HomeMy WebLinkAbout04-0394Chrystal M. Moyer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-394 C~VIL T~RM
Dale E. Moyer,
Defendant
INDIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 30,
2004.
2. The marriage ofplaintiffand 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 ora final decree of divorce after service of notice of
intention to request entry of divome.
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.
CFxrystal ~. Moyer, Plaintiff j~
D
Chrystal M. Moyer,
Plt(mtiff
.' IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
No. 04-394 C~XaL TERM
Dale E. Moyer, : IN DIVORCE
Defendant
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 divome.
I verify that the statements made in this affidavit are true aj~ld correct. I understand that
false statements herein are made subject to the penalties, reft 18 Pa.C.S. Section 4904
relating to unswom falsification to authorities.~/------
Date: ~' c.~(9 / Signature:
Chrystal M. Moyer,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
No. 04-394 CIVIL TERM
Dale E. Moyer, : IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A
DIVORCE DECREE UNDER l}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 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 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.
Chrystal Iv[ Moyer, Plaintiff
Chi3,stal M. Moyer,
Pla'tariff
IN THE COURT OF COMMON PLEAS OF
CUMBERLA]qD COUNTY PENNSYLVANIA
No. 04-394 CiViL T~RM
Dale E. Moyer,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST 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 tree and correct. I understand that
tfoal~lsStwaot~nm;aqtsSifihceart~ionn taXoe amutahdoeriStiueb '~~~. C.S. §4904 relating
Chrystal M. Moyer,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
No. 04-394 CML TERM
Dale E. Moyer,
Defendant
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 Accevtance
and Acknowledgment of Service form on February 29, 2004.
3. (a) DateofexecutionoftheAffidavitofConsentrequiredbySection3301(c)of
the Divorce Code: by Plaintiff, June 2, 2004; by Defendant, June 3, 2004,
4. Related claims pending: There are no outstanding claims,
5. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: June 4, 2004.
(c) Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: June 4, 2004,
Plaintiff's Social Security Number: 207-64-5342
Defendant's Social Security Number: 164-52-8581 ~'/~
Jessica/Diamondstone
Attorney for Plaintiff
MidPenn Legal Services
8 lrvine Row
Carlisle, PA 17013
(717) 243-9400
IN THE COURT OF COMMON PLEAS
Chrystal M. Moyer
OF CUMBERLAND COUNTY
STATE OF PENNA.
NO. 04-394
Civil
VERSUS
Dale E. Moyer
DECREE IN
DIVORCE
AND NOW, l.~_
DECREED THAT Chrystal M. Moyer
AND Dale E. Moyer
, 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;
ALL CLAIMS HAVE BEEN RESOLVED
PROTHONOTARY
IN THE'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANLA
CIVIL ACTION - LAW
Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU JlA VE.BEEN SUED IN COURT. If you wish to defend against the claims set fo~h
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 agairmt 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 mart/age, you
may request marriage counseling. A list of marriage counselors is ava/lable 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 TIlE 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
(T17).¢4~9r3166
Defendant
IN Tl-n~ COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04- Cw~ TERM
IN DIVORCE
COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE
I. Plalntiffis Chw'J)~-~.i ~ I'¥l¢~/10.~. who currently resides a,
Cumberland Count, 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 ~e six months prior to ~e filing of~is Complaint.
4. Plaintiff and Defendant were ma~ied on ~ ~ lq~ at
5. The ma~iage is i~etfievably broken, and the pa~ies sep~ated on
d. There have been ~o prior aotions oCdivorce or ~ulment be~een the pa~ies.
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 connseling and that Plaintiffmay 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
Plaintiff, Pro Se
~r~(~j~ verify 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:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Plaintiff
V.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. c q.3qq
CIVIL ACTION - LAW
1N DIVORCE
PETITION TO PROCEED IN FORMA PAUPERIS
ThePetiti_o, ner, 0_,~ _~CLI ¥~ ~){~0~'~/ , is the Plaintiffin this action.
On the petitioner s behalf, MidPenn Legal Services l~oes 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:
Jessica ~
Jennifer Hoffman
Pamela G. Smith
Attorneys for Plaintiff
MidPenn Legal Services
Pro Se Divorce Clinic
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Plaintiff
VS.
Defendant
[~/)0~. INII~ THE COURT OF COMMON PLEAS OF
(J ::
CUMBERLAND COUNTY, PENNSYLVANIA
No. O~/-~c~t/ civil TEP, M
AFFIDAVIT IN SUPPORT OF PETITION
TO PROCEED IN FORMA PAUPERIS
1. i am the 9 I O i ~ ~ri ~ in We above matter and because of my .nanoial condition
am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am ~able to obtain ~nds from anyone, including my family and associates, to pay the costs
of litigation.
3. I represent ~at the info~ation below relating to my abiliW to pay the fees and costs is tree
and co~¢ct.
(a) Name: ~¢~ ~ ~~
(b) Address: ~ ~ ~ ~?~ ~ ~l~
(c) Social Securi~ Number: ~ - (~q $,~
If you are presently employed, state
Employer: ~[~ ~~¢
Salary or wages per month:
· ypeofwork:
If you are presently unemployed, state
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
Business or profession:
Other self-employment:
Interest:
Dividends:
Pension and annuities:
Social Security benefits:
Support payments:
Disability payments:
Unemployment compensation and
supplemental benefits:
Workman's compensation:
Public Assistance:
Other:
(d) Other contributions to household support
(Wife)(Husband) Name:
If your (husband) (wife) is employed, state
Employer: ~ i Ch ~-~/[
Salary or wages per month:
Type of work: ~ (~('/c'LQ%
Contributions from children:
(e) Property owned
Cash:
Checking Account: !t~ 6,0tS
Savings Account: c~. ~
Certificates of Deposit:
Real Estate (including home):
Motor vehicle: Make CJ~O~J Year q ~
Cost 15Do.C~ Amount owed
Stocks; bonds:
Other:
(f) Debts and obligations
Mortgage:
Rent:
Loans: 1~oo ,o-O
Monthly Expenses:
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
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 pemfit me to pay the costs incurred herein.
5. 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.
Chrystal M. Moyer,
Plaintiff
IN THE COURT OF CO~[IVlON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04- 394 CIVIL TERM
Dale E. Moyer.
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I /~¢ /'~ /~O/e3'- , accepted service ,,fa tree 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.
Date
Da~e E.'Moyer, De~nt