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HomeMy WebLinkAbout05-0955 TRACY MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - : IN DIVORCE ROBERT MOORE, Defendant :NO.DS'-9S'S CIVILTERM 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 MAY BE 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, 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. TRACY MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYL VANIA v. : CIVIL ACTION - : IN DIVORCE ROBERT MOORE, Defendant : NO.oS"-9S5 CIVIL TERM The plaintiff, Tracy Moore, by her attorneys, the Family Law Clinic, sets forth the following cause of action for divorce: COMPLAINT UNDER THE DIVORCE CODE, 23 Pa.C.S. ~~ 3301(c) and 3301(d) 1. Plaintiff is Tracy Moore, who currently resides at 367 North Fourth Street, Apartment A, Newport, Perry County, Penns1vania since January 8, 2005. 2. Defendant is Robert Moore, who currently resides at 503 South 32nd Street, Camp Hill, Cumberland County, Pennsylvania since August, 2002. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on April 21, 1984, in Duncannon, Perry County, Pennsylvania. 5. The plaintiff and defendant have lived separate and apart since approximately July 1,1986. 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 marnage. Date: ;) - d 5 . c:x.s- \Jil:f:tw11 Sara A. McCormick Certified Legal Intern THOMA ACE ROBERT E. RAINS Supervising Attorneys ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Counsel for Tracy Moore VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904, relating to unsworn falsification to authorities. Date: () - ~"~ - os- ;/Vl-a/ j t fY!cK~ e Tracy Moore, P amtIff ~ 1) ~ (-') t.n :-_.,3 n c ~, ,.~ ~, C.:,' (,', TRACY MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - : IN DIVORCE ROBERT MOORE, Defendant : NODS .q s:s CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Tracy Moore, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 1/23/05 I , JJ;RCf) Sara McCormick Certified Legal Intern tdL-. INS THOMAS . PLACE LUCY JOHNSTON- WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 (- ~ 1-.; --, " c.. <.~; t" TRACY MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - : IN DIVORCE ROBERT MOORE, Defendant : NO.DS-955 CIVIL TERM 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. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I. The parties to this action separated in July, 1986 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 conceming 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. r- Date;;2 -J.'? - D..S 'jJ1()"~ f/1,~ ~cy Moo , Plaintiff ~' ,'\ -n ., '>.i ( .\.' TRACY MOORE, PIa inti ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIl. ACTION-LAW DIVORCE ROBERT MOORE, Defendant NO. 05-955 CIVIL TERM PROOF OF SERVICE I, Sara A. McCormick. hereby certify that I am a competent adult and that 1 served a true and correct copy of the above captioned Complaint fix Divorce on the defendant, Robert Moore, by sending. on February 23'0. 2005, a copy of the same via certified, restricted delivery mail with return receipt requested. addressed as follows: Robert Moore 503 South 32nd Street Camp Ilill. PA 1701\ On the 2nd day of Mareh. 2005 the Family Law Clinic received the return receipt, bearing the signature Robert Moore and showing a date of service of February 24th, 2005. I understand that making any litlse statement would subject the Family Law Clinic to penalties under 18 Pa. C .S. ~4904 (relating to unsworn falsification to authorities) Dated:JEllQ5~ d~9_,{Yd/VlA( () Sara A. McCormick Certified Legal Intern ~~-tJ~ THOMAS PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Counsel for Defendant Supervising Attorneys F AMlL Y LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 ..D .-'! ["- ru U.S. Postal Service,,, CERTIFIED MAIL", RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Postage $ ::r ["- ["- U1 coG) Hlii tA ltoll). ::r CO CO CJ Return Reclept Fee (Endorsement Required) t:J Restricted Delivery Fee r1 (Eftdorsement Requllad) .-'! m Certified Fee Total Postage & Fees $ m D ento rJ CJ ~~ (~ ("SR/) + L---y-v"l::3 c.:> /""fL.....-- r'- ~75r;;~~~~~~~~9~~~~~~4~~~~~~~~~~~~~~i~~ c;,y,SI"..Z'f'<.' Cu: ,;2jJ M I; ZJ I . Complete items 1, 2, and 3. Also complete 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 mailpiece, or on the front jf space permits. C. 11'7 o Agent o Addressee DYes DNa 1. Article Addressed to: D. Is delivery address d\ffer'em from item 1? If YES, enter deliver)' address below: (2 c 13"".,-1 TY/ C>.c::>.'~- Co J ~":) (~> ~ C vA') j d ".-.1, ';/-r'022f ~I 1;,'17 o Express Mail ~eturn Receipt for Merchandise o C.O.D. c <'Ocf -!Jdt } 4. Yes 2. Article Number (Copy from service label) 7 cJ /7"3 "3/10 000 cj r; 7-7 (I ~ 7//." PS Form 3811, July 1999 Dorr~qtk: Return Receipt 102595-99-M-17S9 TRACY MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION : IN DIVORCE ROBERT MOORE, Defendant : NO. 05-955 CIVIL TERM CERTIFICATE OF SERVICE I, Sara A. McCormick, hereby certify that I have served true and correct copies of the Notice of Intention to Enter Divorce Decree and Defendant's Counter-Affidavit on the Defendant, Robert Moore. I did so by sending a copy of same in the United States mail, First Class, postage Prepaid, this 13th day of April, 2005. I am mailing the copies to the Defendant at the following address: 503 South 32nd Street Camp Hill, P A 170 II ~~9~jl Sara A. McCormick Certified Legal Intern F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 ~~::; c") c.;..: -.:'n ,:,.n ..,...,..,. '--C :;::1 (",) :..::> TRACY MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - : IN DIVORCE ROBERT MOORE, Defendant : NO. 05-955 CIVIL TERM CERTIFICATE OF SERVICI~ I, Jeffrey Stovall, hereby certify that on this 29th day of June, 2005, I am serving a true and correct copy of the Praecipe to Transmit Record and. Divorce Information Sheet on Robert Moore by first class U.S. mail, addressed as follows: Mr. Robert Moore 503 South 32nd Street Camp Hill, P A 17089 Date:JvNC L~ p5"' F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 .-> c'::':'> -, ;::.:;-, ,- r,::.--:,: ~ N CP -;1 ;;;. 1') .- o .. .-< ~"""1 PIE"" -n;J,.~ ~Y. --~Js.~: -:;~r?\ ';....1 -:;:,: 1! ~- C...1 <..oJ - TRACY MOORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION IN DIVORCE ROBERT MOORE, Defendant NO. 05-955 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 330Hd) DIVORCE DECREE TO: Robert Moore, 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 Mav 13. 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, P A 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. o c "c. I-i ........ = = "-" ~- S~ "'''- o -0 :;:l Ffi:2J r- -afTi ;:'~crj tj~ c3rn :::'''l ':':>" ~j:J -< N 0::> '"lJ ::r: ~ '-'" (....:.i - TRACY MOORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE ROBERT MOORE, Defendant NO. 05-955 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infOlmation, to the court for entry of divorce decree: 1. Ground for divorce: unilateral no fault under 9 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted deliver, return receipt requested, postage prepaid. Service was complete upon receipt by Robert Moore, March 2, 2005. 3. Date of execution of the Affidavit required by 9 3301 (d) of the Divorce Code: February 23, 2005. Date of filing of Plaintiff's Affidavit: February 23, 2005. Date of service of Plaintiff s Affidavit upon Defendant: March 2, 2005. 4. Related claims pending: none. 5. Notice ofIntention to file Praecipe was served on Defendant, by regular United States mail, first class, postage prepaid ril13, 2005, a copy of which is attached. JVN€ lCj, vPS / Date (iu~4JM- VJWB . RAINS THOMAS PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Counsel for Defendant Supervising Attorneys FAMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 r-> = = ""'~ S N OJ -a .~". ~ (..,) r- - o -11 ::;:! ~.~ -r1 rti;= :::1\3 ~~{ '--I ~u "" T ~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .~ . ~ :+0 :+: :+: :t::+: .~ ~ ;F.;f.:+::+::+::+: :+::+: Of. ;+: . .. if. :f.:+::+:+ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. TRACY MOORE, No. 99"5 2005 Plaintiff VERSUS ROBERT MOORE, Defendant DECREE IN DIVORCE c::r3:3Ip.M . Joar, IT IS ORDERED AND AND NOW, :::r~(. DECREED THAT , PLAINTIFF, TRArv MnORR AND ROBERT MOORE , 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 ATTEST: ~ ,~~ , /ROTHONOTARY .. . '+:+::+: :+::of. it::+::+: +;to: +' :+::+.:of. +:;to: 'f. . :+.:+::+. '+':+: Of:+::+::+: Of. +'" '+:+::+::+::+:+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . .;#p;2 ~I ~ ~)(/.. IlL. '7:.:/ Z~ ~ /P 500 )I'L . . . ", .... .. ..