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HomeMy WebLinkAbout01-0041IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, : Plaintiff : :No. V. THURREL L. TAYLOR, : IN DIVORCE Defendant : Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE BEENSUED 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 Prothonntary, Cumber/and County Courthouse, I 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Le han demandado a usted a la cone. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO O PROP1ENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OF1CINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 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 heating or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, : Plaintiff : :No. ~/' ~/! v. : THURREL L. TAYLOR, : IN DIVORCE Defendant : Civil Term COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW comes ROXANN L. TAYLOR, by and through her attorney, Maryann Murphy, Esquire of MidPenn Legal Services, who respectfully avers as follows: 1. Plaintiff is ROXANN L. TAYLOR whose current P.O. Box 1039, Carlisle, Cumberland County, 2. Defendant is TNURREL L. TAYLOR incarcerated at the Cumberland County Prison, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 30, 1989 in Suffolk County, Virginia. 5. Plaintiff believes that a Complaint in Divorce was filed address is Pennsylvania. who is currently 1101 Claremont Road, by Defendant through the mail, however, Plaintiff does not know in which Court this was filed. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. ~R~FOR~, Plaintiff requests this Honorable Court to enter a Decree dissolving the marriage between the Plaintiff and the Defendant. Respectfully submitted, Maryann Murphy, Esquire MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff AFFIDAVIT I, ROXANN L. TAYLOR, verify that the statements made in the foregoing Complaint in Divorce 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant No. IN DIVORCE Civil Term CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Divorce Complaint was served upon the Defendant, THURREL L. TAYLOR, by Sheriff at the following address: Thurrel L. Taylor Cumberland County Prison 1101 Claremont Road, Carlisle, PA 17013 Respectfully submitted, MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Haintiff V. THURREL L. TAYLOR, Defendant NO. IN DIVORCE Civil Term PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, ROXANN L. TAYLOR, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant :NO. Ot- q-t : : IN DIVORCE : Civil Term AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am ROXANN L. TAYLOR, the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, 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: Address: (b) Social Security Number: If you are presently employed, state Employer: N/A Address: N/A Salary or wages per month: Type of work: N/A ROXANN L. TAYLOR P.O. Box 1039, Carlisle. PA 17013 202-46-6790 N/A N/A If you are presently unemployed, state Date of last employment: 11/11/2000 Salary or wages per month: $1.220.00 Type of work: Sealer (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: -0- Disability payments: -O- Unemployment compensation and supplemental benefits: -0~ Workman' s compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: N/A Salary or wages per month: N/A Type of work: N/A Contributions from children: ~0- (e) Property owned Cash: -O- Checking Account: -0- Savings Account: -0- Certificates of Deposit: -0- Real Estate (including home): N/A Motor vehicle: Make N/A Year N/A Cost N/A Amount owed N/A Stocks; bonds: -0- Other: -0- (f) Debts and obligations Mortgage: -O- Rent: -0~ Loans: -0- Monthly Expenses: -0- (currently at Shelter) (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A Children, if any: N/A 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. 4904, relating to unsworn falsification to authorities. Date:/c~ ~ ~.- r~ c) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, : Plaintiff : : No. 2001-41 V. ., THURREL L. TAYLOR, : IN DIVORCE Defendant : Civil Term AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 3, 2001. 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 ora final decree of divorce after service of notice of intention to request entry of the decree. 1 verify that the statements made in this affidavit are true and correct. I understand that fa/se statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date Witness IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant No. 2001-41 IN DIVORCE Civil Term 3,2001. 2. AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January The marriage of Plaintiffand 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 ora 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. Section 4904 relating to unswom falsification to authorities. Date Witness IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant No. 2001-41 IN DIVORCE Civil Term WAIVER OF NOTICE OF INTENTION TO RI~QUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I tmderstand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Witness IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant : No. 2001-41 .. .. : IN DIVORCE ._ Civil Term WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree ofdivome without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI 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. 1 verify that the statements made in this Affidavit are tree 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. Witness Date ROXANN L. TAYLOR/'/ (./. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, : Plaintiff : No. 01-41 Civil Term V. : : THURREL L TAYLOR, : IN DIVORCE Defendant : DOck Sez,-v: A f fi c AFFIDAVIT OF SERVICE I, Marymm Murphy, Esquire, depose and say: l. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on January 3, 2001, the Defendant was served with a 3301(c) Complaim in Divorce by Sheriff at the Cumberland County Prison. A copy of the Sheriff s return, attesting to the Defendant's receipt of the Complaint, is attached hereto. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 P~ SHERIFF'S RETURN CASE NO: 2001-00041 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TAYLOR ROXAL~ L VS TAYLOR THURREL L REGULAR DAWN KELL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according says, the within COMPLAINT ~ DIVORCE TAYLOR THURELL L DEFENDANT , at 0019:58 HOURS, at CUMBERLAND COUNTY PRISON CARLISLE, PA 17013 THURELL L. TAYLOR a true and attested copy of COMPLAINT - NOTICE to law, was served upon the on the 3rd day of January 1101 CLAREMONT RD by handing to DIVORCE 2001 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 .00 31.10 Sworn and Subscribed to before me this . /~ day of ~i~ ~ / A.D. ~Prothonotary R. T~gmas Kline ol/o /2OOl By: Deputy Sheriff ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : No. 01-41 Civil term IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the Family Law Clinic on behalf of the Defendant, Thurrel L. Taylor, in the above captioned matter. May 18, 2001 Respectfully Submitted, ~rek Clepper Certified Legal Intern Robert E Rains Ted L. Henning Supervising Attomeys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717)-243-2968 ROXANN L. TAYLOR, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THURREL L. TAYLOR, Defendant : CIVIL ACTION -LAW : No. 01-41 Civil term : IN DIVORCE CERTIFICATE OF SERVICE I, Derek R. Clepper, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of Pmecipe to Enter Appearance on Pla/ntiff's attorney, Maryann Murphy, at 8 Irvine Row, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the Un/ted States ma/l, First Class, postage prepaid, this 18t~ day of May, 2001. May l8,2001 Certified Legal Intern THE FAMILY LAW CLINIC 45 Noah Pitt Street Carlisle, PA 17013 (717)-243-2968 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROXANN L. TAYLOR, Plaintiff THURREL L. TAYLOR, Defendant To The Prothonotary: : No. 2001-41 .- .. : IN DIVORCE : Civil Term 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(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant was served on January 3. 2001. bv the Cumberland County Sheriff at the Cumberland County Prison located at 1101 Claremont Road. Carlisle, Pennsylvania. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaimiff, June 28, 2001; by Defendant, June 21. 2001. (b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of filing and service of the Plaintiff's Affidavit upon Defendant: N/A. 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date Plaimiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 3, 2001. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 29. 2001. Plaintiffs Social Security Number: 202-46-6790 Defendant's Social Security Number: 228-90-9286 MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of .~ PENNA. Roxann L. Taylor, Plaintiff NO. 2001-41 civil Term VERSUS Thurrel L. Taylor, Defendant DECree IN DIVORCE AND NOW, ~%ll DECREED that Roxann L. Taylor Thurrel L. Taylor AND 2001 IT iS ORDEred AND ,PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECOR~ IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ~ '~ There are no outstandinq claims. PROTHONOTARY