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HomeMy WebLinkAbout10-1811 TAWNYA L. POOLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DAVID L. POOLE, NO. (q - /13 1 ( CIVIL TERM Defendant IN DIVORCE C ri NOTICE TO DEFEND AND CLAIM RIGHTS I J1 4 1 You have been sued in Court. If you wish to defend against the claims se€=f6 th in-.the ? following pages, you must take prompt action. You are warned that if you fail to do so, the`Case will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 -twa.oo Pa AT'T'l Carlisle, Pennsylvania 17013 c0 3 C 2 6 Phone: (717) 249-3166 or (800) 990-9108 kr* 23?gSz TAWNYA L. POOLE, Plaintiff V. DAVID L. POOLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Tawnya L. Poole, an adult individual currently residing at 52 F Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is David L. Poole, an adult individual currently residing at 1513 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 13, 2003, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. submitted, B}dle L. Griffie, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE:?? "3 S? ?' a- TAWNYA . POOLE, Plaintiff FILED-i`~~=; SCE ~_ ; ~: 20l~ ~~~~~ ~~ ~E~ 2~ ~ 7 TAWNYA L. POOLE, Plaintiff v. DAVID L. POOLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~~'"~~~~ CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Bradley L. Griffie, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, David L. Poole, at his address of 1513 Terrace Avenue, Carlisle, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on March 16, 2010. Sworn and subscribed to before me this ~ day of ~ ~~~~~ , 2010 ~~ ~ ' ~ _ NOTARY P LIC RO~Mi J: 'f11iSETT Notary -ublic CARLNLE fOROllriH, CtJIMIlERUWD COUNIY iwifl- Commission Expina Apr t7, ZO11 GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ...r~......i fA~1 !M'RAtON r";38tAi .~. i4~#6+A :,s1t~L4 yrs'~~oi~! "''tt,E}!.~"?rZV3R.eS3##~,~~i J .t:r?rC:+51t~l:3.ld41lil-J U.S . Post al`Ser viceT n~ CE RTIF IED MAIL r RE CE IPT (Do mestic M aif Only ; No Ins r,~ urance Cove rage Provided) ' For d elivery in formatio n vi it b i s ou r we s t e at w ww.usps.com~; ru ~ Pc~-tage $ ~~ f'U Certi~ed Fee M r1.I G `9. Q fleturn Receipt Fee tma ~p (Endorsement Required) ~tHere ~ Restricted Delivery Fee Q Y~~ ~\ ~ (Endorsement Required) Yv G> rLl Total Postage & Fees ~ ~ `` v O ~ Sent To ! , 0 Street. Apt. No., °-~~ _-__-° - - ------------- ~~ ~ ~y ---_-_--- ~ or PO Sox No. f~ / •J~j --- j~%~~ //J GL ~i --------------------° ~.t- 1- ------- C.Ci City, State, ZIP+4 (~"°-"" --°--- --------------- Y :r~ ~~. ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name d address on the reverse so that we can re urn the card to you. ^ Attach this card o the back of the mailpiece, or on the front i' space permits. 1. Article Addressed to: L.. ~~ I>/ ~~.sl,°~ P~ ~7ur3 X si~,~~ tre /w( ^ Agent ~ p,,~ ^ Addressee 1,i a.l / Cbyt-ten \ ~ ~r~ C ~t~ ~,GA Livery D. Is delivery address different ffom item 1? ^ Yes If YES, enter delivery address below: ^ No 3. S ice Type Certified Mail ^ Express Mail D Registered ~ Retum Receipt for M ^ Insured Maii D C.O.D. ,, 4. Restricted Delivery? (Extra Fee) Y~ 2. ArticteNumber 70177 ~22Q 0002 2525 2974 (Transfer from sen~lce label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Flory ::.~. ~,M Tt ,, ^~ , , t.;... t ~ K. ?Q{0 ~~~~ ~~ ~~ ~~ ~~ CUh~_f- ~~ ~~~~UN~Y TAWNYA L. POOLE, Plaintiff v. DAVID L. POOLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~G" ~~'~l CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 12, 2010, and served on March 16, 2010, by certified mail, restricted delivery. 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 THE FOREGOING 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: /~ _ ~ ..,G,• ~ / G~~L~~ _~~~ TAWN A L. POOLE, Plaintiff t ~~[_~A~l f ~i~~ ~~~ Y~C ~' `+~ t,°~a~~~~ ~st 2010 ,1t1~ 25 ~' 3~ ~+~ i1tsS`~1.VrS~3~+ TAWNYA L. POOLE, Plaintiff v. DAVID L. POOLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. Cp. ~~~/ CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. 1 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUB3ECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: TAW A L. DOLE, Plaintiff ~~ryryf e1 J ~ J~~lT'~ 20~~ s~t~ 25 ~~, ~~ ~3 '(,fir:,.: , =, Ott i~~4V. PE~f +'~51~`i. 4~~a'` TAWNYA L. POOLE, Plaintiff v. DAVID L. POOLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~G~,~l' CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 4. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 12, 2010, and served on March 16, 2010, by certified mail, restricted delivery. 5. 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. 6. 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 THE FOREGOING 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: DAVID L. POOLE, Defendant to r C -~o~,.-y t^.:, i'Y~''~~1 1Qla,~?! 25 ~'~ 3~ 43 0,~~'i.~~~`~ ~J ~wJ~ ~{<N~vSYI.V~~4ii~ TAWNYA L. POOLE, P1_ai:rtiff v. DAVID L. POOLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. ~~~~~~/ CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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 THE FOREGOING 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: p~~ DAVID L. POOLE, Defendant FiLF;:1..;:t ~i~.: 20fQ Ji1~ 30 ~~~~ !G~ ~~ TAWNYA L. POOLE, Plaintiff v. DAVID L. POOLE, Defendant CUM ~:~ ~~ ~1~~~NTY Ih i(l~ ~r ~ i IN THE COURT OF COMM~~$~~' CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 10-1811 CIVIL TERM 1N DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: March 16, 2010 via certified mail, restricted delivery. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: June 22, 2010 by Defendant: June 21, 2010 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 25, 2010 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 25, 2010 Bra ie, quire AS CIATES Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TAWNYA L. POOLE V. DAVID L. POOLE NO. 10-1811 DIVORCE DECREE AND NOW, q~ 8 ~ ~o ~ ° , it is ordered and decreed that TAWNYA L. POOLE plaintiff, and DAVID L. POOLE , 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. By the Court, ~~ J. onotary ~• `~ • 1O ee-c'~. cap C~ 7. ~1. 1 U ~ cC~ice. '~loa 1~c~ ~p ~sri.~.~.; ~ d ~~5oc . c~n.o~-~ t ~zc~ --~ ~s.. e-f--~-.