The URL can be used to link to this page

Home My WebLink About04-3498 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW , Plaintiff DM. t \LL L. (U:cc; v, : No. 04- .J 'I "'f 't Civil Term 0c;;,H J 11r~"(\.'i ' J Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM liGHTS YOU HA VE 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, 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 OF ANNULMENT IS GRANTED, YOU MAY LOSE THE liGHT 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 6a,nidk L .{i;.CC( Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04- CML TERM SCDtt j ers:1 Defendant IN DIVORCE COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is L\aD' e..}/e..- L. J(;CCI who currently resides at ,-{of (loJ/crdi// fd ?/)()!a. ~ //6c1S- Cumberland County, Pennsylvania. 2. Defendant is Yo II J. 11r;s-,n.j , who currently resides at /;t., Lark sf 7tl,'ddle!IJIU~/ f1 /7as-l 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 /;/3)3 at 5. The marriage is irretrievably broken, and the parties separated on "<}fr 6. There have been no prior actions of divorce or annulment between the parties. Danielle Tucci, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3498 CIVIL TERM Scott Persing, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under g3301(c) of the Divorce Code was filed on May 28, 2004. 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 :md 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: 8- 7- 0 s Signature: ~. 12-- ' Scott Persing, De:fendant g ..., ~ = = t c.n ,... ~:n c:::: ~ en ~z. , e= \D ~o """ ~~ ::x: 5>8 - ~ .. ~ .r:- -.l -< v Danielle Tucci, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y PENNSYLVANIA v. No. 04-3498 CIVIL TERM Scott Persing, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &330l(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 divon:e 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. 94904 relating to unsworn falsification to authorities. C _L jO ... Signature: ~ u'C..tr....---- Scott Persing, Defendant ....; Date: 8-7-0$ i r- ~ ..s ~ .. - \1 ".II: sl 0- 9~ '" I "5 ft~ c.!) iR~ ::i ~ ~ ~ ~ - 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. Dat:Js)( d~cI~ Plaintiff, Pro Se I, iVllh Lilt L ./ilf'.Cf . , 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. ?;1s~~f Da't/'- '/ J1, L4:zt rI~ Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 :?; ('.~'.' --i~- ,. I' \'..) c:.:' I'...) o DO-rh e..l Ie. L - I Ll(~C , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 04, .1'1:fvIL TERM ~coH j ?-.Qr~,1\5( DefetKlant DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Afln. e-II f I ;;'CLl ,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 a Diamondstone Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 r': "',) ( 1"-...') '-:-.:::" c;:::, ._<;.~- :7: o Go.r\11l- \l~ L IUcc: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA 3V} q <( No. 04- CIVIL TERM v. SCd-{ J ?QI0'~ Defendant IN DNORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Submitted, Plaintiff, Pro Se ,..., '.:::;.) C,~') ..S:;- 1',,) C) r-,) ",'I co Danielle Tucci, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3498 CNIL TERM Scott Persing, Defendant IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Submitted, ,i]dt, L- P1amtiff, Pro Se ~ -' ,',~ ".;- .'." t . ., , j !..., , . ,'- - , Danielle Tucci, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA v. No. 04-3498 CNIL TERM Scott Persing, Defendant IN DIVORCE AFFIDA VIr OF CONSENT 1. A complaint in divorce under ~3301(c) ofthe Divorce Code was filed on May 28, 2004. 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 ~lsification to authOrities~ A , Date: 7-/(-,1.5 Signature: ~ I. ~ Uanlelle Tucci, Plaintiff (~ ~~ ~'I' ::j -, ,..., = = G.n <-- c: r'- o -n -l :r: -n nlp~ -om -nO i:)C, J..]", [_-;'1 ;;'20 r--=snl -< ;;.0 '< co )::"'" ::!: cs C) N Danielle Tucci, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3498 CIVIL TERM Scott Persing, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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 trut:, and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 7-/1-4.,)' ...., = 0 = G.'" -0 L. --l C~ ::c r..- fl,:D r-- CO ~gC; C) , ~.1::l C) ~ , -~ -- :-~ C:i ( C;? 5 'reI ...:::.... :::,-~ --' C> -< :l) 1''' .< - Danielle L. Tucci Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3498 CIVIL TERM ScottI. Persing Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Angela Shaver, do hereby depose and say that, on behalf of and on the authorization of the Defendant, I personally received and accepted service of a true lmd correct copy of the 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. 7/.).(p /o!: , , Date ,~~ Angela Sha r , , , .. > ',,' \. .t)':\ ."" . } " ~~~.. "J(/', " . -"\. .~ .. ,'~", ,-.,.....:' .~, ,(: s. .~ ..".. ~ '. " ~ .,.;;, '.." >:, S -~ , :')' o C' 'j '''T ~i,{" lw ~. ..__!; _,:, _~ .~. ',<ii' ,," """''<1.~'- '''_''':1..,,';;.;0.." c " " ,. .-> c::::;) r'_<-;) c:r> ~ C.:: ," r--? 2 '" ...;,;"",,~~.~~.,., ,\: .- --. n =n ...-\ -r:.-rI r1"lp --;~:;j .~'~V '-';"':\ :}? -::-' ::;',,:", r:~ 0" \--.) ,:.,.~. :::;(. o Danielle L. Tucci Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNrY PENNSYL VANIA v. No. 04-3498 CIVIL TERM Scott J. Persing Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORI! 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 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Sl~rvice was accepted on behalf of the Defendant by Anl!ela Shaver. employee of the Danphin County Work Release Center. Anl!ela Shaver sil!ned for the certified. return receillt. restricted delivery of the Complaint and sil!ned the Acceptance of Service form on Julv 26. 2005. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, July 14. 2005; by Defendant, AUl!ust 7. 2005. 4. Related clairns pending: There are no outstanding claims. 5. Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 18. 2005. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: AUl!ust 9. 2005. Plaintiff's Social Security Number: 189-60-0750 Defendant's Social Security Number: unknown Jessica Grac ' Alo Geo ey Biringer Attorneys for Plaintiff MidPenn Lllgal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 () ?; "\.1 f_~-' t.::,;' "::-:; (0 ' ::~ , ~. ~b ..i:.. :~ ...., = = en ",.. c:: G'l Q. ~~ ~3~ :;:1-,-, ._,~ -r"\ 0-- ::-..".l..-:? 6rn ..... ~ :< en """ :x '? c..:> - .' . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . + + + + + . + + . + . . + + + . + . + . . + + . + + . . . . + . + + . . + + + . + + . + + + . . . . + + + + +:t''f.:+ . + . + . + + + Civil Term : + + + + + + . + + + + + . + . . , . . . + , + . . . . + + + . + + . , . + . . . . . + + . . . . . . . . + + . + + + + + + + + + + + + . + + + + + + + + + + + + + + . + :+:++++:+:+::++'t:+:+::++ ++ :+:++:+: ++ :+:+++++ ++:+ ++:+:+++++++++:+ :+ +++++++++++++++++++++++++++++~ + IN THE COURT OF COMMON PLEAS ; + OFCUMBERLANDCOUNTY : STATE OF PENNA. Danielle L. Tucci Plaintiff No. 04-3498 VERSUS Scott J. Persing Defendabt DECREE IN DIVORCE AND NOW~ Danielle L. Tucci . PLAINTIFF, .- 200) . IT IS 2$ ORDERED AND DECREED THAT AND Scott J. Persing , DEFENDANT. 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; PRCYfHONOTARY Of:+:+::+::+:+:+ +:+:+:+ +:+ Of. +:+:+ +:+:+ :+::+::+ +':+ Of 'f Of Of ,+ :+:+::+:+: :+ :+:+ + J. _* f /"7~ ~tt 50 ;;e'!> S7 r ~~~~? ~ _.7(#. ;ie.~ ~ ,. ..~,;' . .' . .-