The URL can be used to link to this page

Home My WebLink About04-5857 " TAMMY SCARLETT, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. NORRIS SCARLETT, Defendant : CIVIL ACTION - LAW IN : DIVORCE : NO. 0 if - ~-f'51 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 right 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 LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford St. Carlisle, P A 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. TAMMY SCARLETT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE NORRIS SCARLETT Defendant : NO. 04- 5fS'7 CIVIL TERM COMPLAINT The plaintiff, Tammy Scarlett, by her attorneys, the Family Law Clinic, sets forth the following cause of action. DIVORCE UNDER 23 Pa.C.S. SECTION 3301(d) 1. Plaintiff Tammy Scarlett, who currently resides at 221 North Market Street, Mechanicsburg, P A 17055 is a resident of Cumberland County, Pennsylvania. 2. Defendant is Norris Scarlett, who currently resides at 216 N. Arlington Avenue Harrisburg, PA 17019. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 14, 1998 in Harrisburg, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since February 1999. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marrIage. Date /1- (7 ,..O~ !01M(~ Jason C. Evans Certijed Legal Intern &If.~ ROBERT E. RAINS THOMAS M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 VERIFICATION I verify that the statements made in the foregoing Complaint are true 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. S4904, relating to unsworn falsification to authorities. Date: 1\\, t1-( ~..j<!o.Amj Tammy Scarkfi , . (; '" C'.'l () '.:..J -ll _r::- ~ :';:1 C:l '.~:' :I~ "\ ...::: r" I r-- -r" fT1 ,,>. :\ 1"" .1 ! (:J '0 r0 (; ~~~ ~ -I"" ":1 :rJ -;'., ( '/ "" , ~i1 .- ~"') -,) .~~: - , ~- - TAMMY SCARLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : IN CUSTODY O~. ~'i~1 : NO. CIVIL TERM NORRIS SCARLETT, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Tammy Scarlett, through her attorneys, the Family Law Clinic, to proceed in forma pauperis. The Family Law Clinic certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. 1l-17-0q Ret~t~~j Jft C. Evans Cerlffied Legal Intern ~~ ROBERT E. RAINS THOMAS M. PLACE LUCY JOHNSON- WALSH ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 C) ."1: ...:". ,,~ (:,:...) (-~) ..&;.- C) "'h ....1 ;,!'~:~~ . .Jf._- :~~~: J ~~~~.;I ... -"J I {. "~: iT: c, OO(L""': r,) t.,) r..,) . TAMMY SCARLETT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE NORRIS SCARLETT Defendant : NO. 04- 5r:57 CIVIL TERM NOTICE 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. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 1999 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. 94904 relating to unsworn falsification to authorities. 1J 1 f' 0 ~ Date ri1~ J e~ rutA , .. . ' ~ '. f ..' t , .,J. -' (~ ~~? ., I . I'-..J ~~g ..;;;;-- ,-" \ 1 .'h ::;3 ~ Ti :!..~ r'.. 'T~ d;~ , , i ...-.. ro:" _ c::) 'IIi,," r.,) /'\,) -Tl --, ~ F:,; en . .' . . TAMMY SCARLETT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE NORRIS SCARLETT Defendant : NO. 04-5857 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject The Family Law Clinic to the penalties of 18 Pa. C.S. S 4904 (relating to unsworn falsification to authorities), the undersigned verifies that Jason Evans mailed a true copy of the Divorce Complaint and Plaintiffs Affidavit on the Defendant by placing the same in the U.S. Mail, certified no. 7003 3110 5774 2570, restricted delivery, return receipt requested, postage prepaid, on the 24th day of November, 2004 addressed as follows: Norris Scarlett 216 N. Arlington Avenue Harrisburg, PA 17019 Sender's receipt no. 7003 3110 57742570 is attached hereto and incorporated by reference. Green return receipt no. 7003 3110 57742570 was delivered to The Family Law Clinic, bearing the signature of Norris Scarlett and showing a date of service of November 24,2004. The return receipt is attached hereto and incorporated by referenc:e. Date: {l. - O( -04 lC~ Jason c. Ev,ms Certi led Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 . Complete Items 1, 2, and 3. Also ~ item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mallplece, or on the front if space permits. 1. Article AddI'88lMlCl to: ........-' No r r \~ JCQ'( It++ 8\ G> N. fuhY\~D(\ ftvtf\\JC tkrrDb\J~\ PA-- 11-0,q " .,--~'-" , ' " " ^:: N !7Z ~ Q 'P :x 3. ServIce ~ ~Mall o Registered D Insured Mail c:J Express Mail ~turn Receipt for Merchandise DC.a.D. -- --- 4. Restricted Delivery? (Extra Fee) ~s -- 70 04 5774 2570 DamMilic ...." ~ 1 02595-02.M-1 035 -" CJ l"- Ll') ru Postage $ ::r l"- I"- LI') ::r CJ Certilled Fee CJ CJ Retum Reclepl Fee (Endorsement Required) CJ Restrtcted Delivery Fee r-'l (Endorsement Required) r-'l ITl \\. Total Postage & Fees ITl CJ CJ I"- Q to....) t,:,:"::, 0 :-:.: ~ (;:;-..:) .1;.- ~T1 '1 (:::' s:!"Tl 1 - f"ll ("') n'F I ~;J~] , .. ".-'~: ,,-) J:.;~1 ,~:H -'''''U ,;:.( -.J!... ',,',";'(j ......". ,..... ,;5m .~ ',~ -....:~.; Ui ,.J- ::;:;] \0 -< -.- ) TAMMY SCARLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE NORRIS SCARLETT, Defendant : NO. 04-5857 CIVIL TERM CERTIFICATE OF SERVICE I, Burgess Bradshaw, hereby certify that I am a competent adult and that I served a correct copy of the Notice ofIntention to Request Entry of g3301 (d) Divorce Decree on February 4, 2005, to Norris Scarlett, by regular U.S. mail, postage prepaid, at 216 N, Arlington Avenue, Harrisburg, PA 17013, I verify that the statements made in this certificate 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: 6 'i fir-Ill, . ~'r c ~k- Burgess C. Bradshaw Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Phone: (717) 243-2968 Fax: (717)243-3639 ,_.3 c :~, ,'j\ .-- ,-,..;' ~. () ~'n "C_--.-. ;:'n:~:~\ \~? """.1 'C. TAMMY SCARLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE NORRIS SCARLETT, Defendant : NO. 04-5857 CIVIL TERM CERTIFICATE OF SERVICE I, Burgess C. Bradshaw, hereby certity that on this 15th day of April, 2006, I am serving a true and correct copy of the Praecipe To Transmit Record and Divorce Information Sheet on Norris Scarlett by first class U,S, mail, addressed as follows: Norris Scarlett 216 N. Arlington Avenue Harrisburg, P A 17013 Date: D'i.(I)(O'--- ~~{~ Burgess C. Bradshaw Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, P A 17013 ~'" !'~) .::.:::.' ';;;;J. o --il ..0,,' (Ji ~,) 1"'...,) <)1 - " TAMMY SCARLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE NORRIS SCARLETT, Defendant : NO, 04-5857 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: I, Ground for divorce: irretrievable breakdown under S3301(d)(l) of the Divorce Code. 2, Date and manner of service of the complaint: November 24,2004, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3, (a) Date of Execution of the affidavit required by S3301(d) of the Divorce Code: November 17, 2004. (b) Date of filing and service ofthe plaintiffs affidavit upon the respondent: November 22, 2004 filed, November 24, 2004 served by first class United States Mail. 4. Related claims pending: None, 5, Date and manner of service of the notice of intention to file praecipe a copy of which is attached: Defendant was served on February 4,2005 by first class mail, postage prepaid, ~c~ Burgess C. Bradshaw Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Phone: (717) 243-2968 Fax: (717) 243-3639 " , TAMMY SCARLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE NORRIS SCARLETT, Defendant : NO, 04-5857 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: Norris Scarlett, DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 9 3301(d) affidavit. Therefore, on or after February 28, 2005, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce, A counter-affidavit which you may file with the prothonotary of the court is attached to this notice, Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims, 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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. (~ {,~z,~ (~ 'r0 ~,~ "/~) -- c)', ....-J 'i"? --,) \C~, 't;'t;'t;:+i:':'+':f.'+':'::':'f . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'to '+' Of. 'to + +:.: '+' '+' '+' Of 'f 'to +"" ++,., '+' '+' '+':Ii . . . . . . . . . . . . . . '+''+':.:'+' :+i:':+:+ '+''+':Ii+'+''+''+' . '+''+''+'+'t;++:+i++'+'+++:ti+'+' .n n. ,+,,+,+:Ii:ti+ n . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY TAMMY SCARLETT, PENNA. STATE OF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~+++++++:++'+':Ii+'t;+'f+ No. 04-5857 PLAINTIFF VERSUS NORRIS SCARLETT, DEFENDANT DECREE IN DIVORCE AND NOW,----4\>v'' \.. TAMMY SCARLETT /~ 2-0 "-lAJ) ) , IT IS ORDERED AND , PLAINTIFF, DECREED THAT NORRIS SCARLETT AND , 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; NONE. By THJo Co /' ATOm ~ d. ~ ( PROTHONOTARY . + 'to:i''to+ 'to 'to + +: '+' 'to . 't;+'f+++++ .. n +'f'f'to'f+'f+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . / 17??/ 7j /i[J:Pr./ ?~h(, '-7~_/ //., ~~, .'.2 /-?" ,,,. 7?7dX.J ")-,,,/ ( !" r- t. ,+ " >27 Ie ~; C', 7/.c / ,.i... .' /7