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Home My WebLink About01-4000 I ).. . Jp ~qJ'P'" ~IJ, ~,fr? 7'-~W ~ ~ I(;?- b 01 /Cl-?' (/1 ,.. . MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 01- Lfcr:o CIVIL TERM v. WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S COUNTERAFFIDAVIT UNDER ~3301 (Q) OF THE DIVORCE CODE 1. Check either (a) or (b) j~a) I do not oppose entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b) ~a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. '.. I' VERIFICATION I verify that the statements made in this Counteraffidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. 6~: VI-? -~ C:;I d/2 it..11"';" Ii../~ L u: illiam H. Pa mer, III III 0 ~ ":-0 -- . ~~.~ 0 " --r -l=- J~~_' C 00 <(3 (-~-) )... ~ , (' MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-4000 CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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 93301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail on June 29, 2001. 3. Date of execution of the Affidavit required by 93301 (d) of the Divorce Code: June 20, 2001 a. Date of filing and service of the Plaintiffs Affidavit upon the Respondent: June 28, 2001 3. Related claims pending: None. 4. Date and manner of service of the Notice of Intention to file the Praecipe to Transmit the Record, a copy of which is attached: First Class Mail, postage pre-paid on July 26, 2001. n Turo, Esquire ttorney for Plaintiff ., o g; -ot'I._, tpE. ~1~ G:: l.., ~2 z -; -<. CJ if) ,......, --0 -n r:- (::; __-,_._,-,--~,,_'_M_-- - - II MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- if aVO CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : 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 in divorce or annulment may 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 at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 'I MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- l/ovv CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : I N DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Marlene M. Palmer, an adult individual, currently residing at 131 West North Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is William H. Palmer, III, an adult individual, currently residing at 408 North West Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 12. 1981 in Las Vegas, Nevada. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the 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 have lived separate and apart since December 8, 1998 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint or two year separation, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted TURO LAW OFFICES / C;/) 0/01 t~ Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Date VERI FICA TION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. 94904 relating to unsworn falsification to authorities. t.c/d-LID I Dafe I ~A1J 111, rJ'Jtlme1. Ma ene M. Palmer . ,. --. ) 0 i ~ ;) ~ &:: - , <?? ~ ::.:j 8 ~ ~ 4.L ) ~ . MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.01- '/0771.1 CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : I N DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Marlene Palmer, Plaintiff, to proceed in forma pauperis. I, Ron Turo, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's Affidavit showing inability to pay the costs of litigation is attached hereto. c:~o~/ Date Respectfully Submitted Tr;;;;;- Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff '! ! . , MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- iflrl:-(} CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1 . I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. a. Name: Address: Marlene Marie Palmer 131 West North Street Carlisle, Cumberland County, Pennsylvania Social Security Number: 573-94-3269 b. If you are presently employed, state Employer: N/A Address: Salary or wages per month: None Type of work: None If you are presently unemployed, state Date of last employment: August 3. 1999 Salary or wages per month: $2.000.00 per month Type of work: Claims Analvst , I -u-----r- f. er month Loans: None Monthly Expenses: Electric 40.00 Gas 135.00 Water & ewer 45.00 Cable 40.00 Phone 75.00 Food/Clothin 200.00 g. Persons dependent upon you for support Wife/Husband Name: N/A Children, if any: Name: Julia Palmer Name: Catherine Palmer Name: William Palmer. IV Age:16 Age: 18 I Age:19 4. understand that I have a continuing obligation to inform the C urt of improvement in my financial circumstances which would permit me to pay the costs incurred herein. I I 5. 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 P~.C.S. 94904, relating to unsworn falsification to authorities. I 0l;)c)/ c I Dafe I , f7n,.@a rlene M. Palmer, Plaintiff D ~ "> f" ~ co ~ -h 3 q f -; , I I::.. , J MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- </ t"'oV CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE i I I I If you wish to deny any of the statements set forth in this Affidavit, you mut file a Counteraffidavit within twenty (20) days after this Affidavit has been served on ou or the statements will be admitted. I I I NOTICE TO THE DEFENDANT PLAINTIFF'S AFFIDAVIT UNDER ~3301@ OF THE DIVORCE CODE 1 . The parties to this action separated on December 8, 1998 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 concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is grant d. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFI ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS H REIN MADE ARE SUBJECT TO THE PENALTIES OF PA. C.S. S4904 RELATIN TO UNSWORN FALSIFICATION TO AUTHORITIES. (p /~L\I [) I Date ~fJ1:J.P/1lf In t Udorrle1 Marlene M. Palmer (') .. ..1 ex: c o o ~ ~ II , I MARLENE M. PALMER, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANI : NO. 01-4000 CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301 (d) DIVORCE DECREE TO: William H. Palmer, III 408 North West Street Carlisle, PA 17013 You have been sued in an action for divorce. You have failed to answer the Com laint or file a Counter-Affidavit to the 93301 (d) Affidavit. Therefore. on or after August 16, 20 1, 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 ecree in Divorce. A Counter-Affidavit which you may file the Prothonotary of the Court is attach d to this Notice. Unless you have already filed with the Court a written claim for economic relief, yo must do so by the above date or the Court may grant the divorce and you will lose forever the ight to ask for economic relief. The filing of the form Counter-Affidavit along does not protect yo r 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 OFFIC SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 7 h,/o/ Date on Turo, Esquire 8 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff (II F - '" o [.1 ~- G' ~ V'\ ,..J ~ ~ "\ - II , I MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS F : CUMBERLAND COUNTY, PENNSYLV NIA : NO. 01- 1y'i900 CIVIL TERM v. WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S COUNTERAFFIDAVIT UNDER ~3301 <ID OF THE DIVORCE CODE 1. Check either (a) or (b) .X} (a) I do not oppose entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b) (a) I do not wish to make any claims for economic relief. I under tand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divo ce is granted. x:; (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important right. ~ ,'- . I CERTIFICATE OF SERVICE I hereby certify that I served a Notice of Intention to Request Entry of ~3 01 (d) Divorce Decree upon William H. Palmer, III by depositing same in the United Mail, first class, postage pre-paid on the 26th day of July, 2001, from C rlisle, Pennsylvania, addressed as follows: William H. Palmer, III 408 North West Street Carlisle, PA 17013 R 2 South Pitt Street arlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff .( , ) VERI FICA TION I verify that the statements made in this Counteraffidavit are true and corr ct. 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 -,I. William H. Palmer, III o ',_, (./'1 ,,, ~" I( <:l' ~ " , V'o ....j - . :L ) .'" .. .. s MARLENE M. PALMER, Plaintiff : IN THE COURT OF COMMON PLEAS F : CUMBERLAND COUNTY, PENNSYL V NIA v. : NO. 01_L(OO() CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : I N DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the ivorce Complaint, Notice to the Defendant and Plaintiff's Affidavit under Section 3301 (d) iled in the above captioned case upon William H. Palmer, III, by certified mail, return eceipt requested on June 29, 2001 addressed to: William H. Palmer, III 408 North West Street Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office recei t card dated July 6, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFI AVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWL DGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS H REIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES 7)~/ Date ~...."--~' ""' " 1 Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ... 'I ! .. .. . +1)1 VDt CE MmpUi-J)JT Z 452 476 232 us Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See revelSe Senllo I t Postage Certified Fee Special Delivery Fee $ Restricted Delivery Fee L!) 8l Return Receipt Showing to ~ Whom & Date Delivered 5. Return Receipt Showing to Whom, <( Date, & Addressee's Address ci o TOTAL Postage & Fees $ CO CO) Postmark or Date E ~ J wu- zq, ;2D{;) I a.. ('. GI 'C 'iij 0 Complete items 1 and/or 2 for additional services. GI Complete items 3, 4a. and 4b. ~ 0 Print your name and address on the reverse of this form so that we can return this > card to you. l!! 0 Attach this form to the front of the mailpiece. or on the back if space does not GI permit. S 0 Write "Return Receipt Requested" on the mail piece below the article number. C 0 The Return Receipt will show to whom the article was delivered and the date o delivered. 'i 3. Article Addressed to: a; ii E o o .l. SENDER: l^J llLl r1 Yv1 H-. PA-UVlC(;J 1/ 40~ fJO~m juf0T ~nztE r (A-t[U SL t J P,4 no J~ If 11/~~~ 1-- ) 1 /1J1~ 5. Received By: (Print Name) I also wish to receive the follow- ing services (for an extra fee): 4a. Article Number L 45 4b. Service Type o Registered o Express Mail 1l7f1ertified ~sured elum Receipt for Merchandise 0 COD 7. Date of Delivery ~o/ 8. Addressee's Address (Only if requested and fe~ it; pq(d) 102595-99-B-0223 Domestic Return Receipt ai o '~ GI l/) .. D. 'iij o GI a: c .. :s Q; a: CIl c 'iij :s o - :s o >- .It C III .s::. .... ~. ..~ D H ~. 5- . - , ~ -. 9';\ ~ V'I ~ ) II MARLENE M. PALMER, Plaintiff I : IN THE COURT OF COMMON PLEAS bF : CUMBERLAND COUNTY, PENNSYLV,,{NIA v. : NO. 01-4000 CIVIL TERM WILLIAM H. PALMER, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court fo entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under 93301 (d) of the D vorce Code. 2. 2001. I 3. Date of execution of the Affidavit required by 93301 (d) of the Divorce I Code: June 20, 2001 a. Date of filing and service of the Plaintiff's Affidavit up n the Respondent: June 28,2001 3. Related claims pending: None. 4. Date and manner of service of the Notice of Intention to file the Pr ecipe to Transmit the Record, a copy of which is attached: First Class Mail, postage pr -paid on July 26,2001. /' .,,~- Date and manner of service of the complaint: Certified mail on Ju e 29, \"" Ron Turo, Esquire ~~ey for Plaintiff () s_~ ':-:> "'<':,. MARLENE M. PALMER, : Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW WILLIAM H. PALMER, III, Defendant NO. 01-4000 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of September, 2001, upon consideration of Plaintiffs Praecipe to Transmit Record, and the file containing a Defendant's Counteraffidavit seeming to indicate that Defendant does wish to claim economic relief, a divorce decree will not be entered at this time, without prejudice to the parties' rights to clarify the record and file a new praecipe to transmit if appropriate. BY THE COURT, Ron Turo, Esq. 28 S. Pitt Street Carlisle, P A 17013 Attorney for Plaintiff d~1 r William H. Palmer, III 408 North West Street Carlisle, P A 17013 Defendant, Pro Se ~ < :rc t<i\!'//\l),:j\!UJd }'l>\iri:~~':'''''~ :"-~', !-"':':~,~"~{)' . . , "' ,~; S I :,~ ',::' S 1 c! J S i:',~} r,