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HomeMy WebLinkAbout02-1231IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND coUNTy, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff Defendant : : IN DIVORCE Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE BEEN SUED IN COURT. If you wish to defend against the clain~s 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 thc 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 &the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, 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 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 Ee han demandado a usted a la cone. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una aparieneia escrita o en persona o por abogado y arehivar en la corte en forma escrita sus defensas o sus objeeiones a las demandas en contra suya. Se has avisado que si usted no se defienda, la cone tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier que ja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABII,ITIES 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- CIVIL ACTION - LAW IN DIVORCE 1. Plaintiffis Cumberland County, Pennsylvania. 2. Defendant is COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE v/Pcq-t~q.(rA'a ~. ~ or/~, , who currently resides at who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on /~ 0(c4 i~~ [~ ~9c~ at I 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parities. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiffmay have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plaintiff, Pro Se ~ ~] , verify that the statements made in this Complaint are tree and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date Plaintiff Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 h'vine Row Carlisle, Pennsylvania 17013 (717) 243-9400 Patricia A. Judy, Darron G. Judy Plaintiff V. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002- 0 1q--~ [ : CIVIL ACTION - LAW : : IN DIVORCE PETITION TO PROCEED IN FORMA PAUPERIS The Petitioner, Patricia A. Judy, is the Plaintiff in this action. On her behalf, I, Joan Carey, attorney for MidPenn Legal Services, do hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn Legal Services is assisting the Petitioner in filing a divorce case pro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests leave to proceed without payment of fees or costs. /~Care~. RespectfullYMidPenn LY'e~SU'~bmitted: Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 Plaintiff VS. Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERlVl AFFIDAVIT IN SUPPORT OF PETITION FOR I.EAVE TO PROCEED IN FORMA PAUPERIS 1. I am the PI o,'o ~l'~-~ 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: [~ tx) f~J~n'f,~ 57" ~jOT I &) S~i~ S~ufi~ Number: I If you ~e presently employS, state Employer: "T-r Sfl~ or wages ~r mon~: ~ of work: If you ~e pr~enfly unemploy~, state Dam of last employment: /'L)ewr,'lle g~/4 I)zq l Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: g~floqe~ Other self-employment: Interest: t~I ~ Dividends: Pension and annuities: Social Security benefits: dig Support payments: Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(I-Iusband) Name: D'~ If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: O~-e/,'~ I~ .~ 7, o0° c/rl~ Contributions from children: (e) Property owned Cash: ~'[] 0°~ Checking Account: g/ Savings Account: ~' 3 Certificates of Deposit: Real Estate (including home): Motor vehicle: Mak~ Year Cost Stocks; bonds: Other: ~/~ (f) Debts and obligations Mortgage: Loans: Monthly Expenses: 0q ~ O ~' Amount owed (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: ~OO~q Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 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 Pa. C.S. 4904, relating to unsworn falsification to authorities. 6") c:::::, 0 DIVORCE INFORMATION SHEET PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1,2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. ~LEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN 1'O THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: ~,- /,~ ~ / DATE OF MARRIAGE: ~'-. ~-_ Patti_cia A. Judy, Darron G. Judy, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : : NO. 2002-1231 : : CIVIL ACTION - LAW : : IN DIVORCE ACCEPTANCE OF SERVICE I Darron G. Judy, do hereby depose and say that I personally received and accepted service ora true and correct copy of the Complaim in Divorce on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date Patricia A. Judy, Darron G. Judy, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1231 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE I, Tffft'{O'l$ ~. ~ ,~*J , do hereby swear that l have served Darron G. Judy with a Divorce Complaint and Plaintiff's Affidavit under Section 3301(c ) or (d) of the Divorce Code by personally handing him a copy at - /~]¢9CO~rt'tf~ (Str~e~N~mber and Address) /~¢ (Ci~) (S~) (Zip) .yo ~ate) ' '~Mon~) (Y~) in ~is i' ~¢,~q ~ ~'( ,~ ~ , ved~ ~at ~e smmments made (Name of person who performed service) Affidavit of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Signature:~t~C~2r_~o~ ~ ?~/' PATRICIA A. JUDY, Plaintiff Vo DARRON G. JUDY, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 2002-1231 CIVIL · IN DIVORCE _AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on March 12, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. I verify that the statements made in this affidavit are true and correct. I understand that false to unswom fa/~cation to autlhhoeriPt]~a~ties of 18 Pa.C.S.f Secti)~n 4904statements herein are made subject to relating Date:, 'Il!q/r).,'3_ Signature. L. /~ d ~ I I- Pa~ricia A. Judy / :-7 PATRICIA A. JUDY, Plaintiff DARRON G. JUDY, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 2002-1231 CIVIL · IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on March 12, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subjef~to the penalties of~l~8 Pa.C.S. S~ction 4904 relating to unswom falsifica)j,5~ authoriti~. /'~/ Date: o~ ~,P--C/Z Signature: ~~~- _~g~.~ Darron G. Judy v t~ PATRICIA A. JUDY, Plaintiff Vo DARRON G. JUDY, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 2002-1231 CIVIL · IN DIVORCE o WAIVER OF NOTICE OF INTENTION TO ~ U~ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice· I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 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 unswom falsification to authorities· Signature: ¢. Patricia A. Judy PATRICIA A. JUDY, Plaintiff DARRON G. JUDY, Defendant · IN THE COURT OF COMMON PLEAS OF : · CUMBERLAND COUNTY, PENNSYLVANIA : : · NO. 2002-1231 CIVIL : : · IN DIVORCE WAIVER OF NOTICE OF INTENTION TO ~ .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 ifI 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. Date: I verify that 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. Darron G. Judy PATRICIA A. JUDY, Plaintiff V. DARRON G. JUDY, Defendant To The Prothonotary: · NO. 2002-1231 · IN DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL PRAECIPE TO TRANSMIT RECORI) Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Divorce Code· 2. Irretrievable breakdown under Section 3301 (c) of the Date and Manner of service of the Complaint: Defendant personally accepted service of the divorce, by agreement, on March 15, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, July 19, 2002; by Defendant, August 27, 2002. (b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) Date of filing and service of Plaintiff's Affidavit 'upon Defendant: N/A 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 11, 2003. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 11, 2003. Plaintiff's Social Security Number: 192-52-1797 Defendant's Social Security Number: 203-48-1438 Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 iN The cOUrT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF PENNA. PA?Rt-Ct-A A. Jt3~¥ vERSuS JUDY N o. 2002-1231 AND NOW, Decree iN DIVORCE , ~'"~IllT IS OR DER ED AND DECREED THAT PA~TCTA DARRON G. JUDY AND A_ .'I'TTF)¥ , PLAINTiff, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAinS JURISDICTION Of THE FOLLOWING CLAIMS WHICH HAVE BEEN raised of rec.~i~iN this aCTION for WhiCh a Final order has NOT Yet Been ENTERED; ALL CLAIMS HAVE BEEN RESOLVED. ES' ~~--~~~/iROTHONOTA/Y'