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Home My WebLink About90-2520RENITA OWENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : IN ANNULMENT CARL L. OWENS, : Defendant : NO. ~O CIVIL 1990 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 he entered against you for any other claim or relief requested in these papers by the plaintiff. rights important to you, children. When the ground for the divorce is irretrievable breakdown of the marriage, You may lose money or property or other including custody or visitation of your indignities or 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 RENITA OWENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : NO. ~S~O CIVIL 1990 : CARL L. OWENS, : Defendant : IN ANNULMENT COMPLAINT The plaintiff, Renita Owens, by her attorneys, the Family Law Clinic, sets forth the following cause of action: ANNULMENT UNDER SECTION 204(a)(1) OF THE DIVORCE CODE 1. Plaintiff is Renita Owens, who currently resides at 162 E. Chapel Ave., Carlisle, Cumberland County, PA 17013. 2. Defendant is Carl L. Owens, who currently resides at 218 Bedford Road, Carlisle, Cumberland County PA 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. On March 28, 1983, a marriage ceremony was performed between plaintiff and defendant at Houston, Harris County, Texas and thereafter, until August 1, 1986, the parties lived together as man and wife. 5. Prior to said supposed marriage of plaintiff with defendant on March 28, 1983, the plaintiff had, on March 28, 1980 at Houston, Harris County, Texas, entered into a valid marriage with Benedict O. Asemota, which marriage was still existing at the time of the supposed marriage between the parties to this action. 6. Plaintiff initiated divorce action against Benedict O. Asemota in the District County Court in Houston, Texas on July 30, 1986. Said action was dismissed on August 3, 1987 and cannot be reinstated. Therefore, a valid marriage still exists between plaintiff and Benedict O. Asemota. 7. There have been no prior actions of divorce or for annulment between plaintiff and defendant. 8. Copies of marriage licenses documenting marriages between plaintiff and defendant and plaintiff and Benedict O. Asemota are attached as exhibits. WHEREFORE, plaintiff prays that a decree be entered declaring the supposed marriage between the plaintiff and the defendant null and void. Date THOMAS M. PLACE Supervising Attorney FAMILY LAW CLINIC 150 South College Street Carlisle, PA 17013 717/240-5204 COMMON-WEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND: SS. I verify that the statements made in this Complaint 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 unsworn falsification to authorities. RENITA OWENS ;17519 The State of Texas County of Harris To all lieenml ~r ordained Christian Ministers and Prltsts, Jtwish Rabbis, Pen~ns who are Offlters ~[ Re£tglom Organizations and whq are duly authorized by the organization to eond~x~ marriage eerernonit~; and Jmtites qf the 5~prtree Court, Judges ~f the Court ~f Criminal Appeals, Jmtices of tbt Coup. qf Civil Appeab, Judga ~ tItt Di~tticg County, and probate Couffs, Judges ~f the County Cou~ · ; l.~w, C*um ofDonu, stlc llel~t~ ,ndJu~ile CourU, RttiredJustiee~ ~ndJndges ~ftuth Courts, Ju~s ~ tho Peat,,., Retired Jmtittt qf ~ht peace, and Judges of the Fe~al Cou~ qf this Sate, You,"or either of you, are hereby authorized to flin · ~3n t~t ~olp ~mon of ~l~atnmon~ ':.'"i~/~ ' ::::'.~ ~it~ ': Anita Rodeheaver, County El. er)., Harris County, Texas · '-Offic~r'~ ~turn... Solemnized by the undersigned authority tl.'~ ~.ot~/tau MAY 11990 OANITA RODEHEAVER C Oxl~h'~ CLERK ,/~ FILED, 3 R PR COLIHTY CLERK XARRIS CDUE;TYo TEXAS OgL ANITA RODEHEAVER CO U~,.T~ CLERK ~,.-.-~-~, JEI~FERY MR~S '1 J BO[Jr~S36 qG?-I The State of Texas County of Harris To all licensed or ordained Claistian Ministers and l~¢sts, Jewish Rabbi% persons w~ are ~; a~ jmes ~ ~ $~ Co~, J~ges ~ ~ Co~ ~ C~l A~ah, J~t~s ~a ~ A~ J~s ~ ~ ~ C~r.~, a~ ~te Co~, J~n ~ ~ Co~ Co~s You, or either of you, are hereby authorized to join Inion of :ffiatrimonp In Accordance With The Laws Of The State Of Texas Herein Fail Not, t~t ~ ,n~ due rma'n ~ t~, your aut~,~y, to m~ ~ in the City of Houston, Tey~ ~IJdn ~ ~s a~r ~.rfo~mg I~e marriage, terming in what easily you performed the same. In Testim. ony Whereof, witness my hand and seat of office at Houston, Texas, onthis ~St~ dayof ~ ,19 t~ Anita Rodeheaver, r',.,.h, rv,.,-I, Harris County, Texas · azo.~ HtunbeA~on ' · "®ffi£tr'~ t~etu rn... Stgnature Judge Paul Heath Till ~ u s ~ ic e_ _o_f_~ h _e_ ~eace 6000 Chimney Rock Ho us ton~ .._Te~ _77081 MAY 1 1990 Q A NITA RODEHEAV£R C:O~OLERK H/I(RRIS COUNTY, TEXAS FILEI) #ARRI$COUWT¥,TE¥~S qG?-II-ZOqO i ~ mill _ J Il_ Imllll. MAY 1 1990 ANITA ROpEHEAVER CO U/N'TYxCLERN ,~ EFFERY b~J)R KS RENITA OWENS, Plaintiff v. CARL L. OWENS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN ANNULMENT NO. ~o OF 1990 ATTORNEY'S AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I, Shelley M. Jones, of the Family Law Clinic, attorney for the party petitioning to proceed in forma pauperis, certify that I believe petitioner is unable to pay the costs of instituting this action and that I am providing free legal service to petitioner. Petitioner's Affidavit showing inability to pay the costs of litigation is attached hereto. Date ~ III /~ S~i,!~y [M~. ,j~ ES~ Student ~ttO~ey Supervising Attorney FAMILY LAW CLINIC 150 South College Street Carlisle, PA 17013 717/240-5204 RENITA OWENS, : Plaintiff : : v. : : : CARL L. OWENS, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN ANNULMENT NO. ~g~0 CIVIL 1990 PETITION TO PROCEED IN FORMA PAUPERIS Renita Owens, plaintiff in the above titled action, respectfully requests this Honorable Court to grant her leave pursuant to Pa.R.C.P. 1920.62 to proceed in forma pauperis to the extent that she be relieved of all costs attendant to this action. SHELLEY ~. JO~I]~S Student Attor~y THOF~S M.' PLACE Supervising Attorney FAMILY LAW CLINIC 150 South College Street Carlisle, PA 17013 717/240-5204 RENITA OWENS, Plaintiff v. CARL L. OWENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN ANNULMENT : : : NO. ~20 CIVIL 1990 AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The petitioner, Renita Owens, Ave., Carlisle, Cumberland County, deposes and says: residing at 162 E. Chapel Pennsylvania, upon her oath 1. I am the named plaintiff in the above titled civil cause of action and the defendant is Carl L. Owens. 2. This affidavit is made to inform the court as to my status of indigency and to induce the court to grant me leave to proceed in this cause as an indigent. 3. In making this affidavit, I am aware that perjury is a felony and that the punishment is a fine of not more than $3,000 or imprisonment for not more than seven years or both. 4. I do not have any money on my person, at home, or elsewhere which could be used for the expenses of this proceeding. 5. I do not own real estate, personal property, or any other assets other than a 1986 Arrowstar Minivan. I am not owed any amounts of money by any person. 6. The defendant, Carl L. Owens, presently resides at 218 Bedford Road, Carlisle, Cumberland County, PA. He is 35 years old. a) I last lived with the defendant in 1986. b) The defendant is employed as a carrier for the U.S. Postal Service, he has both a checking and savings account, he owns a Chevette automobile and a 1989 Pontiac 6000, he is buying a home. c) I have brought action for child support payments. No action has been taken yet because I missed the hearing on June 15, 1990. 7. I have three children: Carlita R. Owens, who was born on July 13, 1978; Dyan S. Owens, who was born on May 22, 1982; and Joseph P. Owens, who was born on March 17, 1987, all of whom reside with me at 162 E. Chapel Ave., Carlisle, PA. 8. I am presently unemployed because the care of my young child requires my presence at home. I also attend school. I last worked at Child Time as a child care worker. My social security number is 267-19-0534. $248.00; 11. she can. helps. I have the following monthly income: Food Stamps, $227.00. My monthly expenses are as follows: Electric $32.00 Water 44.00 Phone 27.00 Car 202.00 Outstanding debt. She did have a Public Assistance, Plaintiff makes payments on these when friend who was helping. He no longer Master Card $1000.00 Fashion Bug 200.00 J.C. Penny 94.00 Bon Ton 107.00 Montgomery Ward 434.00 12. The defendant and I have not maintained a checking account throughout our marriage. 13. I am the owner of a 1986 Arrowstar Minivan. The balance due is $6000.00. Payments are $202.00/mo. 14. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 15. I verify that the statements made in this affidavit are tr~e 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. WHEREFORE, petitioner prays that this Honorable Court give petitioner leave to proceed in forma pauperis in the above titled action without fee or cost to the petitioner. Date ~////Q~ ~~ ~, ~ RENITA OWENS RENITA OWENS, Plaintiff v. CARL L. OWENS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN ANNULMENT NO. ~5~O CIVIL 1990 ~ORD~OF COUR~ AND NOW, this __ day of , 1990, on consideration of the attached petitioner's Affidavit, leave is granted to the petitioner to proceed in forma pauperis to the extent that she is relieved of all costs in this action. By the Court, RENITA OWENS, Plaintiff V. CARL L. OWENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN ANNULMENT : : NO.~5~0 CIVIL 1990 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 he 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. TRUE COPY FROM RECORD Court Administrator mberland County Courthouse Carlisle, PA 17013 717/240-6200 RENITA OWENS, Plaintiff v. CARL L. OWENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. ~S~O CIVIL 1990 : : : IN ANNULMENT COMPLAINT The plaintiff, Renita Owens, by her attorneys, the Family Law Clinic, sets forth the following cause of action: ANNULMENT UNDER SECTION 204(a)(1) OF THE DIVORCE CODE 1. Plaintiff is Renita Owens, who currently resides at 162 E. Chapel Ave., Carlisle, Cu~erland County, PA 17013. 2. Defendant is Carl L. Owens, who currently resides at 218 Bedford Road, Carlisle, Ctn~berland County PA 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. On March 28, 1983, a marriage ceremony was performed between, plaintiff and defendant at Houston, Harris County, Texas and thereafter, until August 1, 1986, the parties lived together as man and wife. 5. Prior to said supposed marriage of plaintiff with defendant on March 28, 1983, the plaintiff had, on March 28, 1980 at Houston, Harris County, Texas, entered into a valid marriage with Benedict O. Asemota, which marriage was still existing at the time of the supposed marriage between the parties to this action. 6. Plaintiff initiated divorce action against Benedict o. Asemota in the District County Cou~t in HoUston, Texas on July 30, 1986. Said action Was diSmiSsed on August 3, 1987 and Cannot be reinstated. Therefore, a Valid marriage still exists between Plaintiff and Benedict O. Asemota. 7. There have been no prior actions of diVOrce o~ for annulment between Plaintiff and defendant. 8. Cop/es of marriage licenses documenting marriaa,~ between Plaintiff and ~_~_ COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND: SS. I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge and belief. I understand that penalties of 18 to authorities. false statements herein are made subject to the Pa.C.S. § 4904, relating to unsworn falsification RENITA OWENS ~ BOO~53G 417-11o2~3~ You, or either of you, art h~rtby authorized to join ~n t~t ~olp ~Inion of ~ql~trimonp Anita "'Ollittr'~ MAY 1 1990 ~T ~W ~$i-I~-Zq07 MAY 1 lggo ANITA ROOEHEAVER COU~l.T~ CLERK H/t~RIS ~,OUNTY, TEXAS JEFFERY RENITA OWENS, Plaintiff v CARL L. OWENS, Defendant IN THE COURT OF COMMON P?.R~S OF CUMBEPJ~AND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : : NO. 2520 CIVIL 1990 : IN ANNULMENT ANSWER TO COMPLAINT FOR ANNULMENT UNDER SECTION 204(a)(1) OF THE_DIVORCE CODE 1. Admitted. 2. Admitted. 3. Admitted. 5. in paragraph marriage date is marriage 19, 1980. Admitted. Admitted in part. Ail of the allegations set forth 5 were admitted with the exception of the date of between the Plaintiff and Benedict O. Asemota, which unknown to Defendant, but it is believed that the between her and Benedict O. Asemota occurred on March 6. Admitted. 7. Admitted. 8. Admitted. W~EREFORE, Defendant enter a decree declaring the previous marriage between Plaintiff .and Defendant to be null and void. Respectfully submitted, requests your Honorable Court to the TRUE COPY FROM RECORD m Testimony whereof. I hem unto set my hand and the seal ~ ~i~ourk~ Carlisle. Pa. /_~/f~ ~ ~Zz~__(ta~__~z:~ 19-,~P--- ~ ~iffie, Esquire Attorney for Defendant ~ ~~ GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: CARL L. OWENS RENITA OWENS, : Plaintiff : : : vo : : : CARL L. OWENS, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2520 CIVIL 1990 IN ANNULMENT CERTIFICATE OF SERVICE I, Shelley M. Jones, student attorney for the Family Law Clinic, hereby certify that I have served a true and correct copy of said Complaint in Annulment on Carl L. Owens, residing at 218 Bedford Street, Carlisle, Cumberland County, Pennsylvania, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid, this 18 day of July, 1990. Shelley M. Jo~es ~ j RENITA OWENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : NO. 2520 CIVIL 1990 : CARL L. OWENS, : Defendant : IN ANNULMENT ORDER 0 AND NOW, this day of .' ' -~z, 1991~it is hereby ordered and decreed that the supposed marriage between the plaintiff, Renita Owens, and defendant, Carl L. Owens is declared null and void. By the Court, RENITA OWENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW CARL L. OWENS, : NO. 2520 CIVIL 1990 Defendant : IN ANNULMENT ANSWER TO COMPLAINT FOR ANNULMENT UNDER SECTION 204(a) (1) OF THE DIVORCE CODE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part. Ail of the allegations set forth in paragraph 5 were admitted with the exception of the date of marriage between the Plaintiff and Benedict O. Asemota, which date is unknown to Defendant, but it is believed that the marriage between her and Benedict O. Asemota occurred on March 19, 1980. 6. Admitted. 7. Admitted. 8. Admitted. WHEREFORE, Defendant decree declaring the enter a Plaintiff and Defendant to be null and void. Respectfully submitted, requests your Honorable Court to previous marriage between the ~ffie, Esq~~uire Attorney for Defendant GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. CARL L. OWENS