HomeMy WebLinkAbout04-0392rN THE'COUR.T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
: No.
Defendant
: IN DIVORCE
:
Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOUHA VE BEENSUED 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 ~ound 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, DMSION 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
2 Liberty Avenue
Carlisle, PA 17013
(717) ,2. ~9r3166
Ee hah demandado a usted a la corte. Si usted qulere defenderse en contra estas demandas
expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en
contra suya.
Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una
orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en
la peticion do demanda~ USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A LIN ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIK ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Plaintiff
VS.
eCg /3-. S o ,_s
-- Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COLrNTY PENNSYLVANIA
No. 04- QVlL TERM
: IN DIVORCE
COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE
1. Plaintiffis--~'J'l'l't.t'~ //[4.~),~)t~/'£-~(T0~St°who currently resides at
Cumberland Co~, Pe~sylvania.
2. Defendant is ~~.~~ , who c~ently resides at
3. Plaintiff has been a bona fide resident of the Co~onweal~ of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on 1~o b r-lx.~.~ '"~, &OD& at
5. The marriage is irretrievably broken, and the parties separated on
6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best of his/her 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.
Date
I,~'c~&/Y~ [6}j'st~r43 -'. ~-FO~.Lerify that the statements made in this Complaint
are tree and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unswom falsification to authorities as
provided in 18 Pa. C.S. §4904.
Date:
Plaintiff, Pro Se
Assisted by:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
PETITION TO PROCEED 1N FORMA PAUPERIS
The Petitioner, ~t~Z',,at }Pt~ ~(~t~5- .~'~0~O.~ , is the Plaintiff in this action.
On the petitioner's behalf, MidPenn Legal Services does hereby certify that the Petitioner is
indigent according to the poverty guidelines of MidPerm Legal Services. MidPenn Legal
Services is assisting the Petitioner in filing a divorce case pro se. The Petitioner's Financial
Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests
leave to proceed without payment of fees or costs.
Respectfully submitted:
Je
Jennifer Hoffman
Pamela G. Smith
Attorneys for Plaintiff
MidPenn Legal Services
Pro Se Divorce Clinic
8 lrvine Row
Carlisle, PA 17013
(717) 243-9400
Plaintiff
: 1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
Defendant :
CIVIL TERM
AFFIDAVIT IN SUPPORT OF PETITION
TO PROCEED IN FORMA PAUPERIS
1. I am the t~ ~ in the above matter and because of my financial condition
am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs
of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is true
and correct.
(c) Social Secufi, Number:
If you are presently employed, state
Employer:
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment:
Salary or wages per month: ~". ~T) ~
· ypeofwork:
(c) Other income wi~in the past ~elve months
Business or profession:
Other self-employment:
Interest:
Dividends:
Pension and a~uities:
Social SecuriW benefits:
Support payments:
DisabiliWpayments: ~,')ta~ ~]o
Unemployment compensation and
supplemental benefits:
World's compensation:
Public Assistance: ~0~00 ~ ~
(d) Other con~ibutions to household suppo~
(Wife)(Husband) Name:
If your (husband) (wife) is employed, state
Employer:
Sala~ or wages per mon~:
T~e of work:
Contributions from children:
(e) Property owned
Cash: oqO.
Checking Account:
Savings Account:
Certificates of Deposit: 1,0 ] tot
Real Estate (including home): I'0 1
Motor vehicle: Make ~0 t-tJ( Year
Cost /tO ,~-~ Amount owed
Stocks; bonds: 1~d }
Other:
(0 Debts and obligations
Mortgage: fi, fi/lq
Rent: cT~gCh -"0 0
Loans:
Monthly Expenses: ,_~'tl 0 ·
(g) Persons dependent upon you for support
(Wife) (Husband) Name: /1~/d}
Children, if any:
Name:
Age:
4. 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.
5. 1 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 unswom falsification
to authorities.
Date: /-"J-cOq
Patricia M. Winters-Strouse
Plaintiff
V.
Jeffrey J. Strouse
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-392 CIWL T~RM
IN DIVORCE
AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE
I, //~Oq[~mr~ ~--~-trl¢~/fft° , do hereby swear that l have served JefferyJ.Str°use,
with a Divorce Complaint under Section 3301 (c) of the Divorce: Code by personally handing him
a copy at
/.~ , (Street Number and Address)
(City) v c} (State) (Zip)
at j. 3 {3 ~ .m. on the /~) day of Ojl.~_~ 200
(Time) (Date) (Month) (Year)
I, /Q2~4.~-? ~°.~71rl)~'~~-- , verify llhat the statements made in this
Affidavit of Service 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.
'3 /o--oq
Date: ~ , - t
Patricia M. Winters-Strouse,
Plaintiff
V.
Jeffrey J. Strouse,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-392 CIVIL TERM
INDIVORCE
Date
ACCEPTANCE OF SERVICI~
I, Jeffrey J. Strouse, accepted service of a true and correct copy of the
Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904,
relating to unsworn falsification to authorities.
Jefltf~ J.~ gtrot~,, ~ndant
Patricia M. Winters-
Strouse,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COLrNTY PENNSYLVANIA
No. 04-392 CIVIL TERM
Jeffery J. Strouse,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 30,
2004.
2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have
elapsed from the date of filing and service of the Co:mplaint.
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 tree 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 aut~. ,
Date: ~9 3~ O Signatu~e:/~x CJCk ~P~ ]~;~d3fi 'Z_ ~
Patricia M. Winters-S~trouse, Plaintiff
Patricia M. Winters-
Strouse,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-392 CIVIL TERM
Jeffery J. Strouse,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI 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 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 unswom falsification to authorities.
Date:~
Patricia M. Winters-Strouse, Plaintiff
IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff :
Vs : File No. c~,i9 q_
/ -- Defendant :
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/defendant in the above matter,
[select one l~y marking
M prior to the entry ora Final Decree in Divorce,
or __ after the entry of a Final Decree in Divorce dated
hereby elects to resume the prior surname of [,?.~~,O~ , and gives this
written notice a¥owing his / her intention pgrg~t to ~e provisions of 54 P.S. 704.
Signature of name being resumed
COMMONWE~TH~OF PENNSYLVANIA )
COUNTY OF ~
Onthe '~ dayof ~/k/~ ,2004, beforeme, the Prothonotary or the
notary pubhc, 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[~ereunto set my~j ;d official
seal.
Ir)aw, M. SHU~,^,I. Notary Public I Notary Pul~lic'
~ Carlisle, Cumbedand County
]My Commission ........ Expires Nov, 28, 2006
Patricia M. Winters-
Strouse,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-392 C, ML TERM
Jeffery J. Strouse,
Defendant
IN D1VORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 30,
2004.
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 authorifes. ~ t~
Patficia M. Winters-
Strouse,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
No. 04-392 CIVIL TERM
Jeffery J. Strouse,
Defendant
IN DWORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER §3301(c) OF 'rilE DWORCE CODY,;
I consent to the entry of a final decree of divorce without notice.
I understand that I may lose fights concerning alimony, division of property, lawyer's
fees or expenses ifI 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 flied with the
Prothonotary.
I verify that statements made in this affidavit are tree 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.
Signature:
Je~
Patricia M. Winters-
Strouse,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-392 CIVIL TERM
Jeffery J. Strouse,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORI)
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 March 10, 2004.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of
the Divome Code: by Plaintiff, June 30, 2004; by Defendant, July 26, 2004.
4. Related claims pending: There are no outstanding claim~.
5. (a) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: July 2, 2004.
(b) Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: August 9, 2004.
Plaintiff's Social Security Number: 191-46-0795
Defendant's Social Security Number: 463-41-2524
Jessica Diamondstone
Grace D'Alo
Geoffrey Biringer
Attorneys for Plaintiff
MidPenn Legal Services
8 h-vine Row
Carlisle, PA 17013
(717) 243-9400
IN THE COURT OF CO~IMON
OF CUMBERLAND COUNTY
STATE OF ~ ..,~~
Winters Stroucc
NO.
VERSUS
Jeffery J. Strouse
PENNA.
04-392
PLEAS
DECREE IN
AND NOW,
DECREED THAT
DIVORCE
Patricia M. Winters-~ern~,=~
AND Jeffery j. Strouse
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;
NONE
BY TH~ COURT:///J
ATTEST: ~ · · ~ j-.
. ----f g PROTBONOTARY