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HomeMy WebLinkAbout09-4382IN THE COURT OF COMMON PLEAS FOR THE COUNTY OF , PENNSYLVANIA ?enn C' I I ' Q_ '? j 4 c `1 3 ('??-t t I xx4 , (Petitioner) : VS. CIVIL ACTION (Defendant) APPLICATION TO PROCEED IN FORMA PAUPERIS I, k n n A In E C 1 l ? , declare that I am the petitioner in the above entitled proceeding; that, in support of my request to proceed without being required to pre- pay fees, costs or give security therefore, I state because of my poverty, I am unable to pay the costs of said proceeding or give security therefore, and that I believe that I am entitled to relief. The nature of my action, defense or other proceeding or the issues I tend to present on appeal are briefly stated as follows: IN FURTHER SUPPORT OF THIS APPLICATION, I FURTHER AVER AS FOLLOWS: 1. I am incarcerated in the State Correctional Institution at Coal Township, 1 Kelley Drive, Coal Township, Pa. 17866-1021. 2. 1 do not have any income, of any type, other than prison wages. Other: / (f) Debts and obligations Mortgage: Rent: Loans: Other: (g) Persons dependent upon you for support Wife Name: Children, if any: J (-Q!-? Name: c, A t C- " e. Age: C/ a im c ono (A C-? - Age: J C01,411 d I Cie C, l ? : ? Age: (91 Other perso'ifs? G<-"d Name: Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances, which would permit me to pay the costs incurred herein. 5. 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.A. §4904, relating to unsworn falsification to authorities. Date: t;,V VL. OF 12: ?i Workman's Compensation: Public assistance: Other: j0'? ? (A n ( Q r psi d S 0-111?- (d) Other contributions to household support (Wife) Name: If your wife is employed, state I Employer: i Salary or wages per month: \\Jl Type of work: Contributions from children: Contributions from parents: Other contributions: (e) Property owned Cash: Checking account: Saving account: Certificates of deposit: Real estate (including home): Motor vehicle: Make , Year Cost , Amount Owed $ Stock; Bonds: Form DC-135A INMATE'S REQUEST TO STAFF MEMBER Commonwealth of Pennsylvania Department of Corrections INSTRUCTIONS Complete items number 1-8. If you follow instructions in preparing your request, it can be responded to more promptly and intelligently. 1. To: (Name and Title of Officer) .. 2. Date: l } ?? 3. By: (Print Inmate Na a and _Number) 4. Counselor's Name \ r ?4ate Signature 5. Unit Manager's Name q 'f /-I 6. Work Assignment 7. Housing Assignment _ 8. Subject: State your request completely but briefly. Give details. , ' C, Y1 t _ i , 9. Response: (This Section for Staff Response Only) To DC-14 CAR only ? To DC-14 CAR and DC-15 IRS ? r Staff Member Name C U/y1 / Date Print Sign Revised July 2000 i? ell 'N4 (J. ?` '' m IN THE COURT OF COMMON PLEAS FOR THE COUNTY OF C,ur,,17j?- f 1L,nd , PENNSYLVANIA (Petitioner) VS. CIVIL ACTION (Defendant) AFFIDAVIT IN SUPPORT OF PETITIONER'S APPLICATION TO PROCEED IN FORMA PAUPERIS 1. I am the petitioner in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associate, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Yt Q. Y® r) - C t-?y ?f Address: -row oc IS- C Social Security Number:/ -7 - (,, % -_ j 3. I do not own any stocks or bonds, nor do I receive any payments for any interests, annuities rental properties or other sources. 4. I do not have any checking or saving accounts. 5. I have approximately $ , _ V in my prison account. Nei V-L-? ?? 7 My m'Ah?-' ,? ?s-t- 3',' ti A- nLS?- #9 ?= pG A I declare, under the penalties provided for perjury, that the facts contained herein are true and correct to the best of my knowledge, information and beliefs. Respectfully Submitted, Executed on (Date) SCI-Coal Township 1 Kelley Drive Coal Township, PA 17866-1021 OF ?'t'om ?;??,+Y IN THE COURT OF COMMON PLEAS FOR COUNTY, PENNSYLVANIA PLAINTIFF ACTION IN DIVORCE VS. NO. (-;,i. 9 3 s' Ct?tit 1 z?- er"?y 1"l fait 1 DEFENDANT 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 you 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 at: (ROOM NUMBER - ADDRESS) 0a IOUT G,,4Q-s f- P IN THE COURT OF COMMON PLEAS FOR -C U (V1 Be-- C I G-n U COUNTY, PENNSYLVANIA PLAINTIFF ACTION IN DIVORCE VS. NO. 0 ?t 3 (, DEFENDANT COMPLAINT UNDER SECTION § 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is h ?2 n ru2?? ` ,nom who currently resides at and has since- f - C) S.S 2. Defendant is who currently resides at and has since j 3. Ksl' n has/have. been a bona fide resident(s) in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and defendant were married on -03 (a, _ i ?, t at 5. There'has been no prior actions of divorce or for annulment between the parties except 0 6. The marriage is irretrievably broken. y L -SIN 7. 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. 8. Plaintiff requests the court to enter a Decree of Divorce. 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 the Unsworn Falsification to Authorities. Respectfully Submitted, Date: G-0)1- o q IN THE COURT COMMON PLEAS FOR kA 01 ec l Gkn rl COUNTY, PENNSYLVANIA PLAINTIFF ACTION IN DIVORCE vs. NO. fj. cl '.., DEFENDANT NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: f3 ezkLti [A , It nj?- L. rtj n/C=`l H ?. , C;:. l r nl?: Intends to file with the Court the attached Praecipe to Transmit Record on or after G - j S 20 p 9 requesting that a Final Decree in Divorce be Entered. /s/ me aPP , C U y'?,7%J" 1Ne ¢4i_ t rF PF NNISYLVANIA Date: ? ?. y I L„r i `zeal Nathan I. Poler, : rotary Public Faiiview'+Wei.,Yort County My Commission Expires Nov, 21, 2011 Member, Penr, v!. ari;3 ssnciadion of Notari-- L??? I Mfr P C iL ?C? S 1 C?t? c -r G Yt,jj T Y 2. ,> ?l Y? I t C , FLED-—: Tpr- OF C: 2009 JZ' q' 30 PE`12: r r? r' JUL O 1 4009 G, IN THE COURT OF COMMON PLEAS FOR THE COUNTY OF , PENNSYLVANIA A eNNG?A F-, e//?je-- (Petitioner) VS. &jverly 1q, (Defendant) ORDER AND NOW, this /V0. )I,e . (),7 . Lt 3 9 aL C-?u 7z- CIVIL ACTION day of 206?, Upon consideration of the Petitioner's Motion captioned; PETITION TO PROCEED IN FORMA PAUPERIS; It is Hereby Ordered and Decreed that Petitioner shall be granted Leave to Proceed as a Poor Person. IT IS SO ORDERED By The Court, ,?,44L JUDGE CF YFI" , 10TARY 2 J!++ 14 91,111: 23 Lc- ?7 KENNETH CLINE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. BEVERLY CLINE Defendant CIVIL ACTION - LAW NO. 09-4382 IN DIVORCE ACCEPTANCE OF SERVICE CIVIL TERM ? rrl= 3rrn n• rn 2M -om ?G O =c = F5 c- , CA) - ..tM I, Beverly Cline, the Defendant, in the above captioned divorce action acknowledge receipt of a true copy of the Complaint in Divorce on July 7, 2009 and accept service thereof. DATE: "'fiPLY-L t4 [( By: Cj?, Beverly line COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ON THIS, the. day of 2011, before me. the undersigned officer, personally appeared Beverly Cline, 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. IN WITNESS WHEREOF, I have set my hand and official seal. _SEAL Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal LMy nelle M. Gaines, Notary Public r Alien Twp., Cumberland County ommiss ion Exores Jan. 18, 2012 Member, Pennsylvania Assodatlon of Notaries KENNETH CLINE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVaN l? V. : CIVIL ACTION - LAW ..I'M ~- 3W --i rnF A m ?© BEVERLY CLINE :NO. 09-4382 CIVIL TER1VOx co 4 Defendant : IN DIVORCE y° ?p c w °rn AFFIDAVIT OF CONSENT - < < 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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" G?O Oeu Beverly Cline, aintiff COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jynefle M. Gaines, Notary Public Lower Allen Twp., Cumberland County M Commission Expires Jan. 18, 2012 Member, Pennsylvania Association of Notaries C_% ° - KENNETH CLINE : IN THE COURT OF COMMON VF rnF:-,. Plaintiff : CUMBERLAND COUNTY, PE L*N CID c V. :CIVIL ACTION-LAW n-n 2c) w BEVERLY CLINE :'NO. 09-4382 CIVIL' ffM 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 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: A0©f/ _Lz.e_jl? Beverly Cline, D endant COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jynelle M. Gaines, Notary Public Lower Ailen Twp., Cumberland County My Commission Expires Jan. 18, 2012 Member, Pennsylvan`i'a' Association of Notaries KENNETH CLINE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BEVERLY CLINE : NO. 09-4382 CIVIL TE$9 o Defendant : IN DIVORCE = <r CD CD AFFIDAVIT OF CONSENT 5:c: w CD -! L A Complaint in Divorce under Section 3301(c) of the Divorce Code 'Was N filed > -?qn 3C) 0c) 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: '? " Z k' l L. KENNETH CLINE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA c'S c V. : CIVIL ACTION - LAW r., o C? rqCD zm x=• ' - BEVERLY CLINE :NO. 09-4382 CIVIL TE!R Orn- Defendant : IN DIVORCE ?A Ica < .? S Q x' c:: C4 WAIVER OF NOTICE OF INTENTION n TO REQUEST ENTRY OF A DIVORCE DECREE -= UNDER § 3301(c) OF THE DIVORCE CODE I . 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: -3- 2S -1? KENNETH CLINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION zM x" M rni= - BEVERLY CLINE M UM Defendant NO. 09-4382 CIVIL TERMS co o? PRAECIPE TO TRANSNUT RECORD 3>C-) z-n w Cm TO THE PROTHONOTARY: N) 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(c) of the Divorce Code. 2. Date and manner of service of the complaint: July 7, 2009 by personal service (see acceptance of service attached. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff March 28, 2011; by Defendant March 16, 2011. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 3/fir Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ANDREWS & JOHNSON I I' Date: Marchg011 By 41?10 A j&;0J76 r Ronald E. J son, sq. 78 West P et Street Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 16453 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kenneth Cline V. Beverly Cline NO. 09-4382 DIVORCE DECREE AND NOW, 04 Z c> I I , it is ordered and decreed that Kenneth Cline , plaintiff, and Beverly Cline , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for .alimony pendente.lite if.an.y 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 areas follows: (If no claims remain indicate "None.") None By the Court, ,4/0 No y nA4d rb f f No4t * 4 dwsR