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HomeMy WebLinkAbout03-5209IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Patricia Lee Loyd 501 Barry Ct. Mechanicsburg, Pennsylvania 17050 SS#: 611-01-2773 Plaintiff Ronald Thomas Loyd 501 Barry Ct. Mechanicsburg, Pennsylvania 17050 SS#: 571-39-7924 Defendant VS. NO. 03- 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 Plaintiff. You may lose money, property or other rights important to you, including the right to demand marriage counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: CUMBERLAND County Bar Association Lawyer Referral Service IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Patricia Lee Loyd SS~: 611-01-2773 Plaintiff Ronald Thomas Loyd SS~: 571-39-7924 Defendant VS, NO. DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Patdcia Lee Loyd, who currently resides at 501 Barry Ct., Mechanicsburg, Pennsylvania 17050. She has resided et this address at least since April 2002. 2. Defendant is Ronald Thomas Loyd, who currently resides at 501 Barry Ct., Mechanicsburg, Pennsylvania 17050. He has resided at this address at least since Apd12002. 3, Plaintiff has been e bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on ~12/23/95, at Chumh, Oliverhurst,, California, County of Yuba. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no pdor actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The plaintiff is aware of the availability of counseling and of the dght to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An odginal copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. Plaintiff (Pre Se) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Patricia Lee Loyd SS#: 611-01-2773 Plaintiff Ronald Thomas Loyd SS#: 571-39-7924 Defendant VS. No. DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Patricia Lee Loyd, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of her own knowledge that the Defendant Ronald Thomas Loyd herein is not in the military service as defined in the Solders' and Sailors' Relief Act of 1940 and its Amendments thereto, for the following reasons: At no time during the marriage have I ever witnessed my spouse report or make contact with military personnel. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. Signature of Plaintiff IN VVlTNESS THEREOF, I have hereunto set my hand and seal. Dated: NOTARY PUBLIC DOMESTIC RELATIONS INFORMATION SHEET CR NO. CP NO. FOLIO NO. DR NO. INFORMATION ON PARTIES PETITIONER: FIRST NAME MI LAST NAME Patricia Lee Loyd ALIAS, IF ANY None MAILING ADDRESS 501 Barry Ct., Mechanicsburg, Pennsylvania 17050 RESIDENTIAL ADDRESS, IF DIFFERENT FROM MAILING ADDRESS Same 10/19/77 DATE OF BIRTH 611-01-2773 SOCIAL SECURITY NO. DPW NO. Anglo-American HT WT RACE HAIR EYES DISTINGUISHING FEATURES PLACE OF EMPLOYMENT NAVICP-M MED. INS. CARRIER NAME, ADDRESS PHONE: POLICY NO.: CHILDREN COVERED? No OCCUPATION: N/A ATrORNEY'S NAME & ADDRESS SALARY: N/A ATTORNEY ID NO.: N/A RESPONDENT FIRST NAME MI LAST NAME ALIAS, IF ANY Ronald Thomas Loyd None MAILING ADDRESS 501 Barry Ct., Mechanicsburg, Pennsylvania 17050 RESIDENTIAL ADDRESS, IF DIFFERENT FROM MAILING ADDRESS Same 08/23/75 DATE OF BIRTH 571-39-7924 SOCIAL SECURITY NO. DPW NO. '" lbs. Anglo-American HT WT RACE HAIR EYES DISTINGUISHING FEATURES Hershocks, Inc. PLACE OF EMPLOYMENT MED. INS. CARRIER NAME, ADDRESS MARITAL PROPERTY Plaintiff lists ell marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: THERE ARE NONE Item Number: 1 Description of Properly: Names of All Owners: None None Cost or Value as of Value as of Date of Date of Acquisition: Action Commenced: $ $ Nature of Any Lien: Effective Date of Lien: Date of Acquisition: Amount of Any Lien: $ Holder of Lien: N/A MARITAL DEBTS Plaintiff lists ell marital debts in which either or both spouses have a legal or equitable responsibility individually or with any other person as of the date this action was commenced Item Number: 1 Item Number: 2 Item Number: 3 Description of Debt: Members 1'~ CU Description of Debt: Federal College Loan Description of Debt: Members 1~ CU #2 Party Responsible: Petitioner Party Responsible: Petitioner Party Responsible: Respondent Amount of Debt: $6,700.00 Amount of Debt: $13,600.00 Amount of Debt: $16,951 Item Number: 4 Item Number: 5 Item Number: 6 Description of Debt: Star Card Description of Debt: Social Security Description of Debt: Federal College Loan #2 Party Responsible: Respondent Party Responsible: Respondent Pady Responsible: Respondent Amount of Debt: $1,950.00 Amount of Debt: $1,000.00 Amount of Debt: $3,OO0.00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Patricia Lee Loyd SS#: 611-01-2773 Plaintiff Ronald Thomas Loyd SS#: 571-39-7924 Defendant vs. : No. Case Number : DIVORCE ACCEPTANCE OF SERVICE I, Ronald Thomas Loyd, hereby state that I have a .c~.epl;ed service of a true correct copy of the Co_.mplain! i.~.n Divorce in the above captioned matter at ~ ~n~ on ~',//'3 | ~by personal service. The server was /~*~/~E.~'~t whose age is .--~--.~ and whose address is: W~GZ~w'4.~.T.Z.S [~'~(,.I ~b A 17o5"*o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Patdcia Lee Loyd SS#: 611-01-2773 Plaintiff Ronald Thomas Loyd SS#: 571-39-7924 Defendant VS. No. Case Number DIVORCE AFFIDAVIT OF CONSENT ~/-- 1. A complaint in Oivome under Section 3301(c) of the Divorce Code was filed on /(~// ,2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 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. Sec 4904 relating to unsworn falsification to authorities, SWORN and SUBSCRIBED to before me this day of Notary Public IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY. PENNSYLVANIA FAMILY DIVISION Patdcia Lee Loyd SS#: 611-01-2773 Plaintiff Ronald Thomas Loyd SS#: 571-39-7924 Defendant VS. No. Case Number DIVORCE AFFIDAVIT OF CONSENT l. A complaint in Divome under Section 3301(c) of the Divorce Code was filed on / 0// ,2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. I understand that I may lose rights concerning alimony, division of prope~'y, 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. Sec 4904 relating to unswom falsification to authorities. Defendant SWORN and SUBSCRIBED to before me this __ day of Notary Public IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI~'~ FAMILY DIVISION Patricia Lee Loyd SS~: 611-01-2773 Plaintiff Ronald Thomas Loyd SS~: 571-39-7924 Defendant vs. No. Case Number 2003-05209 DIVORCE WAIVER OF NOTICE OF INTENTIONS TO REG~UE;s i THE ENTRY OF A DIVORCE DECRFr UNDER SECTION 3301 (c) OF THE DIVORCE COn, I consent to the entry of a final decree in divorce without notice. I understand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. STATEMENT 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date Plaintiff _IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Patdcia Lee Loyd SS~: 611-01-2773 Plaintiff Ronald Thomas Loyd SS~: 571-39-7924 Defendant VS. No. Case Number 2003-05209 DIVORCE .WAIVER OF NOTICE OF INTENTIONS TO REQUES; THE ENTRY OF A DIVORCE DECR~'F .UNDER SECTION 3301 (c) OF THE DIVORCE CO[Ji I consent to the ent~ of a final decree in divorce without notice. I understand that I may lose rights concerning alimony, division of property, I ' or expenses if I do not claim them before a divorce is granted, awyer s fees I undemtand tllat 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. STATEMENT 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date_ IN THE COURT OF Cfb~ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ?~O~,-C~t~CiViL 19 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: __ / ~/~/~ 3. Cc~plete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff by the defendant B. (1) Date of execution of the plaintiff,s affidavit requJ~ed by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff.s affidavit upon the defendant: 4. Related claims pending: 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code 2/ ~Oa/ Attorney for Plaintiff/Defendant IN THE COURT OF COMMON OF CUMBERLAND COUNTY VERSUS STATE OF NO, PLEAS PENNA. DECREE IN DIVORCE AND NOW, DECREED THAT ~i1~¢4 , ,~oc~'/, IT IS ORDERED AND , PLAINTIFF, , 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