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HomeMy WebLinkAbout08-3254 Sonya J. Milbourne IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. N0.08- 3xZ6-4 CIVIL TERM Ricky B. Milbourne Defendant 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 Sonya J. Milbourne Plaintiff V. Ricky B. Milbourne Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 3a S-y IN DIVORCE CIVIL TERM COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is 56 n - k64 who currently resides atlD X00 Ofheya i)r rw4. ?'1GVYlieSGur?? POP Cumberland County, Penns?y/l?v/a}ni(a. 2. Defendant is C le 1 ' I I 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 at e( acwat" f- ?tk? ?Ai 5. The marriage is irretrievably broken, and the parties separated on Q / ") /0 e 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. l Date Plaintiff, ro Se beq GYM ? ' rkl,? , 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. Date: Assisted by: Thomas J. Williams, Esq. Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-1383 ? r- N ? ? -- ? l -? # ? --?• F-I ....?; i'T7 ? N Y`t r .., - _ -'f {- _.:- ?. ?' .. { 4..f - -C Sonya J. Milbourne Plaintiff V. Ricky B. Milbourne Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- jaS4 CIVIL TERM . IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Sonya J. Milbourne Plaintiff, to proceed in forma au eris. I, Thomas J. Williams, 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. Thomas J. W liams, Esquire Attorney for Plaintiff Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-3341 C°7 +? <? w i tom:? r , -r- ---r :c: _? n?F-r; ?i r_.! ,. ? `° _ ` .. j ?` - ? F:\F1LES\Cknts\5492 Mid Fenn\5492.77\MZourne\5492.77.ptareinstate Revised: BASIN 10:13AM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SONYA J. MILBOURNE, Plaintiff V. RICKY B. MILBOURNE, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3254 CIVIL ACTION - LAW IN DIVORCE PRAECIPE Please reinstate the Divorce Complaint. MARTSON LAW OFFICES By ?t Aa Thomas J. William , Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: August 15, 2008 V co a ' 77 F:\F1LES\C1ients\5492 Mid Penn\5492.77\Milboume\5492.77.aos Revised: 8/19/08 0:00PM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SONYA J. MILBOURNE, Plaintiff V. RICKY B. MILBOURNE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3254 CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Ricky B. Milboume, Defendant, 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. Date: 0? 0? 0/ "??? .11 _?. ?, °; asp ?;; ? ? , _ ?? ? ? ` -c? - ,? ' ' ? . _ .. E r?t y ? ? -?1 Sonya J. Milbourne IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08-32?y CIVIL TERM Ricky B. Milbourne Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complai t in divorce under §3301(c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety dayls, have elapsed from the date of filing and service of the Complaint. 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 pe lties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date:ZZZ? Signature: Sonya J. 'lbou e, Plaintiff ,,.-, rv %oj #`.. Sonya J. Milbourne Plaintiff V. Ricky B. Milbourne Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08-3asN IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(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. //? 6 '- k )ate/ Signature: Sonya J.1VI'ilboufne, Pli['intfff