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Home My WebLink About08-7024Ms. Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Scott Lamason, Defendant : NO. 08- 7G?)y CIVIL TERM 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 the 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Ms. Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Scott Lamason, : Defendant : NO. 08- '70 2 `f CIVIL TERM DIVORCE COMPLAINT WITH ALIMONY COUNT The plaintiff, Ms. Renee Lamason, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and alimony: COUNTI DIVORCE UNDER 23 Pa.C.S. §53301(a)(6), (c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Ms. Renee Lamason, who currently resides at 104 Tip Top Circle, Carlisle, Cumberland County, PA 17013 since November 26, 2007. 2. Defendant is Scott Lamason, who is currently residing at the Cumberland County Prison located. at 1101 Claremont Rd, Carlisle, Cumberland County, PA 17013 since October 4, 2008. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 14, 2003 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since approximately June 27, 2008. 6. Defendant has been physically abusive towards Plaintiff and a Temporary Protection From Abuse Order was issued as a result of the abuse, Docket Number 08-4436, on July 25, 2008. 7. There have been no prior actions for divorce or for annulment between the parties. 8. Defendant has committed indignities against the innocent and injured Plaintiff so as to render Plaintiff's condition intolerable and life burdensome. 9. The marriage is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 11. Defendant is not a member of the armed services of the United States. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II ALIMONY 12. Plaintiff repeats and realleges paragraphs one through eleven as if fully set forth herein. 13. Plaintiff requires support to adequately maintain herself according to a reasonable standard of living. 14. Plaintiff was not substantially employed during the marriage. WHEREFORE, Plaintiff requests the Court to enter an award of reasonable alimony, and such other relief as the Court deems just. DATE I ?L11 / d'? Respectfully Submitted, "o r 1' 'C4-? uchika Gupta Certified Legal Intern ME N RIESMEYER ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DateL(-17 - ?? Plaintiff Ms. Renee Lamason C- ? ; rt ) -T? Ms. Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Scott Lamason Defendant NO. 08- 740CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Renee Lamason, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date P a I N Respe lly submitted, chika G Certified Legal Intern MEGA ESMEYER ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 - cc5 > Co Ms. Renee Lamason, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE Scott Lamason , ; Defendant NO. 08-7024 CIVIL TERM AFFIDAVIT OF SERVICE I, Ruchika Gupta, hereby certify that I personally served a true and correct copy of the Divorce Complaint on Scott Lamason at Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013 at .00 m. on Monday, December 8, 2008. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: kauchi Certified Legal Intern co ?s ? ? i ?7s RENEE LAMASON, Plaintiff V. SCOTT LAMASON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE NO. 08-7024 CIVIL TERM PRAECIPE TO WITHDRAW ALIMONY COUNT To the Prothonotary: Please withdraw the Count for Alimony (Count II) in the above-captioned matter filed in the Cumberland County Courthouse on December 1, 2008. Date: log . Luke Smith Certified Legal Intern Anne d-Fox Thomas Place Robert Rains Megan Riesmeyer Supervising Attorneys The Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717)243-2968 a ?i Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Scott Lamason, Defendant : NO. 08-7024 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 1, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. 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 unsworn falsification to authorities. Date `",L 1 J Scott Lamason, Defendant F{U_L,l OF TH? 2nu G9 SEEP 2 u F?i 1 • 6J Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Scott Lamason, Defendant : NO. 08 - 7024 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 0301(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 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 unswom falsification to authorities. Date G - Scott amason, Defend ant FL EL;. PR OF T-'F h !n t,,y 2309 SLEP 23 Pil ! : 26 Ct..:i :-ry Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Scott Lamason, Defendant : NO. 08-7024 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 1, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. 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 unsworn falsification to authorities. Date 6-Z'-wJ Renee Lamason, Plaintiff fiOF T!f Prk' NOTARY( 2009 OCT -5 PM -3: 37 CUB, ?-_,.--, ,?. UNTY F`_i,Jt,SYDJANIA Renee Lamason, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Scott Lamason , Defendant :NO. 08 - 7024 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 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 unsworn falsification to authorities. Date Z - °1 Renee Lamason, Plaintiff OF ? THr4-OTARY 2009 aC T -S PM 3: 3 7 P?P4??51'I.VAN Renee Lamason, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE Scott Lamason , Defendant NO. 08 - 7024 CIVIL TERM CERTIFICATE OF SERVICE I, Luke Smith, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Plaintiff's Affidavit of Consent and Waiver of Notice on Scott Lamason, residing at Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013, by depositing a copy of the same in the United States first-class mail. Service was made on the 5 h day of October, 2009. C_ uke Smith Certified Legal Intern &qkm kw??? Meg Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 CF l PRQ; ICTARY 2009 OCT-5 PM 3: 37 E NSYLV NI Renee Lamason , Plaintiff V. Scott Lamason, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE : No. 08 - 7024 CIVIL TERM 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by personal service at Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013 on Monday, December 8, 2008. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff- October 2, 2009; by Defendant- September 20, 2009. 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: October 5, 2009. Date Defendant's Waiver of Notice was filed with the Prothonotary: September 28, 2009 G r9 ? ? ?' t Date uke Smith Certified Legal Intern Meganesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff FUD-OFFICE OF THE PROTHONOTARY 2009 OCT -S PM 3: 41 CUt:, t rl,,,f (1?.J1`hVi f 'ti R INSYLVANIA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. co Tr- A-Em-r--1 NO. CAS - 4-0 2-q DIVORCE DECREE AND NOW, it is ordered and decreed that 4 tE7N eE? LAVAR-'? 1--) , plaintiff, and 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.") /40 F-J? l e Court, Attest: J. / A?Zji? - -1? In. Prothonotary J . sonJ C`'PY ?--n/yl