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Home My WebLink About07-3509r , Mary J. Chronister, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Wayne R. Chronister, Defendant : NO. 07- 350Q 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. V , ? , Mary J. Chronister, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Wayne R. Chronister, Defendant : NO. 07- 3SG9 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Mary J. Chronister, by his/her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. M3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mary J. Chronister, who currently resides at 636 (B) Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania, 17257 since April, 2007. 2. Defendant is Wayne R. Chronister, who currently resides at 214 East North Street, Carlisle, Cumberland County, Pennsylvania, 17013, since December 2006. 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 17, 2004 at Mount Holly, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since November 17, 2006. 6. There have been no prior actions for divorce or for annulment between the parties. J I . 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. P(?' a,,- Charla Corwin Certified Legal Intern Counsel for Plaintiff ROBEhTIE7 RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 4 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 , ( Plaintiff Mary hronister C"? .. V e-. c=5 -n ,c t L? (J I u: Mary J. Chronister, Plaintiff V. Wayne R. Chronister, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 07- 350 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Mary Chronister, 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 I3 ?' Res tfully submitted, C orwm Certified Legal Intern ROBE INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 c? ? o =r - e -n c crl Mary J. Chronister, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07 - 3509 Wayne R. Chronister, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Charla Corwin, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Defendant, Wayne R. Chronister, residing at 214 East North Street, Carlisle, Pennsylvania, 17013, 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 Wayne R. Chronister, on the 21"day of June 2007 as evidenced by the attached green card. Charla Corwin Certified Legal Intern lkel:?? AV, ROBER E. RAINS THOMAS M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-3696 Fax: (717) 243-3639 c? o C= r r c cr J Zr 5 c: co ?s vw d ?F ai i 10 you. s Aftch #ft and to the ( om* d t w aeon ttto front it spa= PwIl ft 4. X- wit C. n.n d D,rw a. ft Dal a by( t. ? rt tern twin t? Ke "r M YE4 w?gly Mds t D No ?? '49.06~ and D E p.« MOO RESTRIMED 4. Red&iod D~ Pft Fee) 1% Yes 7005 0390 0003 2632 5645 ' o25a PS Form 3811, Fowu y S DPWA W NOW FASSW so2 M w Mary J. Chronister, Plaintiff VS. Wayne R. Chronister, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3509 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on June 14, 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. d Date ?- 0 Mary J. ister, Plaintiff ... IMI r ?t ? Mary J. Chronister, Plaintiff VS. Wayne R. Chronister, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3509 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on June 14, 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 t, 14?? Wayne R. Chronister, Defendant ?. ?, -?"-? ?? °? _ ..p + J C"? ,_ ' <Y," ? ? . Mary J. Chronister, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07 - 3509 Wayne R. Chronister, CIVIL ACTION - LAW Defendant IN DIVORCE 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. ?j V-aw?) Z) Date 0- 93-0 / - INk ary J. ster, Plaintiff r -T, E`a't 4 . ?C7 17 f-; ?-;f Mary J. Chronister, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07 - 3509 Wayne R. Chronister, CIVIL ACTION - LAW Defendant IN DIVORCE 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 /Q - ?- 07 Wayne . Chronister, Defendant a C ` . Q r I_i .,, J T Mary J. Chronister, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW : DIVORCE Wayne Chronister, Defendant : NO. 07 - 3509 CIVIL TERM AFFIDAVIT OF SERVICE I, Charla Lenz, hereby certify that I personally served a copy of the Plaintiff s Affidavit of Consent and Waiver of Notice of Entry of a Divorce Decree on October 30, 2007, at 214 East North Street, Carlisle, Pennsylvania, 17013, by depositing, on this date, a copy of the same in the United States mail, postage prepaid. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. 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: Q_J - G, Charla Lenz Certified Legal Intern CII) r .. nlK L._ co C Mary J. Chronister, Plaintiff V. Wayne R. Chronister, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE AND CUSTODY : No. 07 - 3509 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Wayne R. Chronister, Defendant, on June 21, 2007. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff on October 23, 2007; by Defendant on October 18, 2007. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: October 30, 2007. Date Defendant's Waiver of Notice was filed with the Prothonotary: October 30, 2007. 0 cy- Date Charla Lenz Certified Legal Intern _?44"CiLjv _?? Anne Ma onald-Fox, Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff -4 ? r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MARY J. CHRONISTER, Plaintiff NO. 3509 2007 VERSUS DECREE IN DIVORCE AND NOW, K)nyCz =2LI- 'S , Zcorl , IT IS ORDERED AND DECREED THAT MARY j- C`HRONT STRR , PLAINTIFF, AND _ WAYNE R 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; NONE BY THE COURT: PROTHONOTARY -W