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HomeMy WebLinkAbout07-4300Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., Defendant : N0.07- ~/3 ~ 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 A 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. Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., . Defendant : N0.07-43av CIVIL TERM DIVORCE COMPLAINT The plaintiff, Peggy Busey, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §~3301(c) OF THE DIVORCE CODE 1. Plaintiff is Peggy Busey. Plaintiff currently resides at 201 East Burd Street, Shippensburg, Cumberland County, PA 17257, where she has resided since February 19, 2007. 2. Defendant is Robert Busey, Sr. Defendant currently resides at 221 East Garfield Street Shippensburg, Cumberland County, PA 17257, where he has resided for fifteen years. 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 21, 1981 at Hagerstown, Washington County, Maryland. 5. Plaintiff and Defendant have lived separate and apart since February 19, 2007. 6. There have been no prior actions for divorce or annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. Holly O. Vaug Certified Legal Intern `~~' I- R B .RAINS THOM S 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 / Q 7 Plaintif f Pegg Y `._` h.) r `~ : ` (" ---3 _ _ c.~_ ,_ T r,-n , ~_ ~ ~ - > -- ; ; _ __. ` •` + „-i _.. C.F i :Z7 w- °G Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY Robert Busey, Sr., Defendant NO. 07- ~~D CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Peggy Busey ,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 ~a d-4O-1 Respectfully submitted, Holly O. aughn Certified Legal Intern R B .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-, ,~, ,_~- ~~~ '' -_- CJ - : .. ..a ~- C::" i "~ -..f- Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW DIVORCE Robert Busey, Sr., . Defendant N0.07-4300 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Robert Busey, Sr., residing at 221 East Garfield Street, Shippensburg, Pennsylvania, 17257, 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 Robert Busey, Sr. on the 9th day of August, 2007 as evidenced by the attached green card. Holly O. aughn Cie jrtified Leg'a/l?Intern Anne c onald-Fox, Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 N (-- ,~ f~ •- ~ ~ Ir..... - ~ .., t__~ ~I~ •v ., i ~, ~ '-~-': ~ - ` „ ~ rr; -~s ~ ~ Q ~~ ~ ___._ _ s ~'-°~ ; gym. Nkn 4 If I~IioAM 4 ~L _11 PrY~t Y~ n~MrirrM~MIS+ori I~r so 1A0t wr ~ Mllflit'IIk'~li 0111lt 1l~ ~. ^ AM~oh 1hi~ cM~d b ~ ~k+~~ i iMtenfhs~Wbtk~~ 1. AiMW~ Atid~~d tae ~ ~ ~~ ~~ ~ ~ -. 2Z 1 [ ~S~ ~~~~ ' ` ~ + 1_ - ~~ . ~~~ IIMM D ~ MM ^ IiipfMrnd ~I Rrlirr~ iFx tar kAaMwxM» ~, ~ Q -nwr.a+~w D co.o. b F' 4. pMtriol~d D~Nwry? (F rba Fse1 Yes ~~ ,~ i = ~~i~ ~t9a aoa3 ~6~~ ~s -~- P$ ORiI .~~ ~ . F ~ ~ ~ 102595.02-M-1540 Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., Defendant : NO. 07-4300 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on July 20, 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 unsworn falsification to authorities. Date Pegg aintiff C'~r ~.. ~: ~ C~? t ~;., ~ .. ~,-; - c ; n.~ -; r-~- r r ~ ~ ) . `?~ _ ' `-- V°.r ..~ Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., Defendant : NO. 07-4300 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on July 20, 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 unsworn falsification to authorities. Date ~ ~ ~ ZO ~ D~ Ste. Robes Busey, Sr., Defe dant r,; ~ ~ c-." ~ ~, ,~~., ~~ == -,.:, ~7 -,-, ; ~ ~-; -, : _ 1. t_-- + l~ ~, ''~~; ~-rf Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., Defendant : NO. 07-4300 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &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 are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date ~~ Pegg a ,Plaintiff CC' 7 rv _ t~ ~ ~ f"', !"t'~ '?"i , f ."i; -' - r C,v ~ G, ~ ~ ~~ '~ " fa. ~ ~~ Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., Defendant : NO. 07-4300 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $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 are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date 1 ~ ` 2.C~ ' ~~ , Robe Busey, Sr., Defend t c-~ +~, ~_.. ~' ~ Cr ;1~; ~ ~ ~,=r ,--~-y r a ~ _ ... ;~..., ~ ~ ;.. ; ~. ;`j c ¢ ~ Peggy Busey, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW DIVORCE Robert Busey, Sr., Defendant N0.07-4300 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code, the Affidavit of Consent, and the Praecipe to Transmit the Record by first class, U.S. mail, postage prepaid on this date, on the following persons: Robert Busey, Sr. 221 East Garfield Street Shippensburg, Pennsylvania 17257 Date: ~ ; (~,~ j~;U'V~~c- ~ ~ ~~ 7 v~ Wt-`~. Holly O. aughn Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C ~ r*.~ f-- -~ ty, C~ ~, ,~- ~ - ~ - r,~ rr7 ~.,`a `~- _ _ ~ ~ r-- ~~~ + ., } `E -~ _ ~; ~-j i'. ` -~: J} ,`..3 ~ ` ~ l ~' "1''j .. '~' C"5 ..,~ Peggy Busey, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Robert Busey, Sr., Defendant : NO. 07-4300 .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(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 Robert Busey, Sr. on the 9`~ day of August, 2007. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: By Plaintiff: November 20, 2007; By defendant: November 20, 2007. 4. Related claims pending: none 5. Date plaintiffs Waiver of Notice was filed with the Prothonotary: December 3, 2007. Date defendant's Waiver of Notice was filed with the Prothonotary: December 3, 2007 Gt~vzl+~~~~ ~©~ Date Holly O. aughn Certified Legal Intern Megan' iesmeyer, Esq. Supervising Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff ~ ~ - _ ; , ~ - p -- ~ ~:~ ~` ~ n~ ' - 4 ~~ -~ `- :~ r R~ ,^~~T',' ~ _ st '-C7 "'~: I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ';; ,, .,, N O. 4300 2007 VERSUS DECREE IN DIVORCE AND NOW, ~[l_t -•,b ) ~ ZOb IT IS ORDERED AND DECREED THAT P B l EY PLAINTIFF, AND ROBERT BUSEY~ SR. 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 COU PROTHONOTARY . ,, , . ..