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Home My WebLink About09-8537Hope M. Frye, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 09- f,5-37 L'"I v i Tyler B. Frye, Defendant IN DIVORCE NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 17013 Phone: (717) 249-3166 (800) 990-9108 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. Hope M. Frye, Plaintiff vi. Tyler B. Frye, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- ?S3'7 C-Z? IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Hope M. Frye, who currently resides at 110 East Main Street, Cumberland County, Newburg, Pennsylvania, since on or around 2008. 2. Defendant is Tyler B. Frye, who currently resides at 769 Meadowbrook Road, Franklin County, Chambersburg, Pennsylvania since on or around 2008. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 30, 2004, in Chambersburg, PA. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken, and the parties separated in June 2008. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. By. , Hope . Frey, pro se VERIFICATION 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. § 4904, relating to unworn falsification to authorities. Date: Hope M. Frye, Plaintiff Assisted by: Vincent M. Monfredo, Esquire Rominger Law Office 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 FILED-%?' ?i=lam ^F THE IIDR ?:rNQ'tAPY 2009 DEC 10 PM 3: 39 t , Hope M. Frye IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 09- X5 7 CIVIL TERM Tyler B. Frye Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Hope M. Frye Plaintiff, to proceed in forma au eris. I, Vincent M. Monfredo, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. `Vincent M. Monfredo, Esquire Attorney for Plaintiff Rominger Law Office 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 FILED-C)FFICE OF THE pr-Tym,rpTARY 2009 DEC 10 PM 3: 39 "UNTY Hope M. Frye, Plaintiff v. Tyler B. Frye, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 8537 IN DIVORCE °- `- ~ ~ ~~ l E ~ ~ ~ rj:,~ '- -e - '`: ~- N ' i ~~ ~ :~ ~ ~~~ -. 1 Gl ~ j, '~' ~~- .: c. c.~ :~ a AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 10, 2009. 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: Hope M. Frye, Plaint f Hope M. Frye, Plaintiff v. : Tyler B. Frye, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 8537 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301tc) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. ~° ~_: ~~, a C, Cf~ 1~ w ca t -~ s_. -~, ;-a r~L ,' i~ ~ y 'S;r LKyy[ rt". 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: Hope .Frye, Plaintiff Hope M. Frye, Plaintiff v. Tyler B. Frye, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 8537 IN DIVORCE C - ~ ca rr -c3,~. "'~ " - ~ ...~ ' : c.-. ve,. .~ ;. ~7 f 3~ cry ~ ; sv "~ -"' th t..t ,c. 'rx ~. t.~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tiled on December 10, 2009. 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: ~~ 17 ~` I ~ d Tyler .Frye, Defendant Hope M. Frye, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v• No. 09- 8537 Tyler B. Frye, Defendant IN DIVORCE ~ `= ~ d z~~ f'1"f ri-4 ~ ~' ~_ WAIVER OF NOTICE OF INTENTION %`?~y~ ~"`~ -~~ TO REQUEST ENTRY OF A DIVORCE DECREE ~ ~-` UNDER § 3301(c) OF THE DIVORCE CODE ~L ~ ~ ..~, ~ ~ 1. I consent to the entry of a final decree of divorce without notice ~ ~- . c1 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 wil l 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:~~ ~~~- ~~ yler B. rye, Defendant ,-.,~- ~i~f ~ ' t.1't` i'iv~ ~~~ T~~ ~ j~}~~~~~ 2010 MAR 25 P1~ 3~ 2Z ,~ CiU~~~;y;~; v~% 1 r.; ~~~i~~V,~~I.r~ Hope M. Frye, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ~• No. 09- 8537 Tyler B. Frye, Defendant IN DIVORCE PROOF OF SERVICE OF DIVORCE COMPLAINT ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed t ;y~~,~ 8, ~y~ y/9 ~adGwl~~o,C ~~~ ~'fi~maf,~jQ~,~c, O~ i7~aa A. sin n3 ^ Agent X 7 ^ Addressee B. Recei by nnted Name) C. Date of Delive ~Y ~i~' ~ ~~ 7f~ l ~[, ~~ D. Is belivery addre~s different from item 1? ^ Yes If YES, enter delivery address below: ~No 3. rvlce Type Certified Mail ^ Express Mail ^ Registered ~Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Transferfmmservk 7009 0~8~ 0~~1 844 5246 PS Form 3811,. February 2004 Domestic Retum Receipt 102595-02-M-1540 Hope M. Frye, Plaintiff v. Tyler B. Frye, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 8537 IN DIVORCE PRAECIPE TO TRANSMIT RECORD N ~_ C7 '~ cr ~ ('S'{ r~ ~ ~'c '~~_ rn c:; ,;. ~~-yy~ f~ `..f ri TO THE PROTHONOTARY: ~ ~- w N sv Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail/Return Receipt/Restricted Delivery. December 19, 2009. `~, ~,.~ ~ _,.. ~; ti~ ~:`..; ~r~~ 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff March 20, 2010; by the Defendant March 17, 2010. 4. Related claims pending: None 5. Date Plaintiffls Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 25, 2010. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 25, 2010. Date: ~ ~ ~ , 2010 Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 For Plaintiff/Hope M. Frye/pro se