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HomeMy WebLinkAbout05-2292 CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE ROBERT COMEFORD Defendant : NO, 05-J)12CIVIL 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 ase may proceed without you and a decree of divorce or annulment may be entered against you b 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 y u, including custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown ofthe m iage, you may request marriage counseling. A list of marriage counselors is available in the Offic 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 GRAN ED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELO THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAW ER. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LE SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, Cumberland County Bar Association 32 Bedford Avenue 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 ith the Americans with Disabilities Act of 1990. For information about accessible facilities a d reasonable accommodations available to disabled individuals having business before the ourt, please contact our office, All arrangements must be made at least 72 hours prior to any h aring or business before the court, You must attend the scheduled conference or hearing, CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE , 4J.- : NO, 05- )JCIVIL TERM ROBERT COMEFORD Defendant COMPLAINT UNDER 23 Pa.C.S. The plaintiff, Claudia Comeford, by her attorneys, the Family Law Clinic, sets forth he following cause of action in divorce: I, Plaintiff is Claudia Comeford, who currently resides at 3 Harvard Place, Apartm nt C, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Robert Comeford, who is believed to be currently residing in Lewi burg, Pennsylvania and whose mailing address is 6B Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania, 3. Plaintiff has been a bona fide resident ofthe Commonwealth for at least six mo ths immediately previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on June 25, 1999 in Carlisle, Cumberlan County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since October 2001. 6, There have been no prior actions of divorce or for annulment between the part es, 7. The marriage is irretrievably broken, 8, Plaintiff has been advised that counseling is available and that Plaintiff or De ndant may have the right to request that the court require the parties to participate in counselin , WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. D"ID~__ i;tdt ~rt;fi~d L~:a~~ntern "21) ~<<Jca5VL THOM S , PLACE ROBERT E, RAINS Supervising Attorney ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorney F AMIL Y LAW 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, t the best of my knowledge, information and belief. I understand making any false statement ould subject me tot he penalties of 18 Pa.C.S, M904, relating to unsworn falsification to autho ities. Date ~ ~I -0 'J ~~~~~ Clau la e ord,/p aintiff -,-, ,..,., ..:;:':) c'? U' :-...:1: :;:i: -~ .;::- ~ C-::\ 1-:23 (nr- T ;~i~~ :. -) ~~'.~ ., .f ::>:j'-n ':{ :2 r c:> ,'",-, .~,J :< CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE : NO, 05-JiJ)cIVIL TERM ROBERT COMEFORD Defendant NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statem nts will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 d OF THE DIVORCE CO E 1. The parties to this action separated October 200 I and have continued to live sep ate 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, la er's fees or expenses if! do not claim them before a divorce is granted, I verify that the statements made in this affidavit are true and correct. false statements herein are made subject to the penalties of 18 Pa,C,S, 94904, relating to nsworn falsification to authorities. Date 5 4 ~DS 0 t-> 0 c:> c,~ =' -"\'1 .:.:,Tl ..-l ...;:..,. :G"""'J :..;.i" -..;: [1lp~ _.:'1.rn \ -;)C? 1;:- '-~) (~) ~,L..:- -" ^)~t~ -'" ,;,_,,)~-n ~.:~ .r-- -":0 \.D :< CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 05-d29.cIVIL TERM ROBERT COMEFORD Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Claudia Comeford, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifie that we believe the party is unable to pay the costs and that we are providing free legal servi e to the party. Date~ Lt ROBE T, INS THOMAS M, PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys ~uJy~ F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ,..., C' ,-=:::;I cJ' I .Ie' C) -n --, I"ll n"IC: -'lc3 ,:.__:~~s ;C) [, ~ -0 .[.- .~~ \.0 CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ROBERT COMEFORD Defendant : NO, 05-2292 CIVIL TERM AFFIDAVIT OF SERVICE I, Brenda Coppede, hereby certify that I am a competent adult and that I served a true and correct copy of Complaint for Divorce on the Defendant, Robert Comeford, at the Family Law Clinic in Carlisle, Pennsylvania by handing him a copy of the complaint. Service was complete upon receipt by Robert Comeford on the l2'h day of May 2005, 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. 9 4904, relating to unsworn falsification to authorities, Date: V:;/12/ Cc) " --, r~ 1 c,_~, CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ROBERT COMEFORD Defendant : NO. 05-2292 CIVIL TERM CERTIFICATE OF SERVICE: I, Rene M, Gornall, hereby certify that on the 3'd day of June, 2005, I served a true and correct copy of the Notice ofIntention to Request Entry of Divorce Decree on Robert Comeford by first class U,S, mail, addressed as follows: Mr. Robert Comeford 7B Glenwood Drive Camp Hill, PA 17011 Date:~ , FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (") ~ ~J;',~ :-:)- u; t::(:-. co. 1~-~: 2. ....; -< r--> <::7) = <J"> '-- c:::: :.;.:;:: o .1 =-' _C" rTl---' r' :gT!:J _<_1(( '3r? -0; -.~ ~)(-::; (5:-;'1 --t ?D .< N (X) 2~ N ("J W CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ROBERT COMEFORD Defendant : NO. 05-2292 CIVIL TERM CERTIFICATE OF SERVICE, I, Rene M. Gornall, hereby certify that on this 28th day of June, 2005, I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet on Robert Comeford by first class U.S. mail, addressed as follows: Mr. Robert Comeford 7B Glenwood Drive Camp Hill, P A 17011 Date: to lZbID~ e . Gornall Certified Legal Int F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 ~: -j -~ '" = = en o ~Yj ..... ::I:-r rn-.J -oS ~~~ f? '7~iC; )~~ ~'+; ,n .~:! j'J .-< N CO -"-" ~,O-.- 1'-' {.'" 1'-.: CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ROBERT COMEFORD Defendant : NO. 05-2292 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following inJormation, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under g3301(d) of the Divorce Code. 2. Date and manner of service ofthe complaint: May 12,2005, by hand delivery at the Family Law Clinic, 45 North Pitt Street, Carlisle, Pennsylvania 17013. 3. Date of execution of the Plaintiffs Affidavit required by g3301(d) of the Divorce Code: May 4,2005; Date of service of the Plaintiffs Affidavit upon Defendant: May 12, 2005. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of S3301(d) Divorce Decree, a copy of which is attached: United States mail, fi t class ostage prepaid on June 3, 2005. Date~ ROB c. RAINS THOMA:S M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 CLAUDIA COMEFORD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ROBERT COMEFORD Defendant : NO. 05-2292 CIVIL TERM NOTICE OF INTENTION TO REOUEST ENTRY OF Ii 330Hd) DIVORCE DECRE~ TO: ROBERT COMEFORD 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 June 13,2005, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary ofthe court an arlswer 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD 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 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 busim:ss before the court, please .-.._'.~~.~... ..." +....m._n..,.. .._-~-_..~ _ ._.--.._-~..~...................... .,......~--~-",.._.._.._---~~..---...._- .... 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. -'.~'-'--'_"'___"H____ -'~~"""'-'. .-.... _.~...,~.__.,--- ,~..".._.___~.._..._. .un'.,<.,."~..~,._-,_......._,~_.",-,-,~.____,,_..__. 0 "'" = ~ f; c"'" en >". :::l 'te, e (".~ iT: i t..:: itiill ~, ;;.;~ - -("Jrq o} N CO i3'i ~,~,::~' -0 ~:i'f! :ii ~~ :z: :~:~fL; ~ Csrn ~.( ::} (,,) ~O w -< - .' . . . . + + + + + . + + + + + + . + + + . + + + + + . + + . + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + . + + . + + + + + + + + + + + . + + + + . + + + + . + + + + + + + . + . . + ++ ~ ~ '+' :+: :+:+ ~++ '+' :+: ++ '+' ++++ + 'f.'f.+ ++ +.+ +.+. +.+ +. +.+.+.+.+.+.+.~ + + IN THE COURT OF COMMON PLEAS : + OF CUMBERLAND COUNTY STATE OF CLAUDIA COMEFORD PLAINTIFF VERSUS ROBERT COME FORD DEFENDANT AND NOW, PEN NA. No. ()~ ??q? DECREE IN DIVORCE J u\ 1 b 7DO~ , IT IS ORDERED AND DECREED THAT CLAUDIA COMEFORD , PLAINTIFF, AND ROBERT COMEFORD , 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 THE COURT: JlI ATTE r J. ~P"O'HONO'A"' ++ +. 'I'+.+:+:++.:+:++'f.+'f. :+; ++ + +. +.++ +'+' ++.++.+.++.+.++. + + + + + + + + + + + + + + + + + + + + . + + + + + . + + + + + + + + . + + + + + + . + . + . . + . + . + + + . . + . + + + . . + . . + . + . + . + + + + + + . + + + ++ <~2~ ~ 5r?/1( . 7;;7 '7 ~~,;7 /'9 Sr?, ) I-c.. . .,..: .. . . .,