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HomeMy WebLinkAbout04-2987 Patricia Ann Lingle, Plaintiff : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 04- J. 'In -CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. 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 ol"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, first floor, Cumberlanq County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR :I;XPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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. Pennsylvania Bar Association - Lawyer Referral Service Telephone 1-800-692-7375 (PA ONLY) or 717-238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin 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. Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04- ~1'7 -CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is Patricia A. Lingle, who currently resides at 108 Valley Road, Summerdale, Cumberland County, Pennsylvania, since on or about November 20, 2003. 2. The Defendant is Ronald M. Lingle, Jr., who currently resides at 155 Salem Church Road, Lot 49, Mechanicsburg, Cumberland County, Pennsylvania, since on or about November 20,2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 24, 1985, at Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. 7. Plaintiff has been advised that marital counseling may be requested and that a list of marriage counselors is available in the office of the Cumberland County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. (b;h~bJ Attorney for Plaintiff PA. ID. # 56002 2025 E. Main St. Waynesboro, P A 17268 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 petjury contained in 18 Pa. C.S. Section 4904, relating to unsworn falsification t?)ut~ori!ies. ", /~ V:;, ~ / DatefJl-9L/ /1) (/ "-/1TtlLU If {AJ/A i,J':y{jt{ I Patricia A. Lingleylaintiff ' tJ ~ ~ ............ J:i:. () ...0 C> l'"',,' it ]'---. c: ; Ci () -n ......... )J 8 Q. -,-, 2 F! . ',(" I () ...0 - , , ~l ~',- -1 '-'- -l:: f' f- ~ "'- 1;: f' Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04- 2987 -CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. ACCEPTANCE OF SERVICE I, Ronald Marlin Lingle, Jr., Defendant, accept service of the Complaint in Divorce in the above-captioned action. Date: 7 /;~ / () y ~ 17?~ Ronald Marlin Lingle, r. Defendant ~"." , ....., .~::;l c"" ~- (_..~ o " .-/ ~~p~ -.;-In, -;,:"C7 ,",1 --,C) .,i-f-, -,~ :=5~;~' '-..- j r", (,.) ~ " , ~v a ,-.q -v Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs, : No. 04-2987-CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant : In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 25, 2004. 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. Section 4904 relating to unsworn falsification to authorities. Date [)(li. I? dfJC!J I .,wl >"".: f"; (.,.') -ji Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 04-2987-CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce In Divorce a. v. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 Waiver 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 /0/1 i /r"Y-( I '. .'\,) ;,",,:',1 Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2987-CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 25, 2004. 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 ofthe decree. I verify that the statements made in this affidavit are tfUl~ and correct. I understand that false statements herein are made subject to the penalties of 18 P'a. C.S. Section 4904 relating to unsworn falsification to authorities. Date: /c/~~'1 ~vn/J)~ Ronald Marlin Lingle, Jr., Defendant ,....., (;-:::'I ~~ r:) em) -.,1 o -n =r'~ rnF -Drn -')9 -'6 {-,'~~ ,.:;n'1 :::'.4 ),," .'U -.< r'.) -J (;.~) !",J Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 04-2987-CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 Waiver 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 ,o/;.o/a'f . . ~ r;r~r% Ronald Marlin Lingle, Jr., Defendant ~ ....., .~ :.(~ o -n 'T'- rli-lJ r"~ -r,1m -uo ",L ~-~IC) r- -ri ,:~-n ~:~ () ~::_)ri1 -.:""1 ~.~ :.0 ~; C,,,) -,"J -i" (;,.? 1'0 Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2987-CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. AFFIDA VlT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ofth(~ Divorce Code was filed on June 25, 2004. 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. Section 4904 relating to unsworn falsification to authorities. Date !1!;2 7 ILl'! I fa L/L,~ / 11 PatriCIa Ann Lingle, Plaintiff 8 f',) ~ c::a = ;?: ..J:"" '"'0 co :z: :r mrn c::::> m:D Z~1:: c::: -om 6i !i: I ~~ ~.-";, :.-c' ~o -0 :>0 ::it a~ c: t:? ~ ..;..j <<::) ~ Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 04-2987-CIVlL TERM : Civil Action - Law Ronald Marlin Lingle, If., Defendant In Divorce a.v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 the statements made in this Waiver 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: / li:J I) D<-I ~afA~ Patricia Ann Lingle, Plai - 1 .~ 0 ,..." = ~ c: = g: .r:" "'0 OJ :z: ~:n ~gj c::> -<: -chi zr;. I ~:;:. ~6 kC.:~ -0 ~~ ~O '0 ::JI': 5>c: ca om ~ .~ 0 ~ Patricia Ann Lingle, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04- 2987 -CIVIL TERM : Civil Action - Law Ronald Marlin Lingle, Jr., Defendant In Divorce a.v.m. 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 Section 330 I (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service on July 14, 2004. (See Acceptance of Service on file.) 3. (a) Date of execution of the Affidavit of Consent and Waiver of Notice of Intention to Request Entry ofa Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff on October 27, 2004; by Defendant on October 20, 2004. 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice under Section 3301(c) was filed with the Prothonotary: November 1,2004 Date Defendant's Waiver of Notice under Section 3301(c) was filed with the Prothonotary: October 27, 2004. Da~4!/w1ri~ ('\ t.~.) ~~-~~ .r::- .-, f"':; \..D p..J c....y) - Of"" :+::+. :+. . . . . . . " . " . . . " . " . . . " .. . :+. :+.Of:+: :+. :+. :+::+.:+. :+: :+. :+. ;.t;;+::+.:+.,+:+. 'ti :+: :+. +.:+.:+.:+;:+.:+. Of. Of.:+: Of.:+.:+.:+.:+. Of' 'f. '+ . . . . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Patricia Ann Lingle, PEN NA. STATE OF Plaintiff NO. No. 04- 2987 -CIVIL TERM . . " " . . . . . VERSUS Ronald Marlin Lingle, Jr., . . . . . . . . Defendant DECREE IN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . DIVORCE AND NOW, pov. >0 , 2c>D,-/, IT IS ORDERED AND Patricia Ann Lingle , PLAINTIFF, DECREED THAT Ronald Marlin Lingle, Jr. , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . " . . . . . . . . . . . . . . . . BY THE COURT: ATTE T. . . J. . . . . . . . . . . . Of. Of. '+ Of. +. Of. 'f. '+' Of. Of. 'f '+' Of. Of. Of 't; Of:+: 'f. '+ Of. '+ '++: . . . . . . . . . . . . . :l';+: Of. '+ . :+:'+''l''+:+':+'Of.:+: '+ :+.Of.'l'0f. 0f.0f. 'fOf.0f. '+Of. :+: :+.:+:Of. :+: . . . . . . . " . . . . . . " " " " " " " " " " " " " " " " " " " " " . " " " . " " " " . " " " " " " " . . " " " " " " . " " " " " . " " " " " " " " - ~? ;z ~~/ ~~ /7<..7 r-.1'7 ~/~ fz?;Z ~?VV ~:t) /'{' A/ f <~. .-