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HomeMy WebLinkAbout02-0567LINDA L. STETS Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIVORCE JOSEPH V. STETS Defendant. NO. 02- %':/ CIVIL TERM 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 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, Cumberland County Courthouse, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland 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. LINDA L. STETS Plaintiff, JOSEPH V. STETS Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : DIVORCE '. : : NO. 02- -3~t' 7 CIVIL TERM COMPLAINT The plaintiff, Linda L. Stets, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce. DIVORCE UNDER 23 Pa.C.S. SECTION 3301(c), 3301 (d) and 3301(a)(6) OF THE DIVORCE CODE 1. Plaintiff is Linda Stets, who currently resides at 306 N West Street, Carlisle, Cumberland County, Pennsylvania, since February 9, 2001. 2. Defendant is Joseph V. Stets, who currently resides at the Coumry Manor Trailer Park, 56 Cherry Lane, Carlisle, Cumberland County, Pennsylvania, since 1984. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 22, 1983 in Carlisle, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since February of 2001. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff avers that Defendant, in violation of his marriage vows under the laws of the Commonwealth of Pennsylvania, has offered such indignities against the Plaintiff, his injured and innocent spouse, as to render the Plaintiff' s condition intolerable, and life burdensome. 9. Plaintiff has been advised that counseling is available and that she may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff Linda L. Stets requests the court to enter a decree in divorce dissolving the marriage. M. PL2C~ ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing Complaint are tree and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: Linda L. Stets LINDA L. STETS Plaimiff, V. JOSEPH V. STETS Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DIVORCE : NO. 02- 5(~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Plaintiff, Linda L. Stets, to proceed in forma pauperis. I, Jason P. McNicholl, Certified Legal Intem in the Family Law Clinic, 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 service to the party. Date: /l/pon P. McNicholl {~Certified Legal Intem ROBERT E. RAIN THOMAS M. PLACE TERI L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 LINDA L. STETS : IN THE COURT OF COMMON PLEAS OF Plaimiff, CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH V. STETS Defendant. DIVORCE : NO. 02-Cx:>567 CIVIL TERM PROOF OF SERVICE I, Jason McNicholl, certify that I served a tree copy of the Divorce Complaint on Defendant by placing the same in the U.S. Mail, ceWlfied no. 7099 3400 0018 4996 9312, as follows: Joseph Stets Country Manor Trailer Park 56 Cherry Lane Carlisle, PA 17013 Sender's receipt no. 7099 3400 0018 4996 9312 is attached hereto. On or about February 5, 2002, the green return receipt no. 7099 3400 0018 4996 9312 was delivered to the Family law Clinic, beating the signature of Joseph V. Stets, and showing a delivery date of February 5, 2002. The return receipt is attached hereto. Date ~//q/o~ e~~ *~,'~ 3qtson P. McNicholl Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and eddrees on the reverse so that we can return the card to you. · Attach this card to the back of the mailplede, or on the front if space ba~nits. ~ 1. Article Addressed to: O Addm C'%,..'zZ~'~-4.//".""/ //o'.. [] R~i~:i ill R~r~ .~,~m for r'l Insured Mail [] C.O.D. 4. Re~flcted Delivery? ~xtre Fee) ~ Yes 2. Ar ticle Num bet (Co/~y?r~ ~v~ce ~be~ ~ ~ peFbtm~3811!Ju~1~gl~ i i~;ii iDo~n~ticRetumReceipt 'i025~-99-M-1789 LINDA L. STETS, Plaintiff, Vo JOSEPH V. STETS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DIVORCE NO. 02- 567 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S: §4904, relating to unswom falsification to authorities. Linda L. Stets, Plaintiff LINDA L. STETS, Plaintiff, JOSEPH V. STETS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : DIVORCE .' .' : NO. 02- 567 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c~ OF THE DIVORCE CODE 1. I consent to the entry of a £mal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 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 unswom falsification to authorities. Linda L Stets, Plaintiff LINDA L. STETS, Plaintiff, JOSEPH V. STETS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .' ; : DIVORCE .' : NO. 02- 567 CIVIL TERM CERTIFICATE OF SERVICE I, Megan Malone, do hereby certify that I have served a true and correct copy of plaintiff's Affidavit of Consent and Waiver of Notice of/ntention to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code on the following person this 24t~ day of May, 2002 via United States first class mail. Joseph V. Stets Country Manor Trailer Park 56 Cherry Lane Carlisle, PA 17013 Certified Legal Intern LINDA L. STETS, Plaintiff, JOSEPH V. STETS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .' : : DIVORCE : NO. 02- 567 CIVIL TERM CERTIFICATE OF SERVICE I, Megan Malone, Certified Legal Intern, hereby certify that I have served a true and correct copy of Defendant's Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code, and the Praecipe to Transmit Record by placing the same in the United States mail, postage prepaid on this 16t~ day of July, 2002 to the following: Linda L. Stets 1420 Bradley Drive Apt F-312 Carlisle, PA 17013 Joseph V. Stets Country Manor Trailer Park 56 Cherry Lane Carlisle, PA 17013 Megan~al-one Certified Legal Intern C'~ o 0 LINDA L. STETS, Plaintiff, JOSEPH V. STETS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIVORCE NO. 02-567 CIVIL TERM AFFIDA~T OF CON~q~NT 1. A Complaint in Divome under §3301(c) of the Divome Code was filed on 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 tree 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 h V~. Stets, Defendant LINDA L. STETS, Plaintiff, V. JOSEPH V. STETS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DIVORCE : NO. 02-567 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST .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 ifI 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 affidav/t 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: eph V. Stets, Defendant LINDA L. STETS, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : DIVORCE : JOSEPH V. STETS, : Defendant : NO. 02-567 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the follOwing information, to the court for entry of a divorce decree: 1. Ground for divorce: Consensual No-Fault Divorce under 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: February 5, 2002. Service performed by mail. 3. Date of execution of the Plaintiff's Affidavit required by § 3301(c) of the Divorce Code: May 21, 2002; Date of service of the Plaintiff's Affidavit upon the Defendant: July 15, 2002. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: United States mail, first class, postage prepaid on July 16, 2002 ega('{Malonfi Certified Legal Intern RoBI /r INS THO19gAS M. PLACE LUCY JOHNSTON-WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of LINDA L. STETS, Plaintiff Versus JOSEPH V. STETS, Defendant PENNA. N o. 567 2002 DECREE IN DIVORCE ~.- (.~: , ~/'~}/~ AND NOW, , , IT IS ORDERED AND DECREED THAT ~DA .~] L. STETS AND JOSEPH V. STETS ARE DIVORCED FrOM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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; None. PROTH O N~C~TAF~i'