HomeMy WebLinkAbout04-0595YN THE 'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff :
/~;n/a~ tl V£R;Defenaant :: IN DIVORCE
Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOUHA FE 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 Cot~. A judgment may also be
entered against you for any other claim or relief requested/n 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, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GR_4,NTED, 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} ¢4_9r3166
Ee ban dema.ndado a usted a la corte. Si usted quiere 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 dem~mctns 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 notitieacion y por cualquier que ja o alivio que es pedido en
la peticion do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS
DERECHOS IMPORT.ANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLA&/iE POR TELEFONO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR 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 accessit~l¢ facilities and reasonable
accomrnodations available to disabled individuals having business before the Court, please contact
our office. All m-rangements 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.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04- i~ Clvm TERM
IN DIVORCE
COMPLAINT UNDER {3301(c) or (d) OF THE DIVORCE CODE
171 ~,v who currently resides at
Cumberland County, Pennsylvania.
2. Defendant is [/~/ig~/ ,O?O,~drd who cu~ently resides at
3. Pla~tiff has been a bonafide resident of the Co~onwealth of Pe~sylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on /~ ~-/ C~ ~ at
o/-/r,'~,· oF ':'~ ~>~,,~4__:,~'~ :iP~ve~ ~, TOFp~~
5. The ma~iage is i~e~evably broken, and ~e pa~ies sep~ated on
/ - P~ 2 c> :_.
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 m~d that Plaintiff may have
the fight to request that the Court require the parties participate in counseling.
WHE~FO~, Plaintiffrequests the Court to enter a Decree of Divorce.
I~ate
I, ? ~ c~ - ~ c ,, , 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 unswom falsification to authorities as
provided in 18 Pa. C.S. §4904.
/
Date:
AsSisted by:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Plaintiff
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. O"t
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION TO PROCEED IN FORMA PAUPERIS
The Petitioner, L~/flf]L fi. ~o~d~t?5/V) , 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 MidPenn 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:
Jessi~tone
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
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: N0.O q- 4'94' CWIL TERM
1. I am the
AFFIDAVIT IN SUPPORT OF PETITION
To ROC ED IN FORM^ P^UP PaS
/z(:- 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 fanfily 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.
(b) Address:
(c) Social Securi~ Number:
If you are presently employed, state
Employer: -42'f ~ ~- h e
If you are presently unemployed, state
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past t~velve months
Business or profession:
Other self-employment: //2~'7
Interest:
Dividends: ,,~-//
Pension ~nd annuities:
Social Security benefits: ~ j //3
Support payments: ,fi~ '~' /
Disability payments: /L) /
Unemployment compensation and /
supplemental benefits: ,pL...;
Workman's compensation:
Public Assistance:
Other: fl/ /
(d) Other contributions to household support
/
(Wife)(Husband) Name:
If your (husband) (wife) is employed, state
Employer: ~-~. ~--r-~r
Salary or wages per month:
Type of work: .q--~fzV (~ Q
Contributions from children:
(e) Property owned
Cash: /~ ~.
Checking Account: ~ O ~e ~- c{ ~ ~%
Savings Account: ~///
Certificates of Deposit: //41 f
Real Estate (including home): /r/j /
Motor vehicle: Make -~4° Year
t)ooAmount owed
.Stocks; bonds:
O er:
(f) Debts and obligations
Mortgage:
(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 cimumstances, which would permit me to pay the costs incurred heroin.
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 unsworu falsification
to authorities.
Date:
Plaintiff
V.
Defendant
: IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. ~
: CIVIL ACTION - LAW
:
: IN DIVORCE
AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE
, ±~( ,! ,Vwe /q'- /~6r~ , do hereby swear that l have served
/6YSqO~c~'J~ //~o ~q~ a~r~r o5 ~ :'with a ~.. ~ ,
~ u~vorce complaint ~d PlaintiWs
Affidavit under Section 3301 (d) of ~e Divorce Code by personally handing hi~er
copy at
(Street Nmnber and Ad.ess)
(CiW) { (State) (Zip)
at~ ff .m. onthe ~]~
200 ~ day of
(Time) (Date) (Month)
in this
(Name of person who performed service)
(Year)
, verify that the statements made
Affidavit of Service is tree and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification
to authorities.
Date:
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. ot4-sq r
CIVIL ACTION - LAW
~ DIVORCE
ACCEPTANCE OF SERVICE
I ~tlll~ ~, ~2t0]O.Skt' , do hereby depose and say that, on behalf of
(nam(] of person accepting service)
and on the authorization of the Defendant, I personally received and accepted service of a
true and correct copy of the Complaint in Divorce 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 unswom falsification to authorities.
Name of person accepting service
Date
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04- 595 CIVIL TERM
Defendant
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
to live separate and apart for a period of two years.
and continued
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,(~~d. i~ ~'
o ~ ~_ ~ o~, 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.
Date
//Plaintiff, Pro Se
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
No. 04- ~.~- ClVm TERM
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
I, /~tb//--i /Lb'l/(// ,doherebyswearthatlservedt~t~,~tmnd~ta~s]'[witha
Plaintiff's Affidavit under Section 3301 (d) of the Divorce Code pursuant to Pa.R.C.P.
1920.42(a)(2) on the i~'~ day of M i~tzh ,2004, by regular mail and certified mail,
return receipt, restricted delivery, to the person and address below:
0 '
I,~ :[v(al?..I~' 'll{t'll~1 Ink.~l'l a~r ~ ~L J , veri~ ~at ~e statements made
in ~is Affidavit of Se~ice ~e ~e ~d correct. I ~dersmd ~at hlse statements herein are
made subject to ~e pemlties of 18 Pa.C.S. Section 4904 relating to ~sworn f~sification to
au~orities. /
Date: 5/1~/0~ Sig~mre
Plaintiff
VS.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COLrNTY PENNSYLVANIA
No. 04- ..f'q5 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(d) of the
Divorce Code.
2. Date and Manner of service of the Complaint: Defendant signed Acceptance
of Service form on February 11, 2004 and Plaintiff signed Affidavit of Personal Service form
February 11, 2004.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of
the Divome Code: by Plaintiff, N/A; by Defendant, N/A.
(b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d)
of the Divorce Code: February 18, 2004.
(2) Date of filing and service of Plaintiff's Affidavit upon Defendant:
Filing Date: March 18, 2004
Date of Service: March 18, 2004
4. Related claims pending: There are no outstanding claim~,
5. Complete either paragraph (a) or (b).
(a) Date and manner of service of the notice of intention to file Praecipe to
Transmit Record, a copy of which is attached: Mailed by regular first class mail on
April 8, 2004 to Defendant at 219 Herman Avenue, rear, Lemoyne, PA 17043.
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with
the Prothonotary: N/A.
(c) Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: N/A.
Plaintiff's Social Security Number: 231-86-7168
Defendant's Social Security Number: 187-42-5703
%ssi~ Diaanondstone
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Plaintiff
VS.
Defendant
IN THE COURT OF COMMON PLEAS OF
CLrMBERLAND COUNTY PENNSYLVANIA
No. 04- ffq~; CIVIL TERM
: IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE DECREE
TO: Raymond F. Romanoski, DEFENDANT
You have been sued in an action for divorce. You have fail[ed to answer the complaint or
file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after April 29, 2004, the other
party can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in
divorce. A counter-affidavit, which you may file with the prothonotary of the court, is attached
to this notice.
Unless you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief. The filing of the form counter-affidavit alone does not protect
your economic claims.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPOHNE TI4E OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELp.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166 OR 1'800-990-9108
Plaintiff
vs.
Defendant
IN THE COURT OF COIvlMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVAN~
NO. 04- 5'?5 CiViL TEPJvi
: /N DIVORCE
.COUNTER-AFFIDAVIT UNDER §3301(d) OF TH]g DIVORCE COD~;
i. 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 all that apply):
[] (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.
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
And expenses ifI 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. IfI 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 notice to me, and I shall be unable thereat%er to file any economic claims.
I verify that the statements made in the 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 unswom
falsification to authorities.
Date:
, Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THJE ENTRY OF A
DIVORCE DECREE AND YOU DO NOT WiSH TO
MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU
SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
IN THE COURT OF COMMON
LYNNE A. ROMANOSKI
OF CUMBERLANDCOLJNTY
STATE OF ~~.. PENNA.
PLEAS
DECREE IN[
D'VORCE ~ t~ ~,~ ~it~,~
' .
AND NOW, ~' ~f, IT S ORDERED AND
LYNNE A. R~MANOSKI
DECREED THAT , PLAINTIFF,
AND
RAYMOND F. ROMANOSKI
,DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOI-LOWING 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