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Home My WebLink About07-7140Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 07- 71zj0 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 Susan M. Vance IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- Ijgo CIVIL TERM Bobby J. Vance Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ' a 6 a ` () . r C , who currently resides at _a ? C? Q ??? nCe?n ? ye A-n-?- l ' [annn ?, ??? l 7111, Cumberland County, Pennsylvania. 2. Defendant is who currently resides at 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 ?ua -7, c9 CEO ( at 5. The marriage is irretrievably broken, and the parties separated on d -- -:7a005 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best ofher 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. 1 u o? ILG . ILLQ.0 Date Plaintiff, Pro Se I,CFn `f?. \n CsZ , 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. ILOQS-&I Date: Plaintiff, Pro Se Assisted by: Barbara Sumple-Sullivan, Esq. Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7/W CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. p P.3 _ ILO : Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 07- 71W CIVIL TERM : IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Susan M. Vance , Plaintiff, to proceed in forma 12aupens. I, Barbara Sumple-Sullivan, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 C7 C= L7 r w CID, I 4 t r (.l t.. t5 ar :{ c -% Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 711114 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on 00;J. -1 ,acx? ti and continued to live separate and apart for a period of two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I,c3i 5AK) 'fi`n. VQLnC,9- , verify that the statements made in this Affidavit 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 P.S. Section 4904. ?k"a s-(-)J? 115Gn 7y). Y nC.p Date Plaintiff, Pro Se I Susan M. Vance IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. No. 07- 71yO Crvu, TERM Bobby J. Vance Defendant IN DrvORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ? (i) The parties to this action have not lived separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims for economic relief. 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. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. A. I verify that the statements made in this counter-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: Bobby J. Vance NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. -7 y Fi n • SUSAN M. VANCE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07 - 7140 CIVIL TERM BOBBY J. VANCE, : Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Certified Mail, Certified No. 7007 0710 0003 2208 5565, Return Receipt Requested, on the above-named Defendant, Mr. Bobby J. Vance, on December 4, 2007 at Defendant's last known address: HCR 1, Box 820, Jadwin, MO 65501. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unswo falsi ation to authorities. Dated: August 28, 2008 Barbara Sumple-Sullivan, Esquire For Susan M. Vance USPSZ - Track & Confirm 0 a-P05 t VTEDSTA ES W SEWXE0 Track & Confirm Home I Help Track & Confine Search Resuhs Label/Receipt Number: 7007 0710 0003 2208 5565 Status: Delivered Track & Confirm Your item was delivered at 10:01 AM on December 4, 2007 in JADWIN, Enter Label/Receipt Number. MO 65501. Itdral t ? ? Reustrta to ft$P&cdia tlMO? r g`) t4ntif cation Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. 'i ._Mag t otita?f Forms Gov't Services Jobs Royary_Policy. TQnns ofd dig Copyrlght(c-) 1999-2007 LISPS. All Rights Reserved. No FEAR Act EEO Data FOIA , 0 Page I of 1 http://trkcnfrml .smi.usps.com/PTSIntemetWeb/InterLabelInquiry.do 12/13/2007 4 "I ra Domestic Only; No Insurance Coverage Provided) Ln rn N . ru Postage $ SO-2 0070 ru Certified Fee S2.65 ?BLRt q m G C3 Retum Receipt Fee (Endorsement Required) 2.15 Pos HMFV 'o O 0 Restricted Delivery Fee (Endorsement Required) $Q.QQ O 1 y?? 4 Qom/ e-? ?' G r- Total Postage & Fees $ $5.38 1 ?® O M1 ° Sant o T D- /-- - aC.:? - ? Wit; pt PO Box No. Q ; ------ ---------------------- \ Q ?] c , S to ZIP+4 CN, ------------------- c) { zw* QrfirO s UM 1, fit, and S. Also oomplate Nom 4 If PaoM M/ Ddwy is deal of PMnt your name and address on the reverse so that we can return the card to you. a Attach this card to the back of the mailpiece, or on the front If spare permits. 1. Article Addrbosed to: bobby S COL ee Jai , f\ A. Sigrrehn Agent 13 X aosaGC 0 ? Addressee B. ReceNed (PftW Name) C. Date of DelNsq Io/-3 -T ?,?AlGG D. b dsilvery address d ftm. itorn ram 1? O Yes If YES, enter delivery address below: ? No 3. Service Type W CwWWd Mail 0 Express Mail 17 Registered O Return Rst Wpt for MwcharrdNe ? InKned Mail O C.O.D. 4. Restricted Deilvery7 P ft Fee) ? Yes 2. Mode Narnber _ --!? (franslferfrorn aervfce MW '2 e 7007 0 710 0003 2208 5565 PS F M 3611, Fd mary =4 ' M mane MM Aeoeipt ,oes /?aV E EXHIBIT "A" C -rz C= i C M .. 00 :?% cry `zx Susan M. Vance IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7140 CIVIL TERM Bobby J. Vance Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on Novegnber 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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. Section 4904 relating tt/o unsworn falsification to authorities. -7 , a Date: l36 406? Signature: E--,Z Bobby Y Vance, Defendant N 4?' r N l-' Susan M. Vance IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7140 CIVIL TERM Bobby J. Vance 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 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?U!?e& Signature: Gam' Bobby J. ance, Defendant .. co ., _?.. rwYr ?y t?'?1 ' ? ?S Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7140 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. EL a Date: -734/U? SignatureC? 'ELa C-Q Susan M. Vance, Plaintiff _ yys _ co C N Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7140 CIVIL TERM 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 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: ??3d Signature?_"?}(?n?o Susan M. Vance, Plaintiff f7 c''`'.? ?} _ G3 1't1 ?,... -?' , -t 1?' ? ? ?? ? ? ? ? t i . .: -,? _ - f _ ? ? CTl ?? .=`.? `? ?'? •'? Susan M. Vance Plaintiff V. Bobby J. Vance Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7140 CIVIL TERM IN DIVORCE 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 Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on December 4, 2007 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, July 30, 2008 ; by Defendant, July 31, 2008 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: August 28, 2008 (c) Date Defendant's Waiver of Notice in Section 301(c) Djy6Aec filed with the Prothonotary: August 28, 2008 Dated: August 28, 2008 / Bar-tiara Sumple-Sullivan, Esquire r for Susan M. Vance C"? r? rtr?: ? m ON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SUSAN M. VANCE, Plaintiff VERSUS BOBBY J. VANCE, Defendant BOBBY J. VANCE DECREE IN DIVORCE f 2008 AND NOW, LO 1 , IT IS ORDERED AND SUSAN M. VANCE DECREED THAT AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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: j ATT E PROTHONOTARY No. 07 - 7140 , PLAINTIFF, -? ?? }?'? 30.1 b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lt GYM ro. '?nQ,V Plaintiff Vs File No. Q -] Q IN DIVORCE 6CAbLi \?Q&VAQ P Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, J or X after the entry of a Final Decree in Divorce dated 9 b o hereby elects to resume the prior surname of 7-i m rn C. t' MO-t\ , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: Cq t a - y c-i ( ? m 00 Q Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF, On the A -5? day of L- ? , 200, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. PROThVNO ? MY ft" CARLISLE C"Em-ft MY COMMISSION EXPIRES JrIll IARV 44 Notary Public t7 N4 ?f 7 i