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HomeMy WebLinkAbout10-2301c Jack D. Lasure, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- )-3 Of CIVIL TERM Sandra M. Lasure Defendant IN DIVORCE n N rn ' `t3 -- _ _ m C? i 7 - NOTICE TO DEFEND AND CLAIM RIGHTS -t; YOU HAVE BEEN SUED IN COURT. If you wish to defend against the class set'fortb-'- 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, 1 Courthouse Square, 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 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Jack D. Lasure, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- ?3D CIVIL TERM Sandra M. Lasure Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is J k --\) ",,rr_ 2Z: , who currently resides at /.?'/U Grk?d?;cw C?..f C?arlWe Py , Cumberland County, Pennsylvania. 2. Defendant is lr?lc,nd r a- fn La j u « , who currently resides at I??Io Gran?u;?w Gryr? CkPli?k 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on Mk y, y- ;2GID / at 5. The marriage is irretrievably broken, and the parties separated on 5 rro???K a? Nov IS 260f 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. M 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plk ntiff, Pro Se I, Uac.k -1xsurc I?T , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. y_L --20iu Date: Pl ntiff, Pro Se Assisted by: Abraham Prozesky, Esq. 674 Stover Ct. Hummelstown, PA 17036 (717) 982-1532 Jack D. Lasure, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-p CIVIL TERM Sandra M. Lasure Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Jack D. Lasure, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- ?,,3 0 I CIVIL TERM Sandra M. Lasure Defendant IN DIVORCE n N a -n' PRAECIPE TO PROCEED IN FORMA PAUPERIS _ c, To the Prothonotary: Kindly allow, Jack D. Lasure, III Plaintiff, to proceed in forma au ens. I, Abraham Prozesky, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attr Plaintiff AbPelstown, o , Esquire 67Ct. Hu PA 17036 (717) 982-1532 Jack D. Lasure, III Plaintiff V. Sandra M. Lasure IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10-J-301 CIVIL TERM Defendant IN DIVORCE 0 c ° 1 r-- 'jj ,'__ C71 ? C7 ACCEPTANCE OF SERVICE ,_n r SZ5 1, Sandra M. Lasure (Defendant), accepted service of a true and correct copy of?ne Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dat Sandra M. Lasure, Defendant Jack D. Lasure, III Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10-2301 Sandra M. Lasure Defendant IN DIVORCE AFFIDAVIT OF CONSENT CIVIL TERM e--) N m rn -a m ?- 9 L A complaint in divorce under §3301(c) of the Divorce Code was filed on April 6, 2010. 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: Signature: -'Jack D. Lasure, III, Plaintiff Jack D. Lasure, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-2301 CIVIL TERM r--- C= -,r Sandra M. Lasure - r --= -i rn CO Defendant IN DIVORCE -n -*? r= ? rn < C' WAIVER OF NOTICE OF INTENTION TO Rl3QUEST ENTRY OF R) ?-a DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE <<-i I< 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 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: --a20JO Signature: Jack D. Lasure, II , Plaintiff Jack D. Lasure, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-2301 CIVIL TERM c ? Sandra M. Lasure : rr' M Defendant IN DIVORCE W1 i ,,rn r--- :z ?- , c < x CD ?- C7 rv i , AFFIDAVIT OF CONSENT 1. A complaint in d ivorce under §3301(c) of the Divorce Code was filed on April 6, 2010. 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: z Z? to Signature: Sandra M. Lasure, Defendant Jack D. Lasure, III Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-2301 CIVIL TERM (7) Sandra M. Lasure M- Defendant IN DIVORCE x` r ' + ?, - v C) c? - --tc:) : "-F3 „c rv M WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE' 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 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: 1 Z Z Signature: s?L' Sandra M. Lasure, Defendant Jack D. Lasure, III Plaintiff V. Sandra M. Lasure Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10 - 2301 IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: {:) r-.3 a n rT1 a) rn -n rn - r "D n r- rn a -? o -_ ru r•, 1. Ground for divorce: Irretrievable breakdown under Section 3301(c of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on April 6 2010 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, December 25, 2010; by Defendart, December 28, 2010. 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 4, 2011. 6. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 4, 2011. Abralfam &ro7 y Plaintiff AttornK209787 PA ID 674 Stover Court Hummelstown, PA 17036 JACK D. LASURE, III V. SANDRA M. LASURE DIVORCE DECREE AND NOW, it is ordered and decreed that JACK D. LASURE, III plaintiff, and SANDRA M. LASURE 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, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2010 - 2301 Attest: J. ,?2? - Prothonotary 69r+. ecpY mw led -b M+d Am No4tw f e*y r?aa.iW -Eo cWt-