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Home My WebLink About09-7297Timothy J. Conrad, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Glenda R. Conrad, Defendant : NO. 09- 7x917 CIVIL TERM 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 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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 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 hearing or business before the court. You must attend the scheduled conference or hearing. Timothy J. Conrad, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Glenda R. Conrad, Defendant : NO.09- 7 Z 9 7 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Timothy J. Conrad, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S $§ 3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Timothy J. Conrad , who currently resides at 311 Monroe Street, Mechanicsburg, Cumberland County, PA 17055 since June 2006. 2. Defendant is Glenda R. Conrad, whose current residence is unknown. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 2, 2000 in Altoona, Blair County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since May 25, 2009. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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 counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. er Bire Certified Legal Intern ROBER E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date l? ?? aD0 p Plaintiff Timothy f-feonrad PILE!' 07U1 22 ?t1 2: J'1 7r/ Timothy J. Conrad, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Glenda R. Conrad, Defendant NO. 09- 7-"-SbVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Timothy J. Conrad, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date 10 / 22101 Amber Bireley Certified Legal Intern ".x &44wz - - ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 _ . FILL; r V ; jr s tY -17 :_ THE 2??i9 (`i 22 P11, 'It 2: 5 7 TIMOTHY J. CONRAD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE GLENDA R. CONRAD Defendant : NO. 09 - 7297 CIVIL TERM AFFIDAVIT OF SERVICE I, Laurie L. Wolf, Legal Assistant I, hereby certify that I personally served a true and correct copy of the Divorce Complaint, on Glenda R. Conrad, at: The Family Law Clinic, 45 North Pitt Street, Carlisle, PA 17013, at 2:39 p.m. on Thursday, October 30, 2009. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: 10/30/2009 -- Lurie L. olf RLED- rduE OF THE PRCT rMOTARY 2009NOV -2 AM 10:40 Timothy J. Conrad, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Glenda R. Conrad, Defendant : NO. 09-7297 CIVIL TERM ~ d ~ ~fi ~~ ~ ~ *,, j ~~ ,~. ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ~~ ~ t> c ? A ENTRY OF A DIVORCE DECREE UNDER ~ ~:~ ~ ~ c a . ~ &3301(c) OF THE DIVORCE CODE ~? ca v 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. P ~1 Date ~~ I 1 C/ i ~ nda R. Conrad, De endant Timothy J. Conrad, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW C .~-,^' IN DIVORCE '~ ° r~ ,~ ; Glenda R. Conrad, .-„ ~ Defendant : NO. 09-7297 CIVIL TERN~~~ ~ ~ ~-= r <- ~.~ .~ s AFFIDAVIT OF CONSENT 2 a v 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on October 22, 2009. 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 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. t1 (..~ ~ _ Date ~ ' 1 ~ I v ends R. Conrad, efendant Timothy J. Conrad, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Glenda R. Conrad, Defendant : NO. 09-7297 CIVIL TERM ~~ ~ rT~ ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ~ ~r`"~ ~' ENTRY OF A DIVORCE DECREE UNDER ~C.. ~" &3301(c) OF THE DIVORCE CODE ~_ c~;, a. ~~~ ~ c o 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 Timothy J. onrad, Plaintiff Timothy J. Conrad, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLV ANIA ~ ' v. ~ :CIVIL ACTION -LAW mks; o IN DIVORCE ~ "`" °° Glenda R. Conrad, Defendant ~' e : NO 09-7297 CIVIL TER1 r- . ~3 ~,,. ~-, ~ ` ca ° ~ AFFIDAVIT OF CONSENT cn i .~ 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on October 22, 2009. 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 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 ~ / .- Timothy ;,C ad, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Timothy J. Conrad V. Glenda R. Conrad NO. 09-7297 DIVORCE DECREE ter- ~.'3a~O.,~ . AND NOW, l~G~ a' , ~/~ , it is ordered and decreed that Timothy J. Conrad plaintiff, and Glenda R. Conrad ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall 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 the Court, Attest: J . ~1;-"'~ Prothonotary