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HomeMy WebLinkAbout02-0809TANYA OBERTON, Plaintiff REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO.0~ -- ~'0~ CIVIL TERM : 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 TANYA OBERTON, Plaintiff REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW :NO. 0c~~- ~)'~57 CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE Plaintiff is Tanya Oberton, an adult individual currently residing at 4 James Drive, Newville, Cumberland County, Pennsylvania. Defendant is Reginald L. Oberton, an adult individual currently residing at 107 East Willow Street, Carlisle, Cumberland County, Pennsylvania. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on December 5, 1998, in Carlisle, Cumberland County, Pennsylvania. There has been a prior action for divorce or annulment between the parties in Cameron County, Pennsylvania, docketed to No. 97-4334, finalized on January 20, 1998. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. Plaintiff has been advised of the availability of counseling and the fight to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent injured spouse, as to make her condition intolerable and life burdensome, WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (a) (6). Respectfully submitted, Ma~a~s, Esqm~ Attom~ f~ Plaint~ G~FFIE & ASSOC~TES 200 No~h Hanover S~eet C~lisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 unswom falsifications to authorities. TANYA OBEI~TON TANYA OBERTON, Plaintiff REGINALD OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION-LAW : NO. 02-809 CIVIL TERM : IN DIVORCE PRAECI~E TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Reginald Oberton, the Defendant in the above captioned matter. April 1, 2002 ROBI~RT E?RAINS THOIVl~S M. PLACE Supervising Attorney LUCY JOHNSTON-WALSH Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 TANYA OBERTON, Plaintiff REGINALD OBERTON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 02-809 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Jennifer Heverly, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of Praecipe to Enter Appearance on Marylou Matas, Esquire, of Griffie and Associates, 200 North Hanover Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail, First Class, postage prepaid, this 2nd day of April, 2002. THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 TANYA OBERTON, Plaintiff VS. REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-809 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 14, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 decrees. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TANYA TANYA OBERTON, Plaintiff VS. REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-809 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c.) OF THE DIVORCE CODF, 1. I consent to the entry of a final decree in 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. Section 4904 relating to unsworn falsification to authorities. DATE: TANYA OBERON ~ TANYA OBERTON, Plaintiff VS. REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-809 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 14, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 decrees. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. RE(~AL-D L. 0BE-RT-OIq / TANYA OBERTON, Plaintiff VS. REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-809 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(e.) OF THE DIVORCE CODE 1. I consent to the entry ora final decree in 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 sero to me immediately after it is filed with the Prothonotary. DATE: 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. R~II~i<L. OB-ER~01~/' TANYA OBERTON, Plaintiff Vo REGINALD L. OBERTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-809 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Teri L. Henning, Esquire, acknowledge that I received a certified and true copy of a Complaint in Divorce in the above captioned action by first class mail, postage prepaid, and further acknowledge that I am authorized to do so on behalf of the Defendant, Reginald L. Oberton. FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 TANYA OBERTON, Plaintiff VS. P~GINALD L. OBERTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 02-809 CIVIL TERM PRAEClPE 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 §3301 (c) ~ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service by Teri Henning, Esquire on February_ 27: 2007, Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff 6/20/02 ; by defendant 8/16/02 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 19, 2002 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: August 20, 2002 ~ u Matas,/~ttorney f~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of TANYA OBERTONt Pla ~ ntiff VERSUS i~E:GZi~T ~ n. Defendant PENNA. 02-809 Civil Term DECREE IN DIVORCE AND NOW, DECREED THAT AND Tanya Obert~t Reginald L. Oberton ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,2002 , IT IS ORDERED AND , 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; ~one BY TH ATTEST: