HomeMy WebLinkAbout04-3497
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f'<"\cn\que. CAmpbe \ \
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYL V ANlA
$t.!q,
No. 04- CNIL TERM
~f\~q~~('~. (.~l\"'\~be.\ \
Defendant
IN DNORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter affidavit within twenty days after this affidavit has been served on you or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER
~3301 (d) OF THE DIVORCE CODE
1. The parties to this action separated on oq~Od.- ~OO ,
to live separate and apart for a period of two years.
and continued
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of marital property,
lawyer's fees, or expenses if I do not claim them before a Divorce is granted.
I, mi)(li'lu~ c.l=lmp~J I , verify that the statements made in this Affidavit 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 P.S. Section 4904.
1- 16--04
Date
'ffi=o s~-RMpbtU
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA
CIVIL ACTION - LAW
fYloni9Ue. ~t
Plaintiff
: No. 04- 31..(Q 7
Civil Term
v.
C.'nrI5Iopher fC4l1 CAmt'~<.\ \
Defendant
: IN DIVORCE
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 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, I Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OF 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 BEI,OW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
fYJonlque C,qrr(Jhe) /
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYL VANIA
v.
No. 04-
CNIL TERM
Chn~wpher P. &wtipbe.J1
Defendant
IN DIVORCE
COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE
1. PlaintiffismDn,' qUe. &mpbcJ I , who currently resides at
liD W. H,3h Sh-te-f ~p+.ll ~RlJ,':::Jc...
Cumberland County, Pennsylvania.
2. Defendant is (\.'nl"\"...~er ~. ~M~II, who currently resides at
~)~ 'Rfchwood lAvle... ~. t) YJ\u~ ~r\~f., ~D.Lo~\'\
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 ~t.. 21... IG'16
at
~ll\" ~~f'l~} ~Sl.OL.Lr\ LDI..\.D\4.
5. The marriage is irretrievably broken, and the parties separated on
01-0d, - ~("J() I
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.
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.
r'\-\5-0\.\
Date
~
Plaintiff, Pro F
~OIm.pWJ
I, tv\oni qU-t.. ~~m~btl\ , 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.
1-\'0-04
.~ ~bdO
Plaintiff, Pro ~
Assisted by:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Date:
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IYlon\qu.e.. CM\~II
Plaintiff
C~r\~~\\tr
v.
P. CMlV\fbe II
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
PENNSYLVANIA
: NO. 04- 3'itiYIL TERM
: DNORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly aIlow, rYloniqut &11lfbel1 ,Plaintiff, to proceed in forma pauperis.
I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis,
certify that I believe the party is unable to pay the costs and that I am providing free legal
services to the party.
Jessi Diamondstone
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 170 I3
(717) 243-9400
:::;j
)
Monique Campbell,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUN1Y PENNSYLVANIA
v.
No. 04-3497
CIVIL TERM
Christopher P. Campbell,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE
I,
l~la rk f). RpPclpr
, do hereby swear that I have served Christopher P.
Campbell with a Divorce Complaint under Section 3301(c) of the Divorce Code by personally
handing him a copy at
505 Richwood.
apartment D.
(Street Number and Address)
Missouri 64015
(State)
(Zip)
Blue Springs,
(City)
at 7 : 00
(Time)
p.m. on the 31st
(Date)
day of August
(Month)
,200 4
(Year)
I, Hark \). Reeder , verify that the statements made in this
(Name of person who performed service)
Affidavit of Service is 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.
~~o~
Date: 08/31/04
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Monique Campbell
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
v.
No. 04-3497
CIVIL TERM
Christopher P. Campbell
IN DlVORCE
Defendant
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 330Hd) of the
Divorce Code.
2. Date and Manner of service of the Complaint: The Affidavit of Service For Personal
Service was signed on AUl!ust 31. 2004.
3. (I) Date of execution of the Plaintiffs Affidavit required by Section 330l(d)
ofthe Divorce Code: July 15, 2004.
(2) Date of filing and service of Plaintiffs Affidavit upon Defendant:
Filing Date: July 20, 2004.
Date of Service: August 31, 2004.
4. Related claims pending: There are no outstanding claims.
5. Date and manner of service of the notice of intention to file Praecipe to
.
Transmit Record, a copy of which is attached: Mailed bv regular first class mail on
March 29. 2005 to Defendant at 505 Richwood Lane, Apartment D, Blue Springs, MO 64014..
Plaintiff's Social Security Number: 432-41-4776
Defendaut's Social Security Number: 500-94-8737
.'-' tf(j(,()'Jy fllntl fl..rlf\L1
Jessie Diamondstone
Grace D'Alo
Geoffrey Biringer
Attorneys for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
(~
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IN THE COURT OF COMMON PLEA
OF CUMBERLAND COUNTY
MONIOUE CAMPBELL
PENNA.
STATE OF
PLAINTIFF
No. 04 3497 Clvn TERM
VERSUS
C'HRTS'I'OPHP.R P
('IIMPRP.T.T.
DEFENDANT
DECREE IN
DIVORCE
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AND NOW,
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20
,~5 . IT IS ORDERE
MONIOUE CAMPBELL
DECREED THAT
, PLAINTIFF,
AND CHRISTOPHER P.
C'AMPBET,L
. DEFENDAN ,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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AND
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
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PROTHONOT RY
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA
YET BEEN ENTERED;
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NOT
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