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Home My WebLink About02-1624BEVERLY M. TRAINUM, Plaintiff ROBERT G. TRAINUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. O.~ ~ I/~-2 ~ CIVIL TERM : IN DIVORCE NOTICE 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 ease may proceed without you and a decree in 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, Carlisle, Pennsylvania 17013. 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 HE~LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 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. BEVERLY M. TRAINUM, Plaintiff Ve ROBERT G. TRAINUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. ~5 ;~ -. I/~,~t CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(e) or O.~.F THE DIVORCE CODE NOW comes the Plaintiff, Beverly M. Trainum, by her attorney, Mark D. Schwartz, Esquire, and files this Complaint in Divorce against the Defendant, Robert G. Trainum, representing as follows: 1. The Plaintiff is Beverly M. Trainum, an adult individual residing at 538 Second Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Robert G. Trainum, an adult individual residing at 705 Westover Drive, Staunton, Virginia 24401. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on June 6, 1987. 5. There are three (3) children bom to this marriage; namely Kimberly G. Trainum, bom 12/18/90, age 11 years; Robert Grain Trainum, II, bom 7/18/93, age 8 years; and Kathryn R. Trainum, bom 3/3/97, age 5 years. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Pursuant to the Divorce Code, Section 3301(c), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. Pursuant to the Divorce Code, Section 3301(d), the Plaintiff avers as the grounds for divorce that Plaintiff and Defendant have lived separate and apart since January, 2000. 9. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the fight to request that the court require the parties to participate in counseling. WI~REFORE, the Plaintiff demands judgment dissolving the marriage between the two parties. Date: April 29, 2002 Respectfully submitted, By: ~ Schwartz, Esquire Attorney for Plaintiff West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I.D. No. 70216 VERIFICATION The foregoing Complaint in Divorce is based upon infoaniation which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. BEVERLY M. TRAINUM Date: April 29, 2002 BEVERLY M. TRAINUM, Plaintiff ROBERT G. TRAINUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. CIVIL TERM : : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: April 29, 2002 CERTIFICATE OF SERVICE I the undersigned hereby certify that on this 3rd day of April, 2002, a copy of the foregoing document was served by United States mail, certified, restricted delivery in Carlisle, Pennsylvania upon the following: Robert G. Trainum 705 Westover Drive Staunton, VA 24401 IRWIN,~KN(J~T & HUGHES BEVERLY M. TRAINUM, : IN IHE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA .. v. : CIVIL ACTION - LAW : : NO. 02-1624 CIVIL TERM ROBERT G. TRAINUM, : Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIDA VIT COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF C[]aS]~Ta'q]) : NOW, Rebecca R. Hughes, Esquire, being duly sworn according to law, does depose and state: 1. That she is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a copy of the Notice of Intention to Request Entry of Divorce Decree and Counter-Affidavit were served upon the defendant on June 12, 2002, by certified mail, addressed to him at 705 Westover Drive, Staunton, Virginia 24401, with Return Receipt Numbe~ 7000 1530 0002 4693 5298. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities Date: June 20, 2002 t~ Rebecca R. Hughes, Esquire / -/~ Attorney for Plaintiff ~ ~ · ~omplete Items 1, 2, end 3. Also comptete Item 4 ff Reetr~cl Dellve~ i~ desired. · Pdnt yOUr r~h~'ar~l address on the reverse so that we can return the card to you. · Attach this card to the back of the mailplece, or o~ the f~ont ff space permits. Robert G..~raimm 705 ~er Dr~ve St:aunt:on, V/~ 2~01 C. Signature B. Date of Dell,~m/ i~ Regist~l I~ Return Rec~pt fo~ r'l fne~red Mall [] C.O.D. 4. Re~,tcted Delivery? (Ex~ Fee) [] A Here U~ ~Sent To l .......... bert G. I'ratnum r~ Ro c3 S~ree .... :~.'~':~-/~: ....................................................... ~ [ ~etover Drive r,- ~'~'~ s~,, z~P+ 4 "=- ..................................................... ~C3 c:~ C3 BEVERLY M. TRAINUM, Plaintiff ROBERT G. TRAINUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : : NO. 02-1624 CIVIL TERM : : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about January 2000, 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 divome is granted. 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. of 4904 relating to unsworn falsification to authorities. Date: BEVERLY M. TRAINUM, Plaintiff ROBERT G. TRAINUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : : NO. 02-1624 CIVIL TERM : : 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 Section 3301(d) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Robert G. Trainum on April 6, 2002 by certified, restricted delivery mail, addressed to him at 705 Westover Drive, Staunton, Virginia 24401, with Return Receipt Number 7001 2510 0009 2828 4982. 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: (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: May 20, 2002. (b)(2) Date of filing and service of the plaintilTs affidavit upon the defendant: Jtme 12, 2002. 4. Related claims pending: NONE. 5. Complete either (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: Certified mail, return receipt requested served on June 12, 2002 (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date: June 20, 2002 Attorney for Plaintiff I} ComlY~e Ite~n~ 1, 2, and 3. A~o com~ item 4 if Reatrlcted Delivery i~ de,md. · Print YOUr name and acldme~ ~ ~he reveme Attach thl~ cjln:l to the ba¢~ Of lhe m~l~, Roberz C. Tra~lum 705 Mestover Dr$ve Stamlton, VA 2&401 A. Reoe~ ~y ~'~e Prat C~e~.yy) = dlff~rer~ fl~t~ It~ 17 r'l~ [] ~--=~- ~,, ~r,~ ~.~0 7001 Ps Form 3811, March 2001 [] C.O.D. 2510 0009 2828 4982 C=~ 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF BEVERLY M. TRAINUM, Plaintiff VERSUS ROBERT G. TRAINUM, Defendant PENNA. NO. 02-1624 DECree iN Divorce AND NOW ,~/~, itl ~ S ORDERED AND DECREED THAT everly . Trainum , PLAINTIFF, AND Robert G. Trainum , 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. ~PROTHONOTARY