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HomeMy WebLinkAbout05-1677 JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN GUST~ .f.\vof.. c e.. : NO. 05-/t 77 CIVIL TERM MAITLAND A. C. SPARROW, 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, LA WYER'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 HAVE A 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 A LAWYER, THIS OFFICE MA Y BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 Bedford Avenue 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. ... JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY . '7 ; NO. 05- 101 CIVIL TERM MAITLANDA. C. SPARROW, Defendant COMPLAINT FOR DIVORCE The Plaintiff, Joanne Sparrow, by her attorneys, the Family Law Clinic, sets forth the following cause of action: DIVORCE UNDER 23 Pa.C.S. ~~ 3301(c) & Cd) OF THE DIVORCE CODE 1. Plaintiff is Joanne Sparrow, who currently resides at 103 East High Street, Apartment 1, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Maitland Sparrow, who currently resides at 428 Spring Run Drive, McConnellsburg, Fulton County, Pennsylvania. 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 February 3, 2003 in Enola, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since September 2004. 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~ LACE ROBER E. RAINS Supervising Attorney ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorney F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 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 tot he penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. Date j /30/ 6S- Jo t\\ '" ~ ~ ~ \N ~ ~ ~ (') ~.'~ r-" ~ ~f' .....;." ..;.- .t ...~~, ~..:J (....) C) o .,,) ....("... ,. ' .....:.:... r:~? G (....:J - .........-- JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-/& 7) CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Joanne Sparrow, 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. Respectfully submitted, Date ~12>O I O~ 74i~ ROB / . THOMA M. PLACE ~. ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 ,.-- ~, ' Q :. f'--:> <:::> o '-n --I ;.fi~ CJ \ r~) (~. c..rl -'- ::::; (.Ai o ,) c. r~,~ - JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PE LEAS OF SYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-1677 CIVIL TE CERTIFICATE OF SERVICE I, Rene M. Gornall, hereby certify that I served a true and correc copy of the Complaint for Divorce on Maitland Sparrow, at 428 Spring Run Drive, cConnellsburg, PA 17233, by depositing a copy of the same in the United Stales mail, c rtified, restricted deliyery, return receipt requested on March 30, 2005. Service was com lete upon receipt by Maitland Sparrow on April 2, 2005, as evidenced by the attac ed green card. , Date: Lj 119 105 c?~/ , . 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. 1. Article Addressed to: Agent o Addressee D. Is delivery address different from it m 1? 0 Yes If YES, enter delivery address bel w: 0 No f!7o..dJ. C, 'l<.l $p LU)/~./.LJ i/;}, 3 S p1-~ ;?'WJ t0~ /J1 (' (' c.rrurJ.titld.LI../'jJ /'11/ 7 J.-. 5 3 3. Service Type 'j23 CertJfJed Mail --s Registered o Insured Mail o Express ai! JZt=Aeturn R eipt for Merchandise DC,O,D, 4. Restricted Delivery? (Extra Fee) es 2. Article Number (Copy from service label) ~c.D"' 0 oc/oil S-77 PS Form 3811, July 1999 Domestic Return Receipt 102595.99.M-1,'89 --r..l \~~,; r-nti! -~~~':-. -.',. ~~;~. "~:\~~ ~l ....... o <:;; ,..., = ~ ~ :;0 1 0' -n o -r1 .-1 ::c."'1 fb--' r:;'l -()~ ~J) "-(' :~~~ (') :;~,., ",' 1 -:-"1'; \~;, ~:->. ':'~ J;. -;<; -,,' -- o - JOANNE S. SPARROW, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-1677 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under SS 3301(c) and 3301(d) of the Divorce Code was filed on March 30, 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 and 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. S 4904, relating to unsworn falsification to authorities. Datefl+ J ~ j6o) J .:;:;; \- t~t '~i: ;l:~, ;}"<;; :.::\ ./- --0 ::G q, ~~ -0 'i3 -0, '1:)0 ..-~~ ---c~ (?~,,), ~:-~,. , 1:2, ''P' :a. Q '::.0 ~.1 "'" cJ' ~ G? ~iq< f'l l,'.; -- -- '-P. <.f' c:P JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05- I 677 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under ~~3301(c) and 3301(d) of the Divorce Code was filed on March 30, 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 and intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statemenls herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsificalion 10 authorilies. Date 1r~J- '?:? C k~' Maitland A. C. parrow, Defendant 0. ~, ..........\:'; ,-Y,;\ -:::?,\ ~~t':,' ~ ~;',-'"_. ~J.;25:~,~ v(~ . 7- -2. r:' ~ ~ A ~ ':J::,,-:Q: "P." ('~ e;, ~ -0;0 :91-) --- c:>\~, ..". ~--t) ")'l'> .--c ..t'i-f\ .,..,,;> 17"'".... ~y ~ '3- <-? $ - JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-1677 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand thaI 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 of the decree will be sent to me immediately after it is filed with the prolhonotary. 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. 0", ~Cf J,?, ,;; We .--' (1b ;&, ~ ,-;') q, .-'...,., :!'~ e (\ r\\ :?)CI -- ?-?~ (~l -- :';;'.~.J ,,, S~ ::i;: <:5- ..4 '7 ":-0 :4 <-.J .. ~f\ ...0 - JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-1677 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 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 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-- O,\'" " ~~;-;;:;:? #~..-/.c-. Maitland A. C. Sparrow, Defendant --- o c. ~. ..~\ (' '~~':\~'o <0,.;;': ~ ~ ~ ? G~ ...... ...... ()\-', .s~_\..~ 'jf~~~~~~ ' ''';;>' ',./- Q, ~~ -:'{,''') 'Ob .....}:;', ~~ '0 :;;A ~ ::z. ~ c.? ~ - ," JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-1677 CIVIL TERM CERTIFICATE OF SERVICE I, Rene M. Gornall, hereby certify that on this II th day of August, 2005, I am serving a true and correct copy ofthe following on Maitland A. C. Sparrow: Defendant's Waiver of Notice ofIntention to Request Entry of a Divorce Decree Under S3301(c) of the Divorce Code; Defendant's Affidavit of Consent; Plaintiffs Waiver of Notice ofIntention to Request Entry of a Divorce Decree Under S3301(c) of the Divorce Code; Plaintiffs Affidavit of Consent; Praecipe to Transmit Record; and Divorce Information Sheet Service was accomplished by first class U.S. mail, addressed as follows: Mr. Maitland Sparrow Dauphin County Prison SOl Mall Road Harrisburg, PA 17111 Date:~ p FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 ,...> c::;.') '3\ p c:: ,,-) ~-- .- o -n ::?:;:l f\1 r:: -:gfd ('''11- :~~'-t\ ~-L-n t~\.~ "::-rn -~~ <;:) ::< - -:.) ~.::;: r;: o o - JOANNE S. SPARROW, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY MAITLAND A. C. SPARROW, Defendant : NO. 05-1677 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: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April2, 2005, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution ofthe Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, July 22, 2005; by Defendant, August 8, 2005. 4. Related claims pending: none. 5. Date Plaintiffs Waiver of Notice in !}3301(c) Divorce was filed with the Prothonotary: August II, 2005. Date Defendant's Waiver of Notice in !}3301(c) Divorce was filed with the Prothonotary: August 11, 2005. Date p') I11I 0 S I ~,(' ' , fr ~ C)rhk.J!i RO U. RAINS MAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON- WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 ..------ ~ <b <P ?:. c':', " -- -- ""J \.,~"- , , ':;:.i'"~ :L ~ ~~ P'~ 1'~~~.; , ~:f\ ""'1 ''''''''""} \?, S" ~ /"'\ ....';~ "(:?\ -S ~~ '6 - :f.;+;:+::+::t< . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . <. <f , , . . . . , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C+;+;:+;'f .. H. """",.,:+::f. :+: . . :+: :+: :+: :+:'f. l' :+i'f.;+;1'+' . ;+; l' =+:4''':+: C+ ~+. . . . ... IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. JOANNE S. SPARROW No. 05 Hi77 PLAINTIFF VERSUS MAITLAND A. C. SPARROW DEFENDANT DECREE IN AND NOW, DIVORCE Av<f- I~ ""'lAP j~ , IT IS ORDERED AND DECREED THAT , PLAINTIFF, ,10IlNNR c: .~PARRnW AND MAITLAND A. C. SPARROW , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAtSED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE. By TH PROTHONOTARY . .. :+: l' '+O:f. 'f. 'f l' 1';tO:+: :f' l' "f.:f' 'f + +. 'to l' :+;1':+:'" :+;+ :+; :+;:f.'f'f'f '+.1':+':+:1' if . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . +''f1'''f.+' -~? ~ .~~ Yc;?.-J'('~ . 7 :::;T .$ "?J' ....:v ~p/ ~..-5V -5(;'..!> ~ ~, . -- .' , . :... t'.;.