HomeMy WebLinkAbout06-3539
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(b) PLAINTIFF'S ATTORNEYS (ADDRESS)
DEFENDANT'S ATTORNEY'S (IF KNOWN) (ADDRESS)
{-
form 13 · 205
COUNTY COURT OF COMMON PLEAS
CML COVER SHEET
Docket No. 0(.. 3:;{ 3 'l'
He.})
DEFENDANTS
L.M t'cha,e,L
J.
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II. MANDATORY ARBITRATION
Does this fall under the mandatory arbitration
requirements per Local Rule 1301?
Yes or@
III. ALTERNATE DISPUTE RESOI.lJTION REOUKHED
Summary Jury Trial
Other: See "Guide to Alternate Dispute
N/ A Resolution PtogtaffiS" Published by the
County Bar Association
IV: CAUSECS) OF ACTION (Cite the statutes or rules of law under which you are filing and write a brief statement of causes(s).)
Divorce Code ~ 3301 (c) or (d)
(a) Is this an equity case? Yes or No
VI. ORIGIN (Matk only I)
X- 1 Original 2 Removed from
Complaint Federal Court
of Writ
V. GENERAL NATURE OF SUIT
CONTRACT
Insurance
PA Bond
Collection Suits
Construction
Other - List in
N above
REAL PROPERTY
Condemnation
Foreclosure
Landlord & Tenant
Partition
Mechanics' Lien
EnVironment
Other-List
in IV above
_ Address of Property
(Place an X in one area only that most accurately describes your case)
PERSONAl. INJURY
Motor Vehicle
_ Product Liability
_ Medical Malpractice
_ Other Prof. Liability
Intentional
Premises
Other - List in
IV above
DOMESTIC RELATIONS
~ Divorce
Protecrion from Abuse
_ Custody/Visitation
Other - List in IV above
_ Support
OTHER STATUTES
_ Zoning Appeal
_ School Boatd Appeal
_ License Suspension Appeal
_ Assessment Appeal
Other - List in IV above
PRISONER PETITIONS
_ Habeas Corpus
Mandamus
Other - List in
IV above
TAX LIEN &
TAX MATTERS
OTHER
List in IV above
_ LABOR
(b) Does it involve a governmental body? Yes or No
3 Confessed
Judgments by
Complaint
or Praecipe
4 Transferred
From Another
_ 5 Appeal
From
_6 Appeal to _ 7 Foreign
Court from Judgment
District or Govt.
County (specifY) Agency
District
Justice
Judgment
VII. REOUESTED IN COMPLAINT N/ A
(a) Is this a CLASS ACTION YES Ot NO
(b) Circle YES only if jury demanded in complaint:
JURY DEMAND: YES Ot NO
Will you accept 6 jurors? YES or NO
VIII. RELATED CASEIS) IF ANY
(c) Amount demanded in complaint
DOCKET NUMBER
Case Ca tion
(p
DATE
.2/. () Ce
JUDGE
G PARTY OR ATTORNEY OF RECORD
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form 3 · 183
};ehDUI'Jf L. FuW
( IN THE COURT OF COMMON PLEAS OF
: ~iJe,yllP7e;L COUNTY, PENNSYLVANIA
(
( CIVIL DIVISION
(
(NO: 0(.. 353q ~ -r;:..
PLAINTIFF,
v.
-
l/YIicIruJ- .J. rlPLP
DEFENDANT.
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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]UDGMENT
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
CHILD(REN).
WHEN THE GROUND FOR THE DIVORCE ARE 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
, PENNSYLVANIA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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.
/J LAWYERS RE~RRAL SERVICE
C./Unher/~dUun*1.. ~ As~6Cia-fl~n.
.3~ S. iuI-/in;i... SI-. [};..y luk PI'/- /70/3
Telephone: 7/7. '2-4q,~ /~u..
~ n
Address: lIlt L-u A-rtt'\. l;O~
~c)IA- vA- 170Z,iS
Telephone: 717. 7Za. 5'5'sq
.
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form 4 · 185
( IN THE COURT OF COMMON PLEAS OF
PLAINTIFF,
: ~l4nIkr/ ~d-
COUNTY, PENNSYLVANIA
v.
( CIVIL DIVISION
lA1i CMel- .j.
-
r(;ltJ)
(NO: 0(,. 3S3Q ~ l.a.,.....
DEFENDANT.
COMPLAINT IN DIVORCE
AND NOW COMES, the petitione~OeRlf L. He/>
who files this Complaint in Divorce a statement of which is as follow:
1-. n
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, by FlUNG PRO SE,
1.
, an adult individual currently residing at
'11- 17 P'2..6 .
2.
3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months
previous to the filing of this Complaint.
4. The Petitioner and Respondent were married on date: ~. I t..f. 9 e. in the State of P A-
5. . There (is) are 2. child(ren) born of this marriage~ Name(s) ~'~J,.. l/f1U"~ ~:
(JJ;ndle ~~ h4> Birthdate(s): /;2. 1/ q~ > '?:./~ 03
6. Neither party is a member of any branch of military.
7. The marriage is irretrievably broken.
8.
If- L. n~
, respectfully requests this Honorable Court
the altern ti ection 330 I (d) of the Divorce Code.
The Petitioner,
to a grant this Divorce pursuant to Section 3301 (c)
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Full Address: J1lt La. l4nn c~
mitt. PA- t'10z.?
,n.7U>.E5''S15Q
Telephone:
I verifY that the statements made in the Complaint are true and correct. I understand that false statements made
herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities.
Dated: fD .;2/ . oCR.
<~ "i
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.
form 5 · 187
']:k~etHf L. 'Fot-i>
( IN THE COURT OF COMMON PLEAS OF
PLAINTIFF,
:LL,,~/AA7t1.- COUNTY, PENNSYLVANIA
v.
( CIVIL DIVISION
V11; chuJ-. J. F(JI'J!)
(NO:
DEFENDANT.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
)
COUNTY OF: ~beY/ant:?t-
) ss:
)
Before me, e subscriber, a Notary Pu!ilif. in and for said Commonwealth and Counry, per-
sonally appeared b, /..-. 1-0. , who being duly sworn
according ro law, deposes and says that rhe facts contained within the foregoing Complaint in Divorce
are true and correct ro the besr of his/her knowledge, informarion, and belief, and that he/she is
authorized to make this Affidavit.
Sworn ro and subscribed before me this
.) / day of i)./...u...-. ,2ooL.
;(vtJ 57 ;g.
,
ONWEALTH OF PENNSYLVANIA
Notarial Seal
Robert J. Reese, Notary Public
Silver Spring 1\vp., Cumberland County
My Commissioo Expu.. Aug. 10, 2008
_,~4-,'-.aI_
..
NOTARY PUBLIC
.
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form 6. 189
COUNTY COURT OF COMMON PLEAS
INTAKE
THIS FORM MUST BE FILLED OUT IF YOU ARE FILING A DIVORCE OR CUSTODY
ACTION IN THE PROTHONOTARY'S OFFICE:
TODAY'S DATE:
t. 81. O~
CASE NUMBER:
0(, - 3~'3r
PLEASE CHECK ONE:
o DIVORCE FILING-NO CHILDREN:
~ DIVORCE FILING-W/CHILDREN UNDER 18:
o CUSTODY FILING-W/CHILDREN UNDER 18:
PLAINTIFF/PETITIONER NAME AND ADDRESS:
:JJehDUl-H- t.... Hf2,;)
II ft La /h111 CdkCi
<Eng I A PII- 17bJ..,?
I
DEFENDANT/RESPONDENT NAME AND ADDRESS:
M; cha..t.t- .d. 'FtPlZ--f-;)
II ~ tu. 4-"" C&v-
<U?b It/l-, PI'r J 702.05'
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form 16 · 213
( IN THE COURT OF COMMON PLEAS OF
:~~ttrlcf..-cOUNTY, PENNSYLVANIA
(
PLAINTIFF,
v.
( CIVIL DIVISION
cAt'Vlrtul-- J httl)
(NO: ;;Jt>of; -I) 3'5aq
DEFENDANT.
1.
AFFIDAVIT OF CONSENT
A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:) ~/ :J.I/!!f..
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of
filing and 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.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 Cd 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. Section 4904 relating to unsworn falsification to authorities.
Date: /~ /~/ O~
.-
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PLAINTIFF,
form 17 · 215
( IN THE COURT OF COMMON PLEAS OF
:~~COUNTY' PENNSYLVANIA
v.
(CIVIL DIVISION
l/f11 Oh~l- J,
.---.
f oet)
(NO: 2 n{p - 6 =?S"3 CJ
Date: MILlliE
DEFENDANT.
AFFIDAVIT OF CONSENT
A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:) ..fL.) 2/1 ~
1.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of
filing and 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.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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. Section 4904 relating to unsworn falsification to authorities.
,J ,
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form 9 · 195
[.htPf-:J
( IN THE COURT OF COMMON PLEAS OF
~ ber'/IWVD COUNTY, PENNSYLVANIA
PLAINTIFF,
v.
( CIVIL DIVISION
lJ/J;clz~t- J. F(JCj)
(NO: 2t5l> fp - ()-;g S-3 9
DEFENDANT.
MARITAL PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made tWs-. day of ,200_, between
PLAINTIFF,~M-Jf j,... ro.w ' residing at U ~ Lu. A-n n C~
(city) €,,,~ I ~ , Pennsylvania /702 t5"' (zip), hereinafter
called ''1IusDclIttt'' I "Wife," and
DEFE~T, lA1iCA6U- d. h4) , residing at '.},;( (!. g,,~ 72,;"" ,
(city) L,~? -If j i,,1- ,Pennsylvania '7 () II (zip), hereinafter
called "Husband" I "~
WITNESSETH
WHEREAS, the parties were married on: (date) ,;l. . I tI 4 /q9 '8
WHEREAS, the parties filed for 3301(c) Divorce on: (date) II- 2-.1 . Z 6tJCe
WHEREAS, the parties hereto desire to settle their property rights;
WHEREAS, both parties agree to relinquish any and all claims which either may have against any prop-
erty now owned or belonging to the other or which may hereinafter be acquired by either of them by purchase,
gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, and agreements con-
tained herein; and,
WHEREAS, both parties each have had opportunity to seek the benefit of competent and independent
legal advise by separate counsel.
.
NOW, THEREFORE, the parties, intending to be legally bound, do covenant, and agree as follows:
1. INCORPORATION OF RECITALS
The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Each paragraph
hereof shall be deemed to be a separate and independent covenant and agreement.
2. APPLICABLE LAW
This agreement shall be construed under the laws of the Commonwealth of Pennsylvania.
196 ·
"
3. PROPERTY TO BE RETAINED BYWIFE.
Husband and Wife agree that, unless otherwise indicated in this agreement, the Wife shall keep all ofh~r
own personal clothing and effects; and that the following property shall also be retained by the Wife:
-If(l,(Je. ~C{;;f~d t:U- 11f, L~ Ann c~ entl~, PI/-
/7f1:L?' aNT:> af/ eJr1fe-n ~.
4. PROPERTY TO BE RETAINED BY HUSBAND.
Husband and Wife agree that, unless otherwise indicated in this agreement, the Husband shall keep all
of his own personal clothing and effects, and that the following property shall also be retained by the Husband:
~~ fi"o exl/~ Yltv iF /FMZIl7~k.8~il~eoB
.. ,
5. DEBTS To' BE PAID 'BYW1FE.
Husband and Wife agree that the Wife shall pay the following debts and will not at any time hold the
Husband responsible for them:
VfI,~~'Jb Ot1 f"'~'1 lite Lee 1#./1 ~)
<f", f,... I PI} 17 p 2-f:> -h /it. P ~ ~ VII tnIf, '''I fo
DilL Srlwru LA1ar.fr:Jt'A-f'i- In --/He-. tU1tAAh.J- pF
~ Gt; i;. 2/- AOe:t-.If ~ I~ 6.
6. DEBTS TO BE PAID BY HUSBAND.
Husband and Wife agree that the Husband shall pay the following debts and will not at any time hold
the Wife responsible for them:
l/If.,,,.H.{. fC<<fmWi-l- -J ~/ ~TII'Z- (lr,y/..-I-
-ha- ;J,?"" f;.t.v fX;>/fYU2.. 1/1 N~
/ pf)1 Z-U 7 tf /t~.JP5" tA-1I-(, I; ~ () 8. i" * a.41'f1 Hr1 +
dF 11 BGt tf{J .AccAI #=
· 197
,
7. PENSION AND/OR PROFIT SHARING PLANS, BANK ACCOUNTS, STOCKS, BONDS,
~CURITIES, CREDIT UNION ACCOUNTS, AND INDMDUAL RETIREMENT ACCOUNTS
Husband and Wife distribute the respective accounts as follows:
.6
8. REAL ESTATE
w/k -10 re1-tufl- h~ !oc:(,It~ tV! life
La, --Ana Cflt4Z.--Tj r;"o/~/ 74- /7/)2-5.
9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL
MARITAL RIGHTS
Each of the parties hereto release the other from subsequent claims for alimony, alimony pendente lite,
or spousal support, except as set forth as follows:
;/f,4L5
198 ·
10. JOINT DEBTS
\
Husband and Wife warrant and certifY to each other that there are no individual or joint marital obliga-
tions outstanding, other than those listed in paragraphs 5 and 6 above.
11. DIVORCE
Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce
under 23 Pa. c.A. Section 3301(c).
12. TAXADVICE
The transfers set forth herein may result in income, inheritance, estate, and other tax consequences to the
parties. The parties specifically acknowledge that no attorney involved in the negotiating or drafting of this
Agreement has provided any tax advised regarding the dispositions contained herein. The parties have been
advised to seek separate tax counsel concerning the Divorce distributions.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first
above written.
Witness
On this c;) f} '" day of OV[
officer, personally appeared NAMES
__ ' 200~i b~ore me, a Notary P}lblic, the undersigned
.j - rJ) <: D AA L. -f() and
, known to me to be the persons whose names
are subscribed to the written instrument, and acknowledged that they executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
r\\CUM r~~
Notary P~bliC (;
COMMONWEALTH OF PENNSYLVANIA
NoIariaI Se;:,1
May J. GouIrer. Notary Public
Sliver Sprlng Twp. C, :"bul1al1('1 County
MyCallmlsslo<' f:xpo::"O' '7 2007
Member. Pennsylva,"" "\SbuLililUon 01 NOUIrItle
form 10 · 199
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( IN THE COURT OF COMMON PLEAS OF
; Ct(,1l1 beY /fiNi). COUNTY, PENNSYLVANIA
(
PLAINTIFF,
v.
( CIVIL DIVISION
tA1v/uu, J. &i)
(
( NO: 2JJ?] (p. 0 3~-3 c;
DEFENDANT.
ACKNOWLEDGMENT
A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on ~/ 21 /~ agree
that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of fil-
ing the Complaint. All information contained within the attached documentation is true and correct to the best of my
knowledge, information, and belief.
I< j, my d"ire m m, whh "', &n,~/a.,td- . County Coun of Common PI", "',
attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as
set forth within said Marital Property Settlement Agreement documentation.
IN WITNESS WHEREOF, I set my hand and seal this c91 ~ay of ;JOVf?ri&:.........
,200~.
On this c;:; '1,t. day of ~I\) \/1...Nt e ~ , 200 (p , before me, a Notary Public, the undersigned
officer, personally appeared NAME ~~_b() fUlrh L ~ , known to
me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same
for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~~l~ 6~
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
W<<y J. Gauffer. NolarY PubliC
SlIverSprinQ Twp., Cumbel1and ColriY
My CQrnrniSSlOn Expires Nov. 17.2007 .
Member, Pennsylvania Association Of Notanes
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so that we can return the card to you.
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or on the front If space permits.
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO.20Gb- D35"?:/1 CIVIL TERM
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 ~3301 (c)
3301 (d)(1) of the Divorce Code.
(Strike out inapplicable section).
2.
Date and manner of service of the complaint:
/;;<./7.d7
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l/VIa4"L.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plaintiff />boM-ff 1-, Po ef) ; by defendant lk1, chct~'- J. FOe.I~ .
(b) (1) Date of execution of the affidavit required by ~3301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending:
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:
(b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: ---.J J.. 0'.0(,
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: I " ' b I . 0
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
ftbo!G4-J./- L. Foe])
PENNA.
NO.;?(X1p-{)3539
VERSUS
M/chae,L J
F-o R.. D
DECREE IN
DIVORCE
AND NOW, m2.J'L~ ~ , ZOO?
DECREED THAT /.)zbJtfl1-ff L 'J-:ou~
L/I1; chut L- J roe-t~ .
IT IS ORDERED AND
, PLAI NTI FF,
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT
YET BEEN ENTERED;
A
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ff.
~
~
ff.
~
~
~
ff.
~
~
~
~
;;;
~
ff.
ff.
~
~
~
~
~
;;;
ff.
~
ff.
ff.
~
-h~ ~ ~ Lt7 fL
~ ~ ~ ~:-P9 LiJ- 6'C
. .... . . ,"'J