HomeMy WebLinkAbout08-6062_ A
Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 08- W&A CIVIL TERM
Maynard E. Robson
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
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Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 08- GO 1,;/- CIVIL TERM
Maynard E. Robson
Defendant IN DIVORCE
COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE
c 1. Plaintiff is e a+k-tr P1 who currently resides at
Cumberland County, Pennsylvania.
2. Defendant is G?J ?'1(tit't? t C)bSr- , who currently resides at
?VRQ-C-' irxct'l tk 1AfttS ?u?\ C6al<`?I f? ?6 IS
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
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.
'A 14
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.
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DaCe Plaintiff Pro Se
I, 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.
Plaintiff, Pro Se
Assisted by:
Michael A. Hynum, Esq.
Hynum Law Office
2608 North 3rd St.
Harrisburg, PA 17110
(717) 774-1357
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Heather M. Robson
Plaintiff
V.
Maynard E. Robson
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 08- W(ol
CIVIL TERM
IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Heather M. Robson, Plaintiff, to proceed in forma pa uperis.
I, Michael A. Hynum, 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.
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Michael A. Hynum, Es
Attorney for Plaintiff ui
Hynum Law Office
2608 North 3rd St.
Ilarrisburg, PA 17110
(717) 774-1357
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Heather M. Robson IN THE COURT OF COMMON PLF4
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Plaintiff CUMBERLAND COUNTY PENNST V. NO. ? CIVIL TERM
Maynard E. Robson c= M
Defendant IN DIVORCE
NOTICE OF ELECTION TO RETAKE FORMER NAME
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Notice is hereby given that Plaintiff in the above matter filed a Complaint in Divorce
filed on Heather Marie Robson hereby intends to resume and hereafter use her previous name of
Heather Marie Teats and gives this written notice avowing her intention in accordance with the
provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980.
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Heather Marie Robson
11
Heather Marie Teats
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS
On this, the day of ,2010, before me, the undersigned officer
personally appeared , also own as known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the same for the purposes therein contained.
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IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Heather M. Robson
Plaintiff
V.
Maynard E. Robson
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
08-(o0(pa
NO.4-9- '
: IN DIVORCE
AFFIDAVIT OF SERVICE
CIVIL TERM
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I, 1e*`being duly sworn according to law, depose and say that on
D J (Date of signing of the green card by spouse), I served a true and
correct copy of the Divorce Complaint upon the Defendant, by Certified Mail, Restricted
Deliver, addressed as follows:
C'? fi51,e N-177010
The Certified Mail Return Receipt Mailing Card ("Green Card"), for the foregoing is attached
hereto and made a part hereof.
Sworn to and subscribed before me a
Notary Public in and for Cumberland
County, Pennsylvania
this day of , 20.
NOTARY PUBLIC
Sign at A? 46
Printed Name
My commission expires:
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¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
m n-t)? ob ti S2
C?,.> s c P- -[ 9613
A. Signature k ? Agent
? Addressee
I Pri Name)
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B ate Delivery
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D. Is delivery address different from item 1? ? Yes
If YES, enter delivery address below: ? No
3. Service Type
J4 Certified Mail ? Mail
? Registered ? etum Receipt for Merchandise
? Insured Mail ? C O D
A '? y W as?-?eA e e 4. Restricted Delivery? (Extra Fee) Yes
2. Article Number 7010 0290 0001 7802 4065
ffmsfer from service label)
Ps Form 3811, February 2004 Domestic Return Receipt 102595.02-M-1540
Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO.,
60W CIVIL TERM
06-
Maynard E. Robson -ri
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Defendant
IN DIVORCE
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AFFIDAVIT OF CONSENT
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1. A co" la ' divorce under §3301(c) of the Divorce Code was filed on
2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days hav e
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 authorities.
Date: ?L? Signature:
Heather M. Robson, Plaintiff
Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
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v. NO. 10- CIVIL TERM rr, L
Maynard E. Robson
Defendant IN DIVORCE
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WAIVER OF NOTICE OF INTENTION TO REQUEST 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.
Date: Signature: 4V4? 4W??K
Heather M. Robson, Plaintiff
Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
41
V. NO.CIVIL TERM
Maynard E. Robson
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Maynard E. Robson (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.
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Date Ma "I rd E. Robson, Defendant
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Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. t9- CIVIL TERM
Maynard E. Robson
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on
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 authorities.
Date: 6?tnW (? Signature: M-YjnN"IS ARC
Maynard E. Robson, Defendant
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Heather M. Robson IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
osSOPo?`a-
v. NO. lf?- CIVIL TERM
Maynard E. Robson
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST 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.
Date:, 2A11A Signature: !0 Ab" . E R"O^
Maynar E. Robson, Defendant
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Heather M. Robson
Plaintiff
V.
Maynard E. Robson
Defendant
To The Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 08 - 6062 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
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)(1) of the
Divorce Code.
2. Date and Manner of service of the Complaint: Defendant signed Acknowledgement
of Receipt for Certified Mail, Restricted Delivery, on April 22, 2010
3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code:
by Plaintiff, C) l ?-G Date of filing and service of the plaintiff's affidavit
upon the respondent: ce?009-.
4. Related claims pending: There are no outstanding claims.
5. Date and manner of service of the notice of intention to file praecipe a copy of
which is attached as Plaintiffs Exhibit "I".
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Heather M. Robson Plaintiff Pro Se
U-C:> 0- Assisted by: Abraham Prozesky, Esquire
PA ID# 209787
stn 674 Stover Court
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w Hummelstown, PA 17036
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HEATHER M. ROBSON IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MAYNARD E. ROBSON ;
DIVORCE DECREE
AND NOW, 7??w••Nr 2r v ?o , it is ordered and decreed that
HEATHER M. ROBSON , plaintiff, and
MAYNARD E. ROBSON , defendant, are divorced from the
bonds of matrimony.
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,
J.
NO. 08 - 6062
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