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HomeMy WebLinkAbout08-66920. b? 1 Wayne R. White Plaintiff V. Kelly R. White Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- ?V9a CIVIL TERM 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 Wayne R. White Plaintiff V. Kelly R. White Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 4 1- CIVIL TERM IN DIVORCE t COMPLAINT UNDER §13301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is A ? t? V?Vk.- , who currently resides at o (D Gar 115 1 e Pi4 203 Cumberland County, Pennsylvania. 2. Defendant is ?e-WA Rae W litC-, who currently resides at 13 01 Vood Creek ?-csr m Rah Al ek4A der c ? 4/ A LA,baMq, 35-olo 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 q /01 Y103 at ?o?,sU??i>? Kv CoUr4 koo? 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. 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. lo? -'tJ Date Plaintiff, P Se 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. I Date: 1- Q Plaintiff, Pro e Assisted by: Michael J. Whare, Esq. Law Offices of Michael J. Whare 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 Irk CT Wayne R. White IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- r<O ?iCl vZ CIVIL TERM Kelly R. White Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Wayne R. White, Plaintiff, to proceed in forma au eris. I, Michael J. Whare, 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- '/ )17 A Michael J. Whare, fuir eAttorney for Plainti Law Offices of Michael J. Whare 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 ca ? G? Wayne R. White Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. Kelly R. White Defendant NO. 08-( 4q )? CIVIL TERM 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 The parties to this action separated on +3 0,5- and continued to live separate and apart for a period of two years. 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, W04A Z 'r, W ? ??? , 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. W I I a o? Date Plaintiff ro Se .... ,"? .?- C.: ??' 3 .. Wayne R. White IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- (Q 4 Gl a. CIVIL TERM Kelly R. White Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Kelly R. White (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (d) 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. L1, 08 Ka E Date Kelly R. ite, Defendant :d Wayne R. White Plaintiff V. Kelly R. White Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08-GG% CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(N) 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. /-d 1111ej -QMhtc, -X Date: °j Signature: Wayne R. hite, Plaintiff 1 t:: i Wayne R. White Plaintiff V. Kelly R. White Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08-46qa CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $33010 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: I^l' C`ng Signature: ktR -LI., Kelly RUWhite, Defendant lL.4?'.= ' ? ? T ,,. a? t`.'S ., l.f? _? ..??. ?^` 1 ' ? V s? -' F .,. t? r • , WAYNE R WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 08-6692 KELLY R. WHITE, Defendant IN DIVORCE PRAECIPE TO TRANSNIIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Filed November 12, 2008, was served on the Defendant by certified mail, endorsed restricted delivery-return receipt requested and Defendant signed an Acceptance of Service dated November 17, 2008 3. (b) (1) Date of execution of the affidavit required under by §3301(d) of the Divorce Code: November 12, 2008. (2) Date of filing and service of plaintiff s affidavit upon the respondent: Filed November 12, 2008 and served on the respondent on November 17, 2008. 4. Related claims pending: None. 5. (b) Date Plaintiffs Waiver of Notice in § 3301 (d) Divorce was filed with the Prothonotary: January 5, 2009. Date Defendant's Waiver of Notice in § 3301 (d) Divorce was filed with the Prothonotary: January 5, 2009. Respectfully submitted, Date: 4.,J 1,,A Michael J. Whar, Esquire 3 7 East Pomfret Street Carlisle, Pa 17013 (717) 243-3561 Supreme Court ID # 89028 Attorney for Plaintiff ,.,, ?_.' ? ..? -?? ? ? ,_., : , .. ce t i t„3's °^.'3 .....? ;-k?q C..? ; i :.x.;, Wayne R. White IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Kelly R. White No. 2008-6692 DIVORCE DECREE AND NOW, JG d? , it is ordered and decreed that Wayne R. White , plaintiff, and Kelly R. White , 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. Attest: J. Prothonotary r +I?h?/1?