Loading...
HomeMy WebLinkAbout07-3261LAURA JEAN STINE, Plaintiff V. JAMIE MICHAEL STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 67-3,W 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. LAURA JEAN STINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. DIVORCE JAMIE MICHAEL STINE, Defendant NO.o7.3.?t/ CIVIL TERM DIVORCE COMPLAINT The plaintiff, Laura Jean Stine, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S W301(a)(6) 3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Laura Jean Stine, who currently resides at 102 West High Street, Carlisle, Cumberland County, Pennsylvania, 17013, since September 11, 2006. 2. Defendant is Jamie Michael Stine, who currently resides in Carlisle, Cumberland County, Pennsylvania, 17013,,at an unknown address. Defendant's last known mailing address was 37 Kerrs Avenue, Carlisle, Cumberland County, Pennsylvania, 17013. 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 March 4, 2004 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since September 11, 2006. 6. There have been no prior actions for divorce or for annulment between the parties. 7. Defendant has offered such indignities to the innocent and injured Plaintiff as to render Plaintiff's condition intolerable and life burdensome. 8. The marriage is irretrievably broken. 9. 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. Susan C. Plano Certified Legal Intern RO ER RAINS THOMAS M. PLACE ANNE MACDONALD-FOX 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 unworn falsification to \ authorities. Date Plaintiff Laura Jean Stine (") C N q f7 _J Co -C LAURA JEAN STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW IN DIVORCE JAMIE M. STINE, Defendant NO. 07 -39101 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Laura Jean Stine, 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. Date 3I` Respectfully submitted, b Dl?_ Susan C. Plano Certified Legal Intern ROBERfiIE. 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 r.a C o Q r?7 ?, ss• rnm C _ Cl) cn co -G LAURA JEAN STINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE JAMIE M. STINE, Defendant NO. 07 - 3261 CIVIL TERM CERTIFICATE OF SERVICE I, Susan C. Plano, Certified Legal Intern, Family Law Clinic, hereby certify that I personally served a true and correct copy of the Divorce Complaint on Jamie M. Stine by handing him a copy of the Complaint at the Domestic Relations Office located at 13 North Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. Service was complete upon receipt by Jamie M. Stine, on the 26th day of June 2007 at approximately 9:10 a.m. Susan C. Plano Certified Legal rn 7A. I Anne -Fox, Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 rJ e? ? -n ? - ' n t'E ; ti ? 1 , ; ?? : ? ' J? ? ;L- t fry-. '"? ? ?.? r 7 -Y. ?° ?. y 'Z ?-- ? .. p - .J-{ ?-?. LAURA JEAN STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE JAMIE M. STINE, Defendant : NO. 07 - 3261 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(a)(6), 3301(c), AND 3301(d) of the Divorce Code was filed on May 31, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. l\ eV3) Laura Jean Stine, Plaintiff C- CD ,; rn LAURA JEAN STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JAMIE M. STINE, Defendant :NO. 07 - 3261 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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 10 /23 to 7 / Jean Stine, Plaintiff a LAURA JEAN STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JAMIE M. STINE, Defendant : NO. 07 - 3261 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(a)(6), 3301(c), AND 3301(d) of the Divorce Code was filed on May 31, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 1112. 107 Jamie M. Stine, Defendant _ ---. .,? ? ? i ?, , ... ,t ... `..?7 I _ `?„ ? t. _. .,..?. " t j?V i ?? ,? tstV1 .-' 1 ~ ?...? ? r LAURA JEAN STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JAMIE M. STINE, Defendant : NO. 07 - 3261 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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 H12-1,0 7 Jamie M. Stine, Defendant ?..: ..is.Yw:Z,w:e..••6otr?.' _:1..-P."?.:.? 1...r.w??-.. y. ,-!. r ` r.a i :2 r C„r`s - . l7 - LAURA JEAN STINE, Plaintiff V. JAMIE M. STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE AND CUSTODY No. 07 - 3261 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 4& 3301(c). 2. Date and manner of service of the complaint: Served on Defendant Jamie M. Stine, by handiniz him a copy of the Complaint at the Domestic Relations Office located at 13 North Hanover Street Carlisle Cumberland County Pennsylvania 17013, on June 26, 2007. 3. Date of execution of the affidavit of consent required by §§ 3301(c) and 3301(d) of the Divorce Code: by Plaintiff- October 24, 2007• by Defendant - November 6, 2007. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: October 24, 2007. 6. Date Defendant's Waiver of Notice was filed with the Prothonotary: November 6, 2007. f Date ? ?,, - , ? C, 4, " - ?, Susan C. Plano Certified Legal Intern Ann ald-Fox, Supervi ing Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff "`? ?' ?? h? __.?- -r7 w? _, : ? w ?z? :r ? a ?? - ! - ? ? _. ? . " "? _.3 ?. ? ' ' ? ., i;;` s ?,-, , - ^ { ? , c? ? ? "= C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NO. 3261 9()n7 VERSUS JAMIE M. STINE, DECREE IN DIVORCE AND NOW, vlc+t-ibGl -2667, IT IS ORDERED AND c DECREED THAT LAURA JEAN STINE , PLAINTIFF, AND JAMIE M. STINE. , 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; BY THE COURT: PROTHONOTARY n°' 1-0 . b/ 7 to?r? 44or 4?.?v Lo. l /Ov- ?- a .... . LAURA JEAN STINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JAMIE M. STINE, Defendant : NO. 07 - 3261 CIVIL TERM CERTIFICATE OF SERVICE I, Susan C. Plano, Certified Legal Intern, Family Law Clinic, hereby certify that I personally served a true and correct copy of the Divorce Decree, Affidavit of Consent, Waiver of Notice of Intention to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code, and Praecipe to Transmit the Record, on Jamie M. Stine by depositing the aforementioned documents in first class US mail, on the 6 h day of December, 2007, to the following address: 37 Kerrs Avenue Carlisle, PA 17013 Susan C. Plano Certified Legal Intern Anne M=D-Fox, E Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 f"'? rrta tw7 . ,. .:, P e1° f :_?