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Home My WebLink About05-5750 MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05- ~1 S6 CIVIL 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 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 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, Pennsylvania 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. MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05- S'750 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Mark A. Ammons, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER TITLE 23 Pa.C.S., !'l!'l330I(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mark Ammons, who currently resides at 207 Clay Street, Apartment 5, West Fairview, Cumberland County, P A, 17025, since approximately August of 1991. 2. Defendant is Marsha Ammons, who currently resides at 5 Albert Lane, Apartment 12, Dillsburg, York County, P A, 17019, since July 9,2005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing ofthis complaint. 4. Plaintiff and Defendant were married on January 15, 1998, at Wellsville, York County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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 respectfully requests the court to enter a decree of divorce. /I / t.{ I {J!,~ ~-J!~ Robert Lascher Certified Legal Intern F AMIL Y LAW 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. s4904, relating to unsworn falsification to authorities. Plaintiff~L 0-" GL.....,Vl/"..;" Mark A. Ammons Date I 0 - _~ 1- 0 S w- !-f -v ? "', C,:":) :::::? c...l'l o -n ~"1"1 rn~.- .",Fn ",9 '~Z:G~ ~-1?~1 :~ :r.- ;1J -< ~. ~ C,."'I -<:: , .l'" :!:'!'. N C.Il MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY MARSHA AMMONS Defendant : NO. 05-S'1t6 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Mark Ammons, 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 )I / 4/0~ ~Y-ch-~ Robert Lascher Certified Legal Intern ~,[Luft ROB . RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C) c; .;: .-' = ,= <:..n f' , c:' ...:;: \'. I r- ~ :r."fl rl1r --)m -by ~)>C) :: ~y, , ~'l'i I,~;~ ~::J .,~ :::.;.. -,'" ,,> U1 '-"""," <":0 '< MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05-5750 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the Complaint in the above-captioned case filed in the Cumberland County Court on November 4,2005. I) J J /05" UJ ')! ~<-- Robert K. Lascher Certified Legal Intern Date: eLC)' STON-WALSH ROB E. RAINS THOMAS PLACE ANNE MACDONALD-FOX Counsel for Plaintiff Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 C~J r--;J MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05-5750 CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint filed in the above captioned action on November 4,2005 and reinstated on December 2,2005. Date I ~/,;tl Dc I C'frLullJA^-- 7Jt. GmmtOl14 Marsha A. Ammons t~l MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05-5750 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under 99 3301(c) of the Divorce Code was filed on November 4,2005. 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: J\o..", Co\.. 1J 0 b ~ aP.L.~ Mark Ammons, Plaintiff MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05- 5750 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !;!;3301(c) of the Divorce Code was filed on November 4,2005. 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. !;4904, relating to unsworn falsification to authorities. Date:~ /fh/Aia ~~ Marsha Ammons, Defendant MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05- 5750 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST 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 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. g4904 relating to unsworn falsification to authorities. Date: 1\ "-"'''- "" '1, 0(, . /%.L~~.~ Mark Ammons, Plaintiff MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARSHA AMMONS, Defendant : NO. 05- 5750 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST 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. 94904 relating to unsworn falsification to authorities. Date: 7l1a1.z 1. ~ 2006 / fh>>ma/J~ &;;~ Marsha Ammons, Defendant MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW : DIVORCE MARSHA AMMONS, Defendant : NO. 05 - 5750 CIVIL TERM CERTIFICATE OF SERVICE I, Robert Lascher, Certified Legal Intern, Family Law Clinic, hereby certify that I served time-stamped copies of the Plaintiffs Affidavit of Consent, the Defendant's Affidavit of Consent, the Plaintiffs Waiver of Notice, the Defendant's Waiver of Notice, the Divorce Information Sheet, and the Praecipe to Transmit Record on Marsha Ammons, residing at 5 Albert Lane, Apt. 12, Dillsburg, P A 17019, by depositing the same in the United States mail, first class, postage prepaid. Service was complete upon mailing on the 14th day of March, 2006. ,;t;ter ~Gv.../ Robert Lasche~ Ce~i~?"tL~1 Inter .. ~~ Thomas M. Place Robert E. Rains Lucy J ohnston- Walsh Anne MacDonald-Fox William G. Martin Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 "" ,'~'::::) ;;:;:J ...:.r, :l: ~t:; (J "11 '-1 ~ nip] n"j ~ ;ri :1". I..} -.l " l:"<' ::;>;: C:J f"-: ------ ~ MARK AMMONS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW : DIVORCE MARSHA AMMONS, Defendant : No. 05- 5750 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: I. Ground for divorce: irretrievable breakdown under S330 I (c) of the Divorce Code. 2. Date and manner of service of the complaint: Defendant was sent a certified copy of the reinstated complaint and an Acceptance of Service document through first-class United States Mail on December 2, 2005. Defendant executed the Acceptance of Service document on December 5, 2005. The Acceptance of Service document was filed with the Prothonotary on December 7, 2005. 3. Date of execution of the affidavit of consent required by S3301 (c) of the Divorce Code: by Plaintiff- March 9, 2006; by Defendant- March 9, 2006. 4. Related claims pending: none. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: March 13,2006. Date Defendant's Waiver of Notice was filed with the Prothonotary: March 13, 2006. 3/1'1/00 Date ~~ Robert Lascher Certified Legal Intern t1-~J '-'LUC& 0 STON-WALSH ANNE MACDONALD-FOX ROBERT E. RAINS THOMAS M. PLACE WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC Counsel for Plaintiff / 45 N. Pitt Street Carlisle, P A 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff ;t,'+';t,;t,;t, . . . . . . . . . . . + . . . . . . + + + + + + + + + + + " " . + + + . + + + + + + + + + + . .+ n .+ + + . .+ :+.:+::+::+: + ;t,:ti:+::+: +n +''+'+':+::+: :+::+::+::+:;t,:+::+::+:+,;t,:+:+,;t,+,:+: +;t,;t, +;+: + IN THE COURT OF COMMON ++ " + + + + + + + + + + + + + + + + + + + + + + + . + + + . + + + + + + + + + + + . + + + + + + + + + . + + + + + . + + + . + + . + + + . + + + . + + . , , , + + + + , + + + + + + + + + + + + + + + + + 'f 'f '+' 'f;+: + + +' '+' "f + "f +' '+' 'f;+: "f + + + + '+' + +' Of ++. OFCUMBERLANDCOUNTY STATE OF MaRK AMMONS. Pl~intiff VERSUS MaRSHa AMMONS. npfpnn~nt AND NOW, DECREED THAT AND No. DECREE IN DIVORCE c?a...; Id' MARK AMMONS MARSHA AMMONS ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA. ~7~O PLEAS ?nn~ , zgo(, _, IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT n NONR By THE C URT: + + + + + + + + + , + + , + + + + . + + + + + + + + + + + + + + + + + + , + + + + + + , + + + + + + + , + + ~+'Of+''+'Of'+'Of++:+'+OfOf'f+'OfOfOf ~ /l f~ :f. +' Of +' Of:'f. Of 'to: + '+:;f Of +';f Of +.+ ;f Of Of Of Of + PROTHONOTARY ++ + + + J. ,~'7:7. ')r, J... ~ /' 7/ '1,7' 5 -e '/1 , . L." ."7 ~h.?f".,.,.y .';>7!p// )iT"/" p r ';:;1/1" vh -/'/ 7j :z./iT'f7'1/ w<ill /,9 . . ,