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Home My WebLink About07-3805 Heather S. Lamar Plaintiff V. Jose D. Lamar Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 3 fr? CIVIL TERM IN DIVORCE 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 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 t ? Heather S. Lamar Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. Jose D. Lamar Defendant NO. 07- CIVIL TERM : IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is P?0l U,,f r who currently resides at Cumberland County, Pennsylvania. 1 7 3 2. Defendant is ??jo-?C- , who currently resides at 4')A Nw( Vz l-C4 wr-e ?Ce St?-' Ph11Gca-elplylG+ P0: lgl?n 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 IjA ri e 1, tk 26)t) at CUW yk1 of r of CC-)L', , ? hI Courr ?ufe Cap-??sc? 5. The marriage is irretrievably broken, and the parties separated on Oct /3, 1-90U 6. There have been no prior actions of divorce or annulment between the parties. 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. U 21 U&htr ? K Dat Plaintiff, Pro Se 1, f t ,o ?J O 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. 7 Dat . Plaintiff, Pro Se O Assisted by: Marcus A. McKn' ht, III, E Irwin & McKnight Law Of gL 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 N ? p sue, ? ? .J Heather S. Lamar Plaintiff V. Jose D. Lamar Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Heather S. Lamar, Plaintiff, to proceed in forma au eris. I, Marcus McKnight, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. A. NfcKnigkt, III, Esq. Irwin & Mc'K'V-ight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 June 25, 2007 c7 ? C= V C I'T C= ?. W Cri 11 5 HEATHER S. LAMAR, Plaintiff V. JOSE D. LAMAR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3805 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA . . SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Jose D. Lamar, on June 26, 2007, certified, restricted delivery mail, addressed to him at 338 East North Street, Apartment B, Carlisle, Pennsylvania 17013, with Return Receipt Number 7004 1350 0003 7289 3457. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties 7,11 Pa. V . Section 4904, relating to unsworn falsification to authorities. - Attorney A. NeK1VGHT, IJI, ESQUIRE Date: August 6, 2007 M r_ M (Domestic . co Ir ti -6 . .- r- I tti Posta S .. p , UN > o N M irEb C3 Certified Fee 'a LQ F N) - C3 Retum Redept Fee E d n -n o, ( n orsement Required) a i V C3 m Restricted Dettfery Fee (Edorsemt Required) y, W '-9 - TOW Pas"o Fees 9, ?I :1 C) a 9 0 Z ? oZ P b) 0 U S" TO MR JOSE D LAMAR ?'• m rti - - ----- •- 40.01 0 C) T NORTH ST APT Bo or _ : - ¦ Com aft fterns 1, 2. and 3. Also owfl i ft ftm,4 N Restricted Delivery is desired: ¦ Print your name wid address on the reverse so that we can retum the card to you; ¦ Anach this card to the back of the moli0m, or an theftrit N apace permfts. 1. Article Addreesed to: MB 3 Ll11!" 338 ST APT B CANJ A 17013 0 Agent X 0 adri.Mil. B. R6hod by Memel C. Date of De my D. Ie elNaryaddroee di fetent from item 1? ? Yee If YES, enter delivery address below: ? No i_ 3. Service bISKUW IW* JE k 19Otlrrrl 2. Article Number 7004 1350 0003 7289 3457 (7ierptrerfiom servke Alban PS Form 3811, February 2004 Domeaft Return Receipt io25ss-0¢ tit t5ao f C> ? .- D r PO HEATHER S. LAMAR, Plaintiff V. JOSE D. LAMAR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3805 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 2007. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 25, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. Date: NOVEMBER 23, 2007 '/ Ja P Vt THER S. LAMAR Plaintiff n - N c? p -n L o n r' tv F m Zr HEATHER S. LAMAR, Plaintiff V. JOSE D. LAMAR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3805 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: NOVEMBER 23, 2007 AT R S. LA Plaintiff tog "-, 2 HEATHER S. LAMAR, Plaintiff V. JOSE D. LAMAR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3805 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 2007. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 25, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. Date: 1ILIIld? AfZ.1,0? J E D. LAMAR Defendant C ?} CA HEATHER S. LAMAR, Plaintiff V. JOSE D. LAMAR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3805 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330i(e) 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: 11T Jt) J SE D. AMAR Defendant -f,? rn Cl) am. -rt W -C HEATHER S. LAMAR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2007 - 3805 CIVIL TERM JOSE D. LAMAR, Defendant IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Jose D. Lamar, on or about June 26, 2007, by certified, restricted delivery mail, addressed to him at 338 East North Street, Apt. B, Carlisle, Pennsylvania, 17013, with Return Receipt Number 7004 1350 0003 7289 3457. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by plaintiff. November 23, 2007; by defendant: November 13, 2007. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) of which is attached: (b) November 27, 2007. November 27, 2007. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy Date plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in Section 3301(c) Divprcg was filed with the Prothonotary: Attorney for III, Esquire Date: November 27, 2007 C i-' cn - v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. HEATHER S. LAMAR, PLAINTIFF NO. 2007 - 3805 CIVIL TERM VERSUS JOSE D. LAMAR, DEFENDANT DECREE IN DIVORCE AND NOW, -2)ett...41, 3'%" , ??Qa-7 , IT IS ORDERED AND DECREED THAT HEATHER S. LAMAR , PLAINTIFF, AND JOSE D. LAMM 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 JPt Q? 7=37? qlv -3qi lo(V - z q _ Z` 1 4-7 $'vvTW -11- ftf , g w ?rjvn-? 130 - to - -Y,