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HomeMy WebLinkAbout06-3839 T AKEIT A TURNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACnON - LAW : IN DIVORCE JAMAR FOSTER, Defendant :'NO. 06- ~J>3? 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIllS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMA nON 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. T AKEIT A TURNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JAMAR FOSTER, Defendant : NO. 06- 3P.1? CIVIL TERM DIVORCE COMPLAINT The plaintiff, Ms. Takeita Turner, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. 1l1l330J(c) AND 330J(d) OF THE DIVORCE CODE I. Plaintiff is Takeita Turner, who currently resides at 436 Meadow Drive, Camp Hill, Cumberland County, Pennsylvania, 17011, since October 2004. 2. Defendant is Jamar Foster, who currently resides at 420 Hummel Street, Harrisburg, Cumberland County, Pennsylvania, 17104, since March 11,2006. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on August 31, 2001 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since March II, 2006. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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 requests the court to enter a decree of divorce. c/JL 0,;/1 Keith O. Hickman Certified Legal Intern Czf~ ~~~[J~ ROB T ~. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON- WALSH Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 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. ~904, relating to unsworn falsification to authorities. Date~ PlaintifJQ~~ Takeita Turner C..,, .-\ '-",~ -';\ I C .- -- ~ ~ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : IN DIVORCE T AKEIT A TURNER, Plaintiff JAMAR FOSTER Defendant : NO. 06-3/J'TCIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Takeita Turner, 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. Date 1- / (p /2.00CP , eith Hickman Certified Legal Intern OBE THO 1\ 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 ::;1 ;-,l (j\ ", ~ ,,,,, TAKEITA TURNER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v JAMAR FOSTER, Defendant : CIVIL ACTION-LAW : DIVORCE : No. 06-3839 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint at the above-captioned docket. ssica D. Woodman-Hardy ertified Legal Intern R~~ THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER KATE CRAMER-LAWRENCE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Telephone: (717) 243-2968 Fax: (717) 243-3639 Date: September 8, 2006 Q) l"'-..> = = c__ (/) ~. ~"'{j o "-T1 -:-{ ::t_, rrl,~:' ~-~? t~~i I CO ""D r'0 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LA W : IN DIVORCE Takeita Turner, Plaintiff Jamar Foster, Defendant : NO. 06 - 3839 CIVIL TERM CERTIFICATE OF SERVICE I, Jessica Woodman-Hardy, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Mr. Jamar Foster, residing at 80 M W Smith Homes, Harrisburg, P A, 17103, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Jamar Foster, on the 11th day of September, 2006, as evidenced by the attached green card numbered 70050390000326324462. sica Woodman-Hardy ertified Legal Intern ~~d ;t}utJ/ft.tLI/~ ROB T E. RAINS if THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER KATE CRAMER-LAWRENCE Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 . - ~'.. SENnF R 'OMI " J . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Att? ~ this card to the back of the mailpiece, or ( the front if space permits. 1. Article> Addressed to: ~;:-uJ ~~ tJ4~< ;) fJ.N>/~ h~ J pA /1 J e 2. Article Number (Copy from service label) ') ()t:J~ O:r '7/) .oDD 3 PS Form 3811, July 1999 ~63~ Domestic Return Receipt 102595-99-M-1789 D. Is delivery address differen from item 1? If YES, enter delivery address below: 3. Service Type 'jit Certified Mail o Registered o Insured Mail D Express Mail ~ Return Receipt for Merchandise DC.D.D. 4. Restricted Delivery? (Extra Fee) Yes t./ 'I" 2.. f r-'-..) c::) , !.:.:.J-' "j'i .-1 -r r .-- ;-. r; ~ -- - r>? c..) (-P, Takeita Turner, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CNIL ACTION - LAW : IN DIVORCE Jamar Foster, Defendant : NO. 06 - 3839 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on July 6, 2006. A Praecipe to Reinstate Complaint was filed on September 8, 2006. Certificate of Service was filed on September 14, 2006. 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. ~904, relating to unsworn falsification to authorities. Date \ ~f ~ ~(Dfp l JatJJ~ Takeita Turner, Plaintiff :?:v c~ ~ () I$! -r; C"Jl f\:;, ~.() ':':) f~Ji \:' Takeita Turner, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Jamar Foster, Defendant : NO. 06 - 3839 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) OF THE DIVORCE CODE "-' ~5 c:) o~ .1 1. I consent to the entry of a final decree of divorce without notice. 0 .-4 ,r: ::r: _~ (-) rtl r-~ 2. I understand that I may lose rights concerning alimony, division ofprop~, lavQ)br's ~~Eg fees or expenses if I do not claim them before a divorce is granted. ::- .... :J:? ~j' ~~: .:~ .~. . ."! 6 3. I understand that I will not be divorced until a divorce decree is entered by:::the C8urt ~:~ m and that a copy of the decree will be sent to me immediately after it is filed with the ,~:2 ~ 2? 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 lG-1 ~ g- /oLP I ~h J{fuMA Takeita Turner, Plaintiff Takeita Turner, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE Jamar Foster, Defendant : NO. 06 - 3839 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 330l(c) of the Divorce Code was filed on July 6, 2006. A Praecipe to Reinstate Complaint was filed on September 8, 2006. Certificate of Service was filed on September 14, 2006. 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 stat.:ments herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date /) -/~-6(p ::>-: C0 cr; \..0 ...:.'..):~ I;:::. C~ u\';-/ C:-:~ ( ,.__.l ::=':\ :' t -.=J u: \ol~ r-:: lL- o '-- CJ" C<l Co.) ,~:-., c:J v::) = = c-l Takeita Turner, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Jamar Foster, Defendant : NO. 06 - 3839 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~330l(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 {d~3l-(j Ce o c;; "".-,-- ~ :3 c..- :;;:,'1";'" __v - N a'< ~ -- -0 ..-;'" J.- ~ .-\ :t;--n P'c --om -,)Y {~~'~ \..--"'1 :2(~) :",-rn ',::2\ 2?-; ~ - <.1' U\ Takeita Turner, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LA W : IN DIVORCE Jamar Foster, Defendant : No. 06 - 3839 CIVIL TERM PRAECIPE TO TRANSMIT RECORD 'fu 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 ~330 1 (c) of the Divorce Code. 2. Date and manner of service ofthe complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Jamar Foster, on September 11, 2006. 3. Date of execution of the affidavit of consent required by ~330 1 (c) of the Divorce Code: by plaintiff-12128/2006; by defendant-12/18/2006. 4. Related claims pending: none 5. Date plaintiff's Waiver of Notice was filed with the Prothonotary: 12/29/2006. Date defendant's Waiver of Notice was filed with the Prothono!ary: 01/26/2007. 6)j;;2/d-;t (7Uee1J~~4 Date ~sica D. Woodman-Hardy Certified Legal Intern ;;:~ L-/J/1~~~ ROBE T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNS TON- WALSH MEGAN RIESMEYER Supervising Attorneys F AMIL Y LA W CLINIC 45 N. Pitt Street Carlisle, P A 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff o ~. ..:;,~... -1:) D:' ~"\~", t9~.... ~ ~~ ~; \~ "-I ::< r-:l egg ;....J -rt ~ rv o -0 ::;l!': ~ ~-n rnf':: -n.rn ~.nY c~ (~} -:~:~1 7:~('1 ,~(n ~ 2D ::.<::. - UJ o ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PL OF CUMBERLAND COUNTY AS DECREE IN DIVORCE ~~~ STATE OF TAKEITA TURNER, Pl"intiff VERSUS JAMAR FOSTER, Defenc1"nt AND NOW, DECREED THAT PENNA. No. 3839 2006 a.oo 7 'T'AKEI'T'A 'T'tJRNER AND , DE DANT, JAMAR FOSTER ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH YET BEEN ENTERED; HICH HAVE HONOTARY J. ~ ~ ~ ~ ~ L(l' ~ -f' -7 ~ ~ ~~ -r;J t:~<7' ~ .~ ",' .. II!.