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HomeMy WebLinkAbout05-1627 PENNY L. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lUNDER !S3301(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 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 ofthe 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. s4904 relating to unsworn falsification to authorities. Date 7-/3-0:-; D .~ ~b Price, Plaintiff (") C "TJ~ lTlt1J ~;;;r:' ~~! 1;:(-':; ~(:-) <;; L. ::<! ...., <=:> = Con - c en o o .,., :r ~~ :=lO ..l:=H 0- zO om ~ .< "'" :.:I: - .. C) CO PENNY 1. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under S3301(c) of the Divorce Code was filed on March 29,2005. 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 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. ~ Date 7..- 13 -o-=> PI'i"tiff~7t -K,;, Penny L rice Q c -?' ...,... -otr: rnrr. ~~\:: '!)~- i2C .~~ ('" .~;:. C.J :Pc:: ~ ~ f?, ~ G'"> ~ ~ r\'l~ ~ \\ :::. -=-\ ;; ~ c:P PENNY L. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ; NO. 05-IWtCIVIL TERM DAVID S. PRICE, Defendant 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 MA Y LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LA WYER 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 Bedford Street 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. PENNY L. PRICE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY PENNSYLVANIA v. DAVID S. PRICE, Defendant :CIVIL ACTION-LAW 1(., ;2.7 :NO. 05- CIVIL TERM :IN DIVORCE COMPLAINT FOR DIVORCE The Plaintiff, Penny L. Price, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. ~~ 3301(c) and (d) OF THE DIVORCE CODE 1. Plaintiff is Penny L. Price, who currently resides at 410 North West Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is David S. Price, who currently resides at 45 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on December 31,1996 at Westminster, Carroll County, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff and Defendant have lived separate and apart since August 2004. 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, the Plaintiff requests that the Court enter a decree of divorce, dissolving the marriage. Respectfully Submitted, t7i7' J~ Date: v ?---( jL/) "/ /r/!--l (.- ~'~. "~.. Ul BRENDA COPP Certified Legal Intern 4~ ~~{jj~( '.-tUG\'> ~STON-WALSH Sup~t<-ising Attorney F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 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. 94904, relating to unsworn falsification to authorities. Date J - J? - 0 :J Plaintiff 4;;;; ~ Penny . Pnce 1'-'''' , , c t-.:> ,"'::.:'" 1;;;;' C,..r1 - ~~; 1'",) W c. ::'~f ? -- !~J ~'n .-:\ ~;:'\~\ -~,C) I 'C) l ~1 , -0 c) ':.,1 <',S --<. _I - PENNY L. PRICE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY PENNSYLVANIA v. :CIVIL ACTION-LAW DA VID S. PRICE, Defendant :NO. 05-I('E CIVIL TERM :IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Penny L. Price, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys 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:) ?~11:::)- Respectfully submitted, r /J ... ~ >;- //'11 / I !~~~~P~/E Certified Legal Intern \..-/ ..\' [V? ~ C0 '~j2";2~-{~Vo "- LUay JO~STON- WALSH ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 t'-) i~~ (-~~ .;,-:J'1 --n ~1" ~;;,,''-; :--:-$ r,j t...{.) C. -.! PENNY L. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 CIVIL TERM CERTIFICATION OF SERVICE I, Brenda Coppede, Certified Legal Intern, Family Law Clinic, hereby certify that I have served a true and correct copy of the Complaint for Divorce on David S. Price, residing at 45 Wolfs Bridge Road, Cumberland County, Carlisle, Pennsylvania, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by David S. Price on April 1 ,2005, as evidenced by the attached green card with the article number 70033110000457742235. ;{;;,ci w 724 /~NDA COB E Certified Legal Intern F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ~:,-~ c) --n c.:...n :-I~ ,T1 c:l '~-r;'. \,",) r..f'" c...o U""TCD STATES POSTAL SERVICE .. I II \ First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender' Please print your name, addrE' S, 3n j ZIP+4 in this box' i,d" u /, '/ J ",'J,( ( I~ ,{ ,J! { ii/I,' //' Ii " " 'J/~,,<'/i' I <, J<>;~'_.i;. _;';j l,' ;,...._....,..._".... .'HH,,".'>'~"'.".' 1 PENNY L. PRICE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ; IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 29, 2005. 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 ofthe decree. 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 unsworn falsification to authorities. Defendant ~J.L David S. Price Date 8~8-aC;- (') s:; --- r-' c.:> c...., C;;... :;::P' c:: f~;J (,.., - o 11 :;;l .......'"\" r'.1f.:c:: .:s;C:~ ::~;() ~.., -r-. ..,....... "" .,.-""." ~::,: (~:) ,:~/ii -~ ~).1- .,.'- - t;;) o c...:~' - PENNY L. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301(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 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 unsworn falsification to authorities. Date F)-8 -~ ~l-LcQ, David S. Price, Defendant t-"' () e-::,l -n ~;::.. "(::.: r;.') (,,~.,. -- - PENNY L. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 CIVIL TERM CERTIFICATE OF SERVICE I, Brenda Coppede, hereby certify that on this 31 sl day of August, 2005, I am serving a true and correct copy ofthe Praecipe to Transmit Record and Divorce Information Sheet on David S. Price by first class U.S. mail, addressed as follows: Mr. David Price 45 Wolfs Bridge Road Carlisle, P A 17013 Date: J1:v I cb ,'It Brenda Coppede Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 l~' ..:-;:, ~:j'; o ., :.T;7o c:: C-.l (.." ;r:c'" Si c w PENNY L. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE DAVID S. PRICE, Defendant : NO. 05-1627 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: 1. Ground for divorce: irretrievable breakdown under S 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Apri11, 2005 by U.s. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the plaintiff, July 13,2005; by the defendant, August 8, 2005. 4. Related claims pending: none. 5. Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: August 10,2005. Date defendant's Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: August 31, 2005. Date: f/39(cr) LUCY ON-WA ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 o c- r-:> <-~ C~:') u' :;;~.. (-,:. G'J U) :!::;:: c) -'11 ....j :C-n (11j_._ -ncr~ ;.>~ ':C~l '-"j';.(; 9 o -.J , . ':;(') <,'rn -~.-::?! .....-,~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " . . . . . . . . . iliH- :+; .. . ., . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNY r. PRIC'E, Plaintiff VERSUS DAVID S PRIC'E, Defendant AND NOW, DECREED THAT AND PEN NA. No. DECREE IN DIVORCE Ih,7 2005 ~r, ~ t:rltA. ~S , IT IS ORDERED AND PENNY r.. PRICE DAVID S. PRICE ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLl_OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE Am'~~ . Of. :f.:f. :+: , , . J. PROTHONOTARY .. . . ;f :f. :+.:f.;t; :+;~:+.:+;:+:;+: . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . , . . . , . . . . . , . . . . . . , . , , . . , . . . . . , . . . . . . . . . . . . . . . . . . . . ;l;;t;,.t ~ :2 ~ ~t.e< >C? -~ . 7 ;;;T .J!. ~ ~,) . /'tJ 59 '0 < . , t" i' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Dorll'l'( L PI','c...'e Plaintiff Vs File No.or ~ / (, if '7 IN DIVORCE va vl'd S PII'e-e.. Defendant NOTICE TO RESUME PRIOR SURNAJ\1E Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or ~ after the entry of a Final Decree in Divorce dated 5e pi ~ I'l b a 8 , :; co )- hereby elects to resume the prior surname of }::\)a t\ .s , and gives this written notice avowing his I her intention pursuant to the provisions of 54 P .S. 704. Date:5eet<~b'r ", Joo(., ~O i P"k,A Signature ~~~ Si e of name being resumed cOMMONWE*.TH OF PENNSYLVANIA ) COUNTY OF Ca~ber(tL~J On the Mday o~fkutJtJ2A'"" , 200~, before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and aclmowledged that he I she executed the foregoing for the purpose therein contained. In Witness 'Whereof, I have hereunto set my hand hereunto set my hand and official seal. cJ~no~~~;~J NOTARIAL SEAL CARUSr:=~OTARY, NOTARY PU8tJC MY COMMISS'O=~~URTHousE -UPV1Yof. 2010 X) ;1 C) r--:) c..::Jo (- L:..:::...:.J -- t -j'l -- cr. (.i'? () ~ \) ~ ~ -~.,-", r- (,...I ,Q ~ ~::.:- \'.:; 13 .>..........'~ ~\ IC'~' J, ,,1 ~\ li"~:" :~ ~(' !: o t)~' . ~ '~A ,:":-\:'.~' :~.: : ~ ,.' .......~.~_..""'......,,'O'_...,,_.'<"_...-..:.~~'._... .,~."""....~-Vj>,",.