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HomeMy WebLinkAbout06-4057 , ,v i",(c :1.~ffJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 06- cJ D!>'/ CIVIL TERM o~ ~~~c ~ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE 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 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, I 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 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 . ~(\t. ~~j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 06- <.[IJ 1>1 CIVIL TERM \?~ l~~l m~ Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. . ... ,,~ .J~u. p:.;f\j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. No. 06- 40:{10V1L TERM 0nui ~~~I0\j IN DIVORCE COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is lJYI"- 41'/1 ;11a.r ' who currently resides at "/ p,,, ltd. //pI. S'a3 J?'17 /1<#<1 Spt-;i1?S. ]),1. ()Oros- Cumberland County, Pennsylvania. 2. Defendant is ~f.ll)L7men'c:i (rIo.{ C)ofiflJ GaJdlltx 6~ . I , who currently resides at or vJro.w kll+ ~ ~~[~ S-<=t f6rls (( . 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 jl'/prf j-r- 199:;- at (YrT, ~JJi-sprl-'1 S 5. The marriage is irretrievably broken, and the parties separated on Jvc. )OOb \ 6. There have been no prior actions of divorce or annulment between the parties. 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 Plaintiff may 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. 7-/~-(){P Date if /~ ~ _ ~J Pia. iff, Pro t I, /{)YA .1 41 , verify that the statements made in this Complaint... are true 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. 7J-/~:y o~ Date: L /: 11fa~ PlaiMiff, Pro 8'e . Assisted by: Jennifer L. Spears, Esquire Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, Pennsylvania 17013 (717) 243-3341 .-, 1= '71 -e (:::.; 'J t '....-::; Lf>no. L. may Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA Vb.tJ1 &wfcL {V1t{ V Defendant : NO.06- 40n CIVIL TERM : DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindlyallow. Lona Lvnn Mav , Plaintiff, to proceed in forma pauperis. I, Jennifer 1. Spears, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. J e i e 1. Spears, Esquire Attorney for Plaintiff 10 E. High Street Carlisle, P A 17013 (717) 243-3341 " rAon"PI,~tJff M~ 9a.u1 ~G ~ Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO-o&-).joS7 : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME ~otice is hereby given that Plaintiff in the above matter filed a Complaint in Divorce filed on ~ ' hereby intends to resume and hereafter use her previous name of (Orla. '-~ oV"\ , and gives this written notice avowing her intention in accordance with th provIsions of the Act of Apnl 2, 1980, P.L., 23 P.S. 702, effectIVe July 1, 1980. )~ L- I1tH( Lona L. May L 8YlCt ('1M G~;d (JV'l loro G.l tlf' WdOiY1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the day of It~", IW +-- ,2006, before me, the undersigned officer personally appeared ona L. t"'l.. , altokii~wn as t..na '-ynl1 Gord,n known to me (or satisfactorily proven) to be the per on whose name is subscritled to the within instrument, and acknowledged that she executed the same for the purposes therein contained. SS IN WITNESS WHEREOF,I hereunto set my hand and official seal. COMMONWEALTH Of PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public Carlisle Bora, Cumberland County My Commisaion Expires Aug. 18, 2007 Member, Pennsylvania ASsOCiation of Notanes ~~~ ~ cl ~~.. -. i-'~ - .....\ ~ cY ~ & . ~",' door. J~~J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. No. 06- t1V57 CIVIL TERM Qdci \oWilllc fY\~ Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, YLJUI IPiA--t (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. r/11 JIJ (, Dat ( ...f2..~ ~ - , :.::::1 d6Y'L ~.~ ~h(l{( d'U(\{A ~, (/(\!Uj Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Qwti ~6~ ~ Defendant No. 06-tj OS 7 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A c01}lplai.!}t in divorce under ~3301(c) of the Divorce Code was filed on ju.\~ 1I(.ltiio . 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 subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1/ JrJo& Signature: ~ rL e!i Lona L. ay, Plain ff ~ () = -'T1 c""'\ co 1',) o ~ A~4\K\a d o.'lbt ci . IY\~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. ~mJ ~~~7 ff\Oj No. 06- 105"7 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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:)) /r/~ . Signature: ~ I arL , Lona t, May, Pliintiff ~ C:) = -n <.:::;..... I C:J r0 C) J{~ j! btsJWllJrlCl J-Oi\fA ,j. (j{\L~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. NO.06-ilJ57 CIVIL TERM ~luJ R(J~L mill) Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. compla,int in divorce under g3301(c) of the Divorce Code was filed on 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 subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authOrities:2 /J 17 Date: ! 1/10 It; (p Signature: ( (;WJ:" If, f Paul R. May, Defendant ------- o ~~; r-" ,--_of j-l :.-:1 C) .<:..,..;: u; "'""'r) r-~.) - Jrsnu l ~dfY) JIKk~ ifJr\Cl -J. fnalj Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. Qwj (RoM m~ Defendant No. 06JjaS"itIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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. nate:#iI Signature: --------- r""1 ~r-i c..n --"" f": ~l GJ~ ~IKICL clonC\ d, Pl~ti' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 06-1051 CIVIL TERM ~cuJ ~6~an~ aJj IN DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following infom1ation, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on ivlr J7, ,JtiIo 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, Dov <( J d~? ; by Defendant, {IN /0 J "Jtt>fo 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dim f, JIlb (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: DJV /5) ad"~ Plaintiff's Social Security Number: {!O-S~-3D37 I (P / - S--t:/ ~ d-9/ U , ~,/~ :tona L. May Defendant's Social Security Number: ,") 2:h ::::! V'i 1",-1 C) Eli :Ii fIJ:Ii :Ii"; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF LONA L. GORDON f/k/a No. 06-4057 LONA L. MAY VERSUS PAUL RODERICK MAY DECREE IN DIVORCE AND NOw,~uvM ~~ , ~Z-- , IT IS ORDERED AND DECREED THAT LONA L. GORDON f/k/a LONA 1.. MAY , PLAI NTI FF, AND PAUL RODERICK MAY , 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. ff."; ff. :f.:f.:f.:f.:f.;t::f.;t::f.:f.:f. :f. :f.:f.:f.ff.;t::f.:t'''' J. ~~ :z ~ ~Jt, 1(/> /- C/ t?1-(?(/JII ? ~~ -TP ?r?- J ~ c/ , .. . . . .. .., . ,to ~.. :4 It t.