The URL can be used to link to this page

Home My WebLink About09-7168L.C. THAMES, Plaintiff V. REGINA W. THAMES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09 - 71(08 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 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 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, One Courthouse Square, Carlisle, Pennsylvania. 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 COUNTYBARASSOCL47YON 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 L.C. THAMES, Plaintiff V. REGINA W. THAMES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09- 7/ L 8f CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is L.C. THAMES, who currently resides at 34 Flower Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is REGINA W. THAMES, who currently resides at Hanover Manor Apartments, Building D, Apartment 206, Carlisle, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents 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 September 7, 2006 at Birkenfeld, Germany. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since May 2009, and continue to do so. 8. 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 such counseling. 9. The Plaintiff in this action is a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, DATE I Z0 0 1 ABOM&KUTULAKIS, L.L.P. Kara W. Haggerty 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 . • VERIFICATION I, L.C. THAMES, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. 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.C. THAMES RLF r?a?p ? ?H c t? : CRY 0 2009 W 20 P ? 3? 00 ,? GL'N v jN a ,N 33S.5o PAD ATN co t48a P74" a3aa71 Y P OM CSC" &U ULAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 L.C. THAMES, Plaintiff V. REGINA W. THAMES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09-7168 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the Complaint under Sections 3301 (a), (c) and (d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on Regina W. Thames, at Carlisle, Pennsylvania, addressed as follows: Regina W. Thames Hanover Manor Apartments Bldg. D- Apt. 206 Carlisle, PA 17013 Return card acknowledging receipt on October 21,2009 is attached as Exhibit "A". ABOM & KUTULAKnS LLP Date: 10129 Kara W. Haggerty, Es Attorney I.D. No: 869 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this 29TH day of October, 2009, I, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, LLP, hereby certify that I did serve a true and correct copy of the foregoing Affidavit of Service by depositing, or causing to be deposited, same in the United States Mail, First- class mail, postage prepaid addressed to the following: Sheri D. Coover, Esquire 44 S. Hanover Street Carlisle, PA 17013 Respectfully submitted, ABom e'9' Kunu AKIS, LL P Kara W. Haggerty, 36 S. Hanover Str t Carlisle, PA 17013 (717) 249-0900 ID No. 86914 Attorney for Plaintiff 1 ,1 ¦ Complete Items 1, 2, and 3. Also complete A. n tore item 4 if ReaftW Delivery Is desired. X Qq,? Agent ¦ Print erne and address on the reverse Afire so that can return the card to you. ) 0. ¦ AttachAlls card to the back of the maiipiece, lI or on -front if space permits. Is address difterent from Item 1 ? 1. Article +rJressed to: If YES, enter delivery address below: No 3. _Jyvice Type Mall ? Express Mail Registered ? Return Receipt for Merchandise / 13 Insured Mail ? C.O.D. /7 4. Restricted Delivery? (Extra Fee) E3 Yes z Article Number 7008 1830 0003 5942 5838 tllsrrMl?r A?w rrrrrlnwM ? . , P6 Fpm 3811, Fsbrw y 2004 Domeaft Raum Receipt ,o2als et.M fsN EXHIBIT `A" fit. D-Offl , OF THE PPOTHOINOW 2009 OCT 29 PM 4: 03 GUMtzr.` ILZ, D COQ PENNKWA 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. 09-715j- v. IN DIVORCE L.C. THAMES, Defendant 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 a.m., 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. 5. 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. 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 b!Coover, Esquire 'Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 10-h day of November, 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 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, Aeri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 F 1-11 PY 2009 NOV 13 PM 12* .1-6 L? INN 2009 NOV v y { 4 Cur FL, T'll t NOV 7 6 2p0%, 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 fA O'RfDER AND NOW, this It day of d , 2009, upon consideration of Plaintiff's 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 finther proceedings in this matter to be docketed under 09 J. Distribution List: ./ Sheri 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) Aborn & Kutulakis, 2 West High Street, Carlisle, PA 17013 e?? OF nK%?%Aav 2009 NOV 18 FM 1: 0 4 CUMB?KLqLj' i-,"f?UNiY PENNSYLVANIA