -'G _~ :. "" ~ °. -, ~ -?- i ~ ~ ~G tai G - Connie Tidd, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW DIVORCE James Tidd, : Defendant : NO: 07-2206 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 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 party. 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 unsworn falsification to authorities. Date James Tidd, Defendant ~ ~ O G _._, ~~` ~ ~~ ~~:. ~ ~?p ~ -~ ~ .` ~ . ~•~' .~ ~ ~ Connie Tidd, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW v. : IN DIVORCE James Tidd, Defendant : No. 07-2206 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: served on defendant by United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by James Tidd, at 1343 Oak Grove Avenue, Rear, Steubenville, Ohio 43952 on Apri121, 2007. 3. Date of execution of the affidavit required by §3301 (d) of the Divorce Code: April 19, 2007; Date of filing of the plaintiffls affidavit: Apri121, 2007; Date of service of the plaintiffls affidavit upon the defendant: Apri121, 2007. 4. Related claims pending: none. 5. Date and manner of service of the notice of intention to file praecipe a copy of which is attached: served on defendant by United States mail, postage prepaid addressed to James Tidd at 1343 Oak Grove Avenue, Rear, Steubenville, Ohio 43952 on May 22, 2007 Z,~ ~oa~ D Holly O. ~ ughn Certified Legal Intern MeganR2iesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff rv ~ O ~~ ~ E'i i `- ~ IJ _ ~. -~; _:: ~: CT C7 r~ ~_ te ? ~ l. ~~ ~ C:. 1 N THE COURT OF COMMON PLEAS + OF CUMBERLAND COUNTY + + STATE OF ~ PENNA. CONNIE TIDD, _y, 2206 2007 + + Plaintiff N O. + + + + + VERSUS + + JAMES TIDD, Defendant + + + DECREE IN DIVORCE + ~t~.'o~ ~o. /~'1 . + AND NOW, , ~ IT IS ORDERED AND + CONNIE TIDD + DECREED THAT PLAINTIFF, + AND JAMES TIDD 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; + NONE + + + + + BY T + ~ ATTEST: J. + + + ~~ j' PROTHONOTARY ~.. ~.: Connie Tidd, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE James Tidd, Defendant : No. 07-2206 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on July 9, 2007 hereby elects to retake and hereafter use her previous name of Connie Sue Adams, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As: Connie Tidd onnie Sue Adams COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the ~~~' day of ~ ~ , 2007, before me, a Notary Public, personally appeared Brandy Smiley, 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 THEREOF, I have hereunto set my hand and Notarial Seal. __ ~ Notarlsl seal Laurie L. Wolin Notary Publla N TAR PUBL Carlisle Boi+o. Cumberland Coontp My Cwami:tia~ Bspira~ Feb.14, Zo10 N ~ ~ { _d O r--' ~ ! 2~. ' ~ . •- ~ Z ~ ~ - :: c-~ na T.._t , C~ f 'Z7 ~T'7 F`; 1 ~~ S`..., ~ ~ 1 } ~ ~~4~ _. a ~ .^ •4i ~ ~i~ \ ~ ~ ~ ~ yy T / •q V ~ / `~ J` 1, ~:. . '4 t ~'`~. f ~ ~ {w; , h Tf F Ri}i N~v R • ~.t'~ 1 .5 ~: r~•..~- (V..• a ~~.