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Home My WebLink About09-7154rl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES, : CASE NO. 0- 715V ?l ?l l V. L.C. THAMES, : CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO DEFENDANT 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 in 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 Defendant. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 South Bedford Street Carlisle, PA 17A13 Telephone (717) ?41-3166 S eri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 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. BY THE COURT: Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES, CASE NO. v 9 '7 rSy c V. . L.C. THAMES, CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Regina Thames who currently resides at 708 Hanover Manor, Carlisle, Pennsylvania. 2. Defendant is L.C. Thames, who currently resides at 34 Flower Road, Carlisle, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on September 7, 2006. 5. Plaintiff and Defendant separated on October 1, 2009. 6. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that she may have the right to request the Court to require the parties to participate in counseling. 7. Plaintiff avers that no issues regarding the custody of children result from this action. COUNT 1 3301(c 1 IRRETRIEVABLE BREAKDOWN 8. Paragraphs 1 through 7 are incorporated herein by reference. 9. The marriage is irretrievably broken and the parties are estranged due to marital difficulties with no reasonable expectation of reconciliation. 10. Plaintiff requests the Court to enter a decree in divorce. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolving the marriage between the parties. COUNT 2 ALIMONY AND AL,MONY PENDENTE LITE 11. Paragraphs 1 through 10 are incorporated herein by reference. 12. Plaintiff lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living he parties established during the marriage. 13. Defendant enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of the Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order granting her reasonable Alimony and Alimony Pendente Lite. COUNT 3 ATTORNEY FEES 14. Paragraphs 1 through 13 are incorporated herein by reference 15. Plaintiff has insufficient assets and income to pay for her counsel fees and costs regarding litigation in relation to the within matter. 16. Defendant enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of the Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order granting her reasonable Alimony and Alimony Pendente Lite. Respectfully submitted, eri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES, V. L.C. THAMES, Defendant : CASE NO. : CIVIL ACTION -LAW : IN DIVORCE VERIFICATION I, Regina Thames hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. kAv/ Regina es Date: M 41 OF THE 2009 OCT 20 AN B: 4 3 CUI-V3 f-Ca 41NS LVAKA ??r Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff REGINA THAMES, CIVIL ACTION AT LAW Plaintiff Case No. 09-7154 V. IN DIVORCE L.C. THAMES, Defendant AFFIDAVIT OF SERVICE I, Sheri D. Coover, Esquire hereby certify that I did serve a true and correct copy of the Divorce Complaint upon the Defendant L.C. Thames, by depositing or causing to be deposited in the U.S. mail, certified, restricted delivery, postage prepaid on L.C. Thames at Carlisle, Pennsylvania addressed as follows: L.C. Thames 34 Flower Road Carlisle, PA 17013 Return card acknowledging receipt on October 23, 2009 is attached as Exhibit "A". submitted, S eri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff REGINA THAMES, : CIVIL ACTION AT LAW Plaintiff' : Case No. 09-7154 V. : IN DIVORCE L.C. THAMES, Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this le day of November, 2009,1 caused the foregoing AFFIDAVIT OF SERVICE, to be served upon Defendant's counsel, Kara Haggerty, via United States first class mail addressed as follows: Kara Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 submitted, S n D. Coover, Esquire ttorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 v 0 a 0 N_ 0 m C 7 m NI N m Ej(," siT 10 A,. T 0-1 V, 'rH 2009 N ' i G fi'r' s Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) %0-0074 (facsimile) REGINA THAMES, Plaintiff V. L.C. THAMES, Defendant Attorney for Plaintiff CIVIL ACTION AT,,LAW Case No. 09-7154 : IN DIVORCE AMENDED PETITION TO CONSOLIDATE AND NOW, comes Plaintiff Regina Thames, by and through her counsel, Sheri D. Coover, Esquire and files the following PETITION TO CONSOLIDATE and in support thereof avers as follows: 1. On or around October 20, 2009 at 8:43 am., Plaintiff Regina Thames filed a Complaint in Divorce with this Court which included claims for Alimony and Alimony Pendente Lite and Attorney Fees. The Complaint was docketed at 09-7154. 2. On or around October 20, 2009 at 3:00 p.m., Defendant L.C. Thames filed a Complaint in Divorce with this Court, which contained no additional claims for relief against the Plaintiff. This Complaint was docketed as 09-7168. 3. The parties are requesting that this Court consolidate these dockets and allow the parties to proceed with the divorce proceedings under docket number 09-7154. 4. Undersigned counsel has spoken to Attorney Kara Haggerty, counsel for the Defendant, and she concurs with this motion. This motion will not prejudice any of the parties to this action and will clear the dockets for the Court. 6. No judge has previously been assigned to this case. 7. This Amended Petition is filed as the docket number for the case filed by L.C. Thames was incorrectly referenced on the Order in the original petition. WHEREFORE, the parties request that this Court issue an Order consolidating the dockets of 09-7154 and 09-7168 for further proceedings and direct that any further action on these matters be pursued under docket number 09-7154. submitted, S?(eri D. Coover, Esquire ttorneyID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff REGINA THAMES, Plaintiff V. L.C. THAMES, Defendant : CIVIL ACTION AT LAW : Case No. 09-7154 IN DIVORCE CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this i?? Kl'' ? day of November, 2009, I caused the foregoing MOTION TO CONSOLIDATE to be served upon Defendant's counsel via United States First Class Mail addressed as follows: Kara Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 submitted, §Iieri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 FILE?. 'E i T„ 'i. M9 V 12 P to w r„'' `'iY Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) REGINA THAMES, Plaintiff V. L.C. THAMES, Defendant Attorney for Plaintiff : CIVIL ACTION AT LAW : Case No. 09-7154 IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE 1. Petitioner Regina Thames is a competent adult individual who resides at Hanover Manor Apartments, Cumberland County, Pennsylvania. 2. Petitioner's date of birth is October 25, 1957 and her social security number is 172-84-3932. 3. Respondent, L.C. Thames, is a competent adult individual who resides at 34 Flower Road, Carlisle, Pennsylvania. 4. Respondent's date of birth is August 4, 1966 and his social security number is 587-33-7776. 5. A divorce complaint which contains claims for Divorce, Alimony and Alimony Pendente Lite was filed under the above-captioned docket number on October 20, 2009. A true and correct copy of the Divorce Complaint is attached to this petition. WHEREFORE, Petitioner requests that this Court Order Alimony Pendente Lite. submitted, S eri D. Coover, Esquire orney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) REGINA THAMES, Plaintiff V. L.C. THAMES, Defendant Attorney for Plaintiff : CIVIL ACTION AT LAW : Case No. 09-7154 : IN DIVORCE VERIFICATION I, Sheri D. Coover, Esquire state that I am attorney for the Plaintiff Regina Thames in this action and that this affidavit is made as attorney as I have sufficient knowledge or information and belief based upon investigation of the matter averred or denied in the foregoing document and that this statement is made subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsific4lapn to authorities. Date Sheri D. Coover, Esquire Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) REGINA THAMES, Plaintiff/Petitioner V. L.C. THAMES, Defendant/Respondent Attorney for Plaintiff : CIVIL ACTION AT LAW : Case No. 09-7154 : IN DIVORCE CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 17th day of November, 2009, I caused the foregoing PETITION FOR ALIMONY PENDENTE LITE to be served upon Defendant/Respondent's counsel via United States First class mail addressed as follows: Kara Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 submitted, .Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 y i ? A ' ? ? s 4 l• ? 1 w 1. [ .r kT v C t+t rt t }, ? .y v iD _ ,? f k 2 x ? j 6 ?K N a O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES, CASE NO Gv ,13Y V. L.C. THAMES, . Defendant CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFENDANT _ O l0 TI n? Col ._J Z I c.) -ti n 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 in 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 Defendant. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 South Bedford Street Carlisle, PA 17 13 Telephone (717) ??-3166 S eri D. Coover, Esquire ,Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 AMERICANS WIT] • tS 1y,??s?'4?ts??"?'tyy K 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. BY THE COURT: Date: ' J. Y ` L.'? r .G21. ?p ',i ' 7T*u x .J,p Vii; x , r ??X' ~ `LL l? ?5ti 1 ,. r - 41 -v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES, V. L.C. THAMES, Defendant CASE NO. CIVIL ACTION - LAW IN DIVORCE' COMPLAINT IN DIVORCE 1. Plaintiff is Regina Thames who currently resides at 708 Hanover Manor, Carlisle, Pennsylvania. 2. Defendant is L.C. Thames, who currently resides at 34 Flower Road, Carlisle, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on September 7, 2006. 5. Plaintiff and Defendant separated on October 1, 2009. 6. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that she may have the right to request the Court to require the parties to participate in counseling. 7. Plaintiff avers that no issues regarding the custody of children result from this action. l COUNT 1 3301(c) IRRETRIEVABLE BREAKDOWN g• Paragraphs 1 through 7 are incorporated herein by reference. 9. The marriage is irretrievably broken and the parties are estranged due to X marital difficulties with no reasonable expectation of reconciliation. 10. Plaintiff requests the Court to enter a decree in divorce. tiVHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolvinb the marriage between the parties. COUNT 2 ALIMONY AND ALIMONY PENDENT," LITE 1 1. Paragraphs 1 through 10 are incorporated herein by reference. 12. Plaintiff lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living he parties established during the marriage. 13. Defendant enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of the Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order granting her reasonable Alimony and Alimony Pendente Lite. COUNT 3 ATTORNEY FEES 14. Paragraphs 1 through 13 are incorporated herein by reference 15. Plaintiff has insufficient assets and income to pay for her counsel fees and costs regarding litigation in relation to the within matter. 16. Defendant enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of the Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order granting her reasonable Alimony and Alimony Pendente Lite. . Respectfully submitted, Oeri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 " I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES, CASE NO. V. L.C. THAMES, CIVIL ACTION - LAW Defendant :IN DIVORCE VERIFICATION I, Regina Thames hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. 1? C f Regina Names Date: CV I () `( (lop -? bo NOV 16 2009, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) REGINA THAMES, Plaintiff V. L.C. THAMES, Defendant Attorney for Plaintiff CIVIL ACTION AT LAW Case No. 09-7154 J : IN DIVORCE ORDER AND NOW, this Lkday of A) 0Vf1F*'1*L_ , 2009, upon consideration of Plaintiffs Motion to Consolidate, the Motion is hereby GRANTED and it is hereby Ordered that the dockets of 09-7154 and 09-7168 are hereby consolidated for further proceedings in this matter to be docketed under 0 J. Distribution List: ,"<heri D. Coover, Esquire (Attorney for Plaintiff) Law Office of Sheri D. Coover, 44 S. Hanover Street, Carlisle, PA 17013 Kara Haggerty, Esquire (Attorney for Defendant) Abom & Kutulakis, 2 West High Street, Carlisle, PA 17013 VQS /na`' ,t 11T Lj'-- R# OF THE 3"MMURY M NOV 18 PM 1= a5 CUM u } a, k a ;.wou ly PENNSYLVANIA ~,~ F~3 Nom' ~ +„ ~5te IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA20 ~ Q , j ~~;=~ ~ 3 ~ ' ~ Z ~ ~ REGINA THAMES, :CIVIL ACTION AT LAV~~. . - ' ~` +''~~ Plaintiff Case No. 09-7154 ~ ~ + t ~~"''~ v. IN DIVORCE L.C. THAMES, Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on October 20, 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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: ~~ Plai Regina Thames ~_ ~. _.'t' ~,i. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL`~$I~ r~ 2 ~ F'+ 2 ~ ~ REGINA THAMES, Plaintiff v. L.C. THAMES, Defendant CIVIL ACTION A~'~~'~-- ~ - ..J`~~~`~ Case No. 09-7154 t - ~-'~~~ ' ,',^~~~,~;'t IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE 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 aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: d ~+~ ~?~ ~ ~i~ Plai iff Regina Thames IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA THAMES V. L.C. THAMES NO 09-7154 DIVORCE DECREE AND NOW, ~ ? , ~r ~ , it is ordered and decreed that REGINA THAMES plaintiff, and L.C. THAMES ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shah 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. By Court, Attest: .1. ~~ _ /~ - Pr honotary ~ J~ . ~~ ~ . C~. ~~ ~~ Ceti