The URL can be used to link to this page

Home My WebLink About09-3594TORI LYNN TAVENNER IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA Plaintiff V. No. 2009 - 3 yq y CIVIL TERM IN DIVORCE CLAYTON DELANEY TAVENNER Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend 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 claim for 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 Court House Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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. Lawyer Referral Service Cumberland County Bar Association (717) 249-316frjor 800-990-9108 Attorney for P ntiff PA ID # 209'A87 401 E. Louther Street, Suite 103 Carlisle, PA 17013 Tel: (717) 243-9400 Date: j b 3 /01 TORI LYNN TAVENNER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiff V. CLAYTON DELANEY TAVENNER No. 2009 - 3 541 y CIVIL TERM IN DIVORCE Defendant COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Tori Lynn Tavenner, by and through her attorney, Abraham Prozesky, and files the following Complaint in Divorce: 1. Plaintiff is Tori Lynn Tavenner an adult individual currently residing at 110 Locust Way, Carlisle, PA 17015. 2. Defendant is Clayton Delaney Tavenner an adult individual currently incarcerated at SCI Graterford, PA 19426. 3. Plaintiff has resided within the Commonwealth of Pennsylvania for a period of six (6) months or more preceding the filing of this Complaint. 4. The parties were married on March 03, 2006 in Greencastle, PA. 5. There were no children born unto the marriage. 6. The parties have been living separate and apart since January 28, 2009. 7. Pursuant to § 3301(a)(5) of the Divorce Code the Plaintiff avers that the Defendant has been sentenced to imprisonment for a term of two or more years upon conviction of having committed a crime. 8. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 9. 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. 10. Defendant is not in the military service of the United States. 11. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff prays this Court to enter a Decree in Divorce. Respectfully submitted, i Abrah9pKProzes , PA ID #x09787 401 E. Lbuther Street, Suite 103 Carlisle, PA 17013 Tel: (717) 243-9400 Date: r 3 9, VERIFICATION I verify that the statements made in this Complaint 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 unworn falsification to authorities. Date: May 13, 2009 LYRN TAVENNER Respectfully ABRAHA??.'ZESKY, ESQ PA Id # 401 E. Luther St, Suite 103 Carlisle, PA 17013 Tel: (717) 243-9400 CX) FILEF" w ; `-r: [. ? j u i i - i I "1 's [Y E CIO ?, ?4-- / TORI LYNN TAVENNER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiff V. No. 2009 - 3594 CIVIL TERM CLAYTON DELANEY TAVENNER Defendant DIVORCE MOTION FOR APPOINTMENT OF A MASTER AND NOW, comes the Plaintiff, Tori Lynn Tavenner, by and through her attorney, Abraham Prozesky, and moves the court to appoint a master with respect to the following claims: ( x) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite ( ) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses and in support of the motion states: (1) Discovery is not complete as to the claim(s) for which the appointment of a master is requested. Discovery is not necessary. (2) The non-moving party has not appeared in the action personally or by his attorney. (3) The statutory ground(s) for divorce is, pursuant to § 3301(a)(5) of the Divorce Code, that the Defendant has been sentenced for a term of 9 (nine) to 18 (eighteen) years imprisonment in Graterford State Correctional Institute upon conviction of having committed a crime. (4) The action is not contested. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take 1 (one) hour. Respectfully submitted, Date: Z G dq G/ AB V PR ESKY, ESQ PA ?097 401 E. Lou er St, Suite 103 Carlisle, PA 17013 Tel: (717) 243-9400 VERIFICATION The above-named Plaintiff, Tori Lynn Tavenner, verifies that the statements made in the attached Motion for Appointment of a Master are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: &I2?q I m ?f Tori Lynn Tavenner TORI LYNN TAVENNER Plaintiff V. CLAYTON DELANEY TAVENNER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : No. 2009 - 3594 CIVIL TERM : DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE I, Tori Lynn Tavenner, the Plaintiff and undersigned, hereby state that the Defendant, Clayton Delaney Tavenner, is not in military service but is currently serving a term of 9 (nine) to 18 (eighteen) years imprisonment in Graterford State Correctional Institute. 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 Ps.C.S. Section 4904, relating to unsworn falsification to authorities. Date: OA60 TORILY TAVENNER Respectfully ABRAffAM PR ,PZESKY, ESQ PA Id # 2097 401 E. Lout h6 St, Suite 103 Carlisle, PA 17013 Tel: (717) 243-9400 TORI LYNN T'AVENNER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiff V. No. 2009 - 3594 CIVIL TERM CLAYTON DELANEY TAVENNER Defendant DIVORCE CERTIFICATE OF SERVICE I, Abraham Prozesky, the undersigned, hereby state that I served a copy of- 1 . A Motion for Appointment of a Master, Verification and Order 2. An Affidavit of Non-Military Service in the above-captioned matter upon Defendant : A. by mailing, U.S. first class mail, postage prepaid to the Defendant at Inmate Clayton D. Tavenner, HX 4567, SCI Graterford, PO Box 244, Graterford, PA 19426, on June 24, 2009. 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 Ps.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 2 4 tJq r ABRA M P ESKY, ESQ PA Id # 209 401 E. Lo ther St, Suite 103 Carlisle, PA 17013 Tel: (717) 243-9400 Oar THE .' Yr Y` T0G9 ,11 "Il 2'14 F I E 2 = v JUN 45 2009 TORI LYNN TAVENNER IN TIME COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiff V. No. 2009 - 3594 CIVIL TERM,, CLAYTON DELANEY TAVENNER Defendant DIVORCE ORDER APPOINTING MASTER AND NOW, , 20 04, a" squire, is appointed master with respect to the following claims: Decree in Divorce pursuant to § 3301(a)(5) of the Divorce Code. MOVING PARTY Name: Tori Lynn Tavener BY THE COURT: NON-MOVING PARTY Name: Clayton Delaney Tavenner Attorney's Name: Abraham Prozesky Attorney's Name: Unknown Attorney's Address: 401 E. Lou er St, Attorney's Address: Unknown Suite 103 Carlisle, PA 17013 Ali^ '?OARY JU)V 26 I4 3 b, VC wy Attorney's Telephone #: (717) 243-9400 Attorney's E-Mail: aprozesky@hotmail.com Party's Address and Telephone # if not Attorney's Telephone #: Unknown Attorney's E-Mail: Unknown Party's Address and Telephone # if not represented by counsel: represented by counsel: Inmate Clayton D. Tavenner FIX 4567 SCI Graterford PO Box 244 Graterford, PA 19426 TC3RI LYRA TAVLl'~lIER Plaintiff V, CLAYTOl~ D~j•~"4' TAB Defendant IN T[rE CoUR'r OF COMMQN PLEAS QF CUMBERLAND CoUNI'Y PEMVSYLVAMA ~Q~ i/W7"~7~17~ Vi`i4 ib1Ci : DNURCE n C` ~,. "'T) •- . 7., -. r , r--- ~, T- r'-` .~ N _~ L 3~ W t_.J .~ ~iIASTER REPORT PRAECIPE It appearing that the Master's report in the above stated case has been filed for ten (1 U) days, that na exc:eptions have been Bled thereto, that the costs have been fully paid and that all the requirements of law and the Rules of Court have been met, you are hereby directed to submit the said case to the Court. of Cc~mman Pleas of Cumberland County, Pennsylvania~at the next sitting thereof. TQ; `~~ AB PRU~ESI~Y, ESQ Attorney for Plaintiff 674 Stover Court Hummelstown, PA 17036 Tel; (717) 982-1532 1-iONOT Y Court of Common Pleas Cumberland County DATED: I, __ ~a~.'al ~ . ~ ~el< ,Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, do hereby certify that the costs in the above stated case, have all been paid, including the Master's fee. "Tl -^-I _r f~, +'} t e-, '~.7 ;=~ 1"1') b .X:7