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Home My WebLink About01-4325 "(.)0 "0 "0 0....0....0....0....0....0..0... 0. 0. 0. 0. 0. 0. "0 0. "0 "0 0. 0. "0 "0 "0 "0 "0 0. "0 0. CO 0. "0 0. "0 "0 "0 "0 "0 "0 "0 "0 "0 0. "0 "0 0. "0 "0 iCi "0 "0 0. CO 0. "0 "0 "0 "0 iCi "0 "0 "0 "0 "0 "0 "0 "0 0. "0 0. 0. "0 "0 "0 "0 CO "0 "0 "0 "0 "0 "0 "0 "0 "0 "0 "0 "0 0. "0 "0 "0 "0 iCi iCi "0 iCi 0. "0 0. "0 0. "0 :0. :0. :0. :0. :0. :0. "0 :0. 0. :0. ~~~~~~ ~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. RHONNDA CLARK No. 01-4325 Plaintiff VERSUS WILLIAM M. CLARK Defendant DECREE IN DIVORCE AND NOW, (~- IT IS ORDERED AND 11 ~, , DECREED THAT Rhonnda Clark , PLAI NTI FF, AND William Clark , 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; Nothing pending. .,,"'/ . /,~ By THE COUR~>'f'/li .~)/. ATTEST' C ~~ . J ( ~PROTHONOTARY if. !f. !f. !f. !f.!f. !f.!f.~!f.!f.!f.if.!f.!f.!f.!f.!f.!f.!f.~!f.~!f. !f.!f.!f.!f.!f.!f.!f.!f.!f.!f.!f.!f.!f.~!f.!f.!f.!f.!f.!f.!f.~!f.!f.~ ~ u . (YJ -t(f'<!'. Of. ) 0'1:" tV -..:>.,t"CY ~f'1(f),ttti PI- )-03)'''. t.U j,,jo;)' ~-;) - 10 Ib 1('131 .II .. . . - . RHONNDA L. CLARK Plaintiff : IN THE COURT OF COMMON : CUIvIBERLAND COUNTY, PENNA vs. NO. 01-4325 CIVIL TERM WILLIAM M. CLARK Defendant CIVIL ACTION-LAW PRAECIPE TO TRANSMIT THE 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 ~ (3301 (c)) of the Divorce Code. 2. Date and manner of service of the complaint: July 27,2001 by first class mail return receipt requested. 3. Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff November 4, 2001; by defendant December 4, 2001. 4. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: Decembe4 4.2001. . Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Date: December 13~ 2001 Jas n P. Kutulakis, Esquire A mey ID No. 77961 8 South Hanover Street Suite 204 Carlisle, PAl 7013 Attorney for Plaintiff o i? (' ~ () vV ~ ':s "J--" , i :< r ' - RHONNDA L. CLARK Plaintiff vs. IN THE COURT OF COMJ\fON PLEAS CUMBERLAND COUNTY, PENNA NO. 01- 4 5.:A.~-CIVIL TElUvf WILLIAJ\f M. CLARI<.: Defendant CIVIL ACTION-LAW NOTICE TO DEFEND AND CLAIMS 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 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, One Courthouse Square, Carlisle, P A. 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 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 Lawyer Referral Service 2 Liberty Street Carlisle, Pennsylvania 17013 (717) 249-3166 RHONNDA L. CLARK Plaintiff IN THE COURT OF COl\fMON PLEAS CUMBERLAND COUNTY, PENNA vs. NO. CIVIL TEMf WILLIAM M. CLARIZ Defendant CIVIL ACTION-LAW NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT You have been named as a Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with ~3302 (c) or (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Cumberland County Courthouse, Cumberland County, Pennsylvania. You're advised that this list is kept as a convenience to you and you're not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to the divorce decree being handed down by the court. 9. The Plaintiff is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree in divorce. Respectfully submitted, Abom & Kutulakis, L.L.P. Date: July 16,2001 J son P. Kutulakis, Esquire ttorney I.D. No. 80411 Suite 204 8 South Hanover Street Carlisle, PAl 7013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, hereby verify that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.CS. ~4904, relating to unsworn falsification to authorities. Date: ~o-.c."""~/",, t (' Oo.~ Rhonnda Clark -- ~ -----_.------~---------- Qf;J[i.l...1 l ~ tOOl O.T inr 1:(.1 '~~ vs. : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNA NO. 0/- 4..1;15 CIVIL TERM RHONNDA L CLARK Plaintiff \VILLIAM M. CLARK Defendant CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I, Jason P. Kutulakis, hereby certify that I served a true and correct copy of the Complaint Under Section 3301(c) of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached receipt card. [attach green receipt card here) Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Date: July 31, 2001 Ja on P. Kutulakis, Esquire A orney J.D. No: 80411 8 S. Hanover Street Carlisle, P A 17013 Attorney for Plaintiff ~. . 0 () c:' C -7 ~ ~~ ""OlL' ~ mn' "J --;;r -).; .:- -....-' I Zc;::: ~) (j) ""-- N -< .~:~ r::::C -1:) :::'-- ~G ~ p~ r::- .. 0 :z: :::J vJ ~ (.,,) '"\:) j SENDER: COMPLETE THIS SECT/ON . 'Complete items 1, 2.. and 3. Also complete item 4 if Restricted Deli\lery is des'red. . 'print your name and address on the reverse ~o that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: LAJ\ Il \ O-.Vl'\ C\a.r ~ \ 13 Hvfe. ~d 136rliY\j ~Vit'\5S) PA 17001 2. Article Number (Copy from service lab~ 70QQ 3J. ~O 000'1 PS Form 3811, July 1999 is 74- Domestic Return Receipt 102595.00-M-0952 A. Received by (Please Print Clearly) W' 1\ ~,,~ (Y'- c l~\<-- C. Signature .r. n X L~ f"-'C~- ') ~ Agent o Addressee D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No '<--.\ 3. 4. UNITED STATES POSTAL SERVIC~/ /.~.l / ' \ ! I I .....-..,... First-Class~~ Postage & Fees p~MI..~- .uSPS ' - Permit No. G-10 , .. · Sender: Please print your ~me, address, and ZIP+4 in this box · Ai-~ Sll\ k ::WLf <6 ~. \-\c..I'IO Vex- 51. Co.r\~'6k f'A \/013 RHONNDA L. CLARK Plaintiff : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNA vs. NO. 01-4325 CIVIL TERM WILLIAM M. CLARK Defendant CIVIL ACTION - LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301 (c) of the Divorce Code was ftled on July 17,2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of ftling 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. ~4904 relating to unsworn falsification to authorities. Date: ~ (\~~~ Rhonnda L. Clark ~ " ~ -. (A: .. RHONNDA L. CLARK Plaintiff : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNA vs. NO. 01-4325 CIVIL TERM WILLIAM M. CLARK Defendant CIVIL ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on July 17, 2001. 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. 54904 relating to unsworn falsification to authorities. Date: '-i ~<- . l' I l~~- ~ William M. Clark o d A- (, ~ o ~ ~ ') :-, .-j c. I , ..:... RHONNDA L. CLARK Plaintiff : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNA vs. NO. 01-4325 CIVIL TERM WILLIAM M. CLARIZ Defendant CIVIL ACTION-LA\X! 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: ,.,.. L.\ - 0 I f\~ '" ~ Rhonnda L. Clark :--:1 ~. " >.J..-' .... , RHONNDA L. CLARK Plaintiff : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENNA vs. NO. 01-4325 CIVIL TERM WILLIAM M. CLARK Defendant CIVIL ACTION-LA \x/ 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 alitnony, 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.eS. ~ 4904 relating to unsworn falsification to authorities. Date: LJ "D e. c... 0/ I ~t'--. C~ \Villiam M. Clark 0 .- c> 0- (, ..+: ~ '- ..- ";7" ~ .l> .~ I.. -...., ( .l) RHONNDA CLARK, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA : NoD' -l{:So.')Civil Term WILLIAM M. CLARK, : CIVIL ACTION DefendantJRespondent : V. PLAINITIFF'S PETITION FOR RELIEF 1. Plaintiff/Petitioner is Rhonnda Clark, of 32 Montesera Road, Carlisle, Cumberland County, Pa., 17013. 2. DefendantJRespondent is William M. Clark, of 113 Hope Drive, Boiling Springs, Cumberland County, Pa., 17007. 3. Plaintiff and Defendant were married on August 16, 1986. 4. During the course of the marriage, the parties acquired a home, located at 113 Hope Drive, Boiling Springs, Cumberland County, Pa. 17007. 5. The parties were divorced on December 17,2001. 6. During the divorce, the parties did not enter into a marriage settlement agreement which provided for a disposition of the marital home, and the deed to the home and the loan obligation is still in joint names. 7. Plaintiff has been requesting that Defendant assist in obtaining an appraisal of the home since August 2005. 8. Defendant has not offered to cooperate with an appraisal ofthe home. 9. The parties have been unable to agree on the terms for an orderly distribution and partition of the home. WHEREFORE, Plaintiff requests that this Honorable Court enter an Order providing that the home be appraised and that Plaintiff receive payment for her portion of the equity in the home, as well as any other such relief as the Court may deem appropriate. Respectfully submitted, o.re 1(:0(0 i- Ian Adams, Esquire I.D No. 79465 6 South Pitt St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I veritY 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. 94904 relating to unsworn falsification to authorities. Date: /. i'l-/)G {J\ b"""-""'&,;" 'J- C~L_ Rhonnda L. Clark, Plaintiff C) c; <',; -.., .-' , "-> ~.":;'J C-';;;:' ~::J"" o -') '- ::'.''''' :z G) ::;:J hiJJ r-- :-nQ:1 u<.;:J i::! (:) -"'-'-T, j ::::L3 .C. .)rn ;:J :~CJ -< -0 :A: (f'j a