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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 a w 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. 0 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 C'} <^?a ? c ? ?.3 ??v "ei ? ?y-f f j d? ??,? ?' ("' 1 °" i _ ? _ ,:? ? `_ T i";'q ? '?? £.,, 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. IQ? " AAV,----/ Michael A. Hynum, Es Attorney for Plaintiff ui Hynum Law Office 2608 North 3rd St. Ilarrisburg, PA 17110 (717) 774-1357 r^, r.. ? ca ?? cx? O _-„;1 ,...,..? i k j i ' ''' C. .--?; ?' OF;.' Heather M. Robson IN THE COURT OF COMMON PLF4 't, Plaintiff CUMBERLAND COUNTY PENNST V. NO. ? CIVIL TERM Maynard E. Robson c= M Defendant IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME ,4 I' --4 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. c- 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. g=. C'? o IN WITNESS WHEREOF, I hereunto set my hand and official seal. LofOffi SEAL ) 1 e cer "ice Is1rs re ?. d P s'-,.?., d, tfF TM.'?w...?? . , P o cash NA 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 t? N d D W 1 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: 4 1 r ¦ 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) R* B ate Delivery A W .fHG? 22? IL 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 , - ff Defendant IN DIVORCE HIM tr _ -- -Or n -„ 7_ cr AFFIDAVIT OF CONSENT d 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 o v. NO. 10- CIVIL TERM rr, L Maynard E. Robson Defendant IN DIVORCE =- C: . f ; r4: 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. rvl 2 q4 2.010 1..?p. r1dwom Date Ma "I rd E. Robson, Defendant e o 'v3 z 0 C ter.., c7 r?-z to r q ti ti M A 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 C-> -p 3 ca 0` ---t xr C--) v rnm y -+C Gu 8 9v 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 C ? ? C ?m ;:o - > `< w r , C) ,a C7 Q ., Q -t -- "?; ? /\3 --q v? 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". r? ? G Heather M. Robson Plaintiff Pro Se U-C:> 0- Assisted by: Abraham Prozesky, Esquire PA ID# 209787 stn 674 Stover Court -j -UJ w U-J= w Hummelstown, PA 17036 i, co 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 is/a7?io- l;erF. C?p`I rno 'led No+iee f 4t, mailed ,b