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Home My WebLink About08-1102MANDI L. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROY A. YEINGST, Defendant : NO. 08- 16 ? 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 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. MANDI L. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROY A. YEINGST, Defendant : NO. 08- C f d CIVIL TERM DIVORCE COMPLAINT UNDER 23 Pa C S. ri$ 3301(c) AND 3301(d) OF THE DIVORCE CODE The plaintiff, Mandi L. Yeingst, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: 1. Plaintiff is Mandi L. Yeingst, currently residing at 353 North Hanover Street, Cumberland County, Pennsylvania 17013, since January 2008, mailing address is P.O. Box 1084, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Roy A. Yeingst, currently residing at Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 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. Plaintiff and Defendant were married on February 28, 2003 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since January 22, 2008. 6. There have been no prior actions for divorce or for 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. Takara Strong Certified Lega ern Counsel for the Plaintiff A ONALD Supervisin Attorney Counsel for the Plaintiff 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 Plaintiff Mandi L. Yeingst U Z I ` : C Mandi L. Yeingst, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Roy A. Yeingst Defendant. NO. 08- J16?- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Mandi L. Yeingst , 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 aD v g Respectfully submitted, Takara Strong Certified Legal Intern Counsel for the Plaintiff ANNE ALD- Supervisin Attorneys Counsel for the Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?"'' ? C?3 4? a -- ._?-? -,? -?; 9 i __ ._ -a ?+r - . . M w -+? r?' j l 1- y r... ml'i. ?. ? _...... ? 1_ l ....-.. i? z. `? -•w MANDI L. YEINGST, Plaintiff V. ROY A. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 08-1102 CIVIL TERM AFFIDAVIT OF SERVICE I, Takara S. Strong, hereby certify that I personally served a true and correct copy of the Divorce Complaint, on Roy A. Yeingst, at: the Cumberland County Prison, at 2:08 p.m. on February 25, 2008. I verify that the statements made in this Affidavit of Service 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 unworn falsification to authorities. Date: 'J 1W Takara S. Strong Certified Leg*l Intern , ' _ . ll r MANDI L. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROY A. YEINGST, Defendant : NO. 08- 1102 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on February 20, 2008. 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 O? OS 16<:? y" Mani L. Yeingst, Plaintiff a 1rY,;;?? ? ,?'' ??\??? ; nr ??.r ???? ?. ?? ?j ??? J ( ?:.???t . M1 ? y.t 1 ?'t ?L ? T``?? ?`i c?? "? } ? r,..? MANDI L. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROY A. YEINGST, Defendant : NO. 08-1102 CIVIL TERM 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 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 0 Mani L. Yeingst, ntiff FILED r OF THE Q1 ' h r;,Y 2003 ,JUI- - 8 P ti 2: MANDI L. YEINGST, Plaintiff V. ROY A. YEINGST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 08-1102 CIVIL TERM CERTIFICATE OF SERVICE I, Krystal J. MacIntyre, Certified Legal Intern, Family Law Clinic, hereby certify th served a true and correct copy of the Plaintiffs Waiver of Notice of Intention to Request at I of a Divorce Decree Under §3301(c) of the Divorce Code and the Plaintiff s Affidav Entry Consent on Defendant, Roy A. Yeingst, on July 9, 2009 by depositin a co t of United States mail to the following address: g pY of the same in the Roy A. Yeingst 506 Shippensburg Road Newville, PA 17241 K.talJ ac yre Certified Legal Intern Y Meg Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 PIP OF THE PP 2009 jU -9 Pl'i 2: 06 MANDI L. YEINGST, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROY A. YEINGST, Defendant : NO. 08-1102 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on February 20, 2008. 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 ?'l !D FI E ?"uif 2009 ! MANDI L. YEINGST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROY A. YEINGST, Defendant : NO. 08-1102 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST 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 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 -7 MIN 9 ;;py MANDI L. YEINGST, : 11,4 THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW V. : IN DIVORCE AND CUSTODY ROY A. YEINGST, Defendant : No. 08-1102 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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 personal service at the Cumberland County Prison, February 25, 2008. Service was complete upon receipt by Roy A. Yeingst. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff- July 8, 2009; by Defendant- July 10, 2009. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: July 8, 2009 Date Defendant's Waiver of Notice was filed with the Prothonotary: July 14, 2009 00 QDat!44 trstal J. acI yre Certified Legal Intern Anne Fox, Esq. Supervisin Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff OF TMc PiROT "'" OTARY 2009 JUL 21 PM 2: 4 s4 CUtvi _ .k,$ l y PENNISYLVANA MANDI L. YEINGST IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROY A. YEINGST NO 08--1102 DIVORCE DECREE AND NOW, ?IaA 14 Zoo'} , it is ordered and decreed that MANDI L. YEINGST plaintiff, and ROY A. YEINGST bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, a t' i` A..7e . w