HomeMy WebLinkAbout02-2015TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
· IN DIVORCE, EQUITABLE DISTRIBUTION
.'
: NO. 02-.~o/~ CWIL 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 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) 2490-3166
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.
In the Court of Common Pleas of CUMBERLAND Colmty, Pennsylvania
DOMESTIC RELATIONS SECTION
TRACY L. BIGGS ) Docket Number
Plaintiff )
vs. ) PACSES Case Number
JAMES W. BIG~S )
Defendant ) Other State ID Number
02-2015 CIVIL
531104586
ORDER OF COURT
You, TRACY LEA BIGGS
213 N PRINCE ST, SHIPPENSBURG, PA. 17257-1319-13
plaintiff/defendant of
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
AUGUST 8, 2002
at 8 .. 3 o~ for a hearing.
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-P~s,cas filed,
2. your pay stubs for the preceding six (6) months, ~ ~ /
3. verification of child care expenses, and ~~
· . . LT. r~ ~x, ~
4. proof of medical coverage which you may have, or may have avatlable to ~ N~
o tionr ,atin to f sio ,i o .
Form CM-509
Service Type M Worker ID 21302
PACSES Case Number: 531104586
v. BIGGS
BIGGS
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
An appropriate order may be entered against either party based upon the evidence
presented without regard to which party initiated the support action.
Date of Order:
BY THE COURT:
~UDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. 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 MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBER~ 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 at: (7x7) 240-6225 · All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Page 2 of 2 Form CM-509
Worker ID 21302
Service Type M
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
TRACY L. BIGGS ) Docket Number
Plaintiff )
vs. ) PACSES Case Number
JAMES W. BIC-GS )
Defendant ) Other State ID Number
02-2015 CIVIL
531104586
ORDER OF COURT
You, JAMEs ~SLEY Bq'C.~(~S plaintiff/defendant of
FO BOX 602, 306 CLAY ST, BAY MINETTE, AL. 36507-4708-06
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
AUGUST 8, 2002 at 8:30AM forahearing.
You are further required to bring to the hearing:
1. a tree copy of your most recent Federal Income Tax Return, including W-2s, ~ .4Sln ed'
2. your pay stubs for the preceding six (6) months,
3. verification of child care expenses, and
proof of medical covera e which ou .
4... ...... g Y mayhave, or may have avaflable to you;~6~ r~
5. mlormatlon re~atmg to professional licenses
6. other:
Service Type
Form CM-509
Worker ID 213 02
B~C-~S v. BXGOS PACSES Case Number: 531104586
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
. An appropriate order may be entered against either party based upon the evidence
presented without regard to which party initiated the support action.
Date of Order:
BY THE COURT:
JUDGE
YOU HAVE TI'l~ RIGHT TO A LAWYER, WHO MAY ATI'END THE HEARING AND
REPRESENT YOU. 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 MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CmmERraSD 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 at: (717} 240-6225 . All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Page 2 of 2
Service Type M Form CM-509
Worker ID 21302
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: IN DIVORCE, EQUITABLE DISTRIBUTION
:
:
: NO. 02-~"CIVIL TERM
COMPLAINT UNDER 23 Pa.C.S. SECTION 3301(c),(d) OF THE DIVORCE CODE
COUNT I
The plaintiff, Tracy Biggs, by her attorneys, the Family Law Clinic, sets forth the
following cause of action.
1. Plaimiff is Tracy Biggs, who currently resides at 213 North Prince St.,
Shippensburg, PA, 17257.
2. Defendant is James W. Biggs, was last known to reside at306 Clay Street; P.O.
Box 602; Bay Minette, Alabama, 36507.
3. Defendant currently receives mail at P.O. Box 107, Walnut Bottom, PA 17266.
4. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
5. The Plaintiff and Defendant were married on May 30,1997 at Baldwin County
Courthouse, Bay Minnette, Alabama..
6. Plaintiff and Defendant have lived separate and apart since September 2001.
7. There have been no prior actions of divorce or for annulment between the parties.
8. The marriage is irretrievably broken.
9. 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 dissolving the
marriage.
COUNT II
EQUITABLE DISTRIRUTION
10. Plaintiff repeats and realleges paragraphs one through eight.
11. Plaintiff and Defendant have acquired property during the marriage, including,
but not limiting to:
a) Washer and Dryer
b) Ford Windstar Van
c) Refrigerator
d) IRS Refund check for 2001
COUNT IH
ALIMONY
12. Plaintiff repeats and reaileges paragraphs one through eleven.
13. Plaintiff requires reasonable support to adequately maintain herself in accordance
with the standards of living established during the marriage.
14. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable
to support herself through appropriate employment.
15. Defendant is employed and is financially able to provide for the reasonable needs
of the plaintiff.
COUNT IH
ALIMONY PENDENTE LITE AND COSTS
16. Plaintiff repeats and realleges paragraphs one through fifteen.
17. Plaintiff requires reasonable support to adequately maintain herself in accordance
with the standards of living established during the marriage.
18. Plaintiff will be at a disadvantage during this litigation due to the lack of f'mancial
resources. Plaintiff will be unable to pay for any expenses that might arise during the
litigation of this matter.
19. Defendant has been employed during the marriage and will have the financial
resources to pay for expenses that might arise during litigation of this matter.
20. Defendant has the financial ability to provide for the reasonable needs of the
Plaintiff.
WHEREFORE, Plaintiff requests the Court to enter a decree dividing the property
equitably between the parties and providing other relief as the Court deems just.
Respectfully submitted;
Certified Legal Intern
Student Attorney for Plaintiff
Supervising Attorney
LUCY JOHNSTON-WALSH
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are tree 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. §4904, relating to unsworn
falsification to authorities.
TRACY L. BIGGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, EQUITABLE DISTRIBUTION
JAMES W. BIGGS,
Defendant : NO. 02 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Tracy L. Biggs, 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
Respectfully submitted,
Rebecca Case
Certified Legal Intern
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION -
: IN DIVORCE, EQUITABLE DISTRIBUTION
:
: NO. 02 - 2015 CIVIL TERM
:
PROOF OF SERVICE
Understanding that the making of any false statement would subject her to the penalties
of 18 Pa. C.S. §4904 (relating to unswom falsification to authorities), the undersigned verifies
that the Family Law Clinic served a true copy of the Divorce Complaint on the Defendant by
placing the same in the U.S. Mall, certified no. 7001 2510 0003 4482 1877, restricted
delivery, remm receipt requested, postage prepaid, on the 26th day of April, 2002, addressed
as follows: James W. Biggs, 306 Clay Street, Bay Minette, AL 320607.
Sender's receipt no. 7001 2510 0003 4482 1877 is attached hereto and incorporated by
reference.
On or about the 16th day of May, 2002, return receipt no. 7001 2510 0003 4482 1877
was delivered to the Family Law Clinic, bearing the signature of James Biggs and showing a
The remm receipt is attached hereto and incorporated by
date of service of May 13, 2002.
reference.
Jennifer ~'*~r ly
Certified/Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
Postage
Cert~ed Fee
Return Receipt Fee
(Endorsement Required)
Restricted Delivepj Fee
(Endorsement Required)
Total Po~tage & Fees
PS Form 3811, August 2001
q~:~, o~b-TO 000.'~ qq22 I,~Trl
Domestic Return Receipt 1025g~-01-M-0~}l
TRACY L. BIGGS,
Plalmiff
JAMES W. BIGGS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CML ACTION -
: IN DIVORCE, EQUITABLE DISTRIBUTION
:
: NO. 02 - 2015 CIVIL TERM
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern at the Family Law Clinic, hereby certify that I
am serving a true and correct copy of the attached Proof of Service this date upon James W.
Biggs of 306 Clay Street, Bay Minette, Alabama 36507 by regular U.S. mail.
Date
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243 -2968
TRACY L. BIGGS,
Plaintiff
V.
JAMES W. BIGGS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW I
IN DIVORCE
NO. 02-2015 CIVIL TERM
ORDER APPOINTING MASTER
AND NOW, this f7 _ d% of ~ 2002, Mich~
Support Master, is appointed to hear the claim for Alimony Pendente
the pending claim for Spousal Support.
,'1 R. Rundle, Esquire,
Lite simultaneously with
By the Court:
TRACY L. BIGGS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : CIVIL ACTION - LAW I
: IN DIVORCE i
JAMES W. BIGGS, :
Defendant : ,
: NO. 02-2015 CIVIL TERM
MOTION FOR APPOINTMENT OF MASI'
Tracy L. Biggs, Plaintiff, through her counsel, the Family law
appoint a Master with respect to the following claims:
( ) Divorce ( ) Dis
( ) Annulment ( ) Sup
( ) Alimony ( ) Cot
(X) Alimony Pendente Lite ( ) Cos
and in support of the motion states:
1. Plaintiff filed for divorce on April 26, 2002 under Secti
Divorce Code. The Complaint included economic claims of Equitable 13
Alimony Pendente Lite.
2. Defendant was served with the Divorce Complaint on h
3. A Complaint for Spousal Support was filed by Plaintiff
Domestic Relations Office; Docket Number 29 S 2002; PACSES Case
Spousal Support Conference was held on June 11, 2002. The Support 12
to the Support Master because liability is disputed.
4. At the Spousal Support Conference, Plaintiff informed th
had also filed for Alimony Pendente Lite. Defendant stated that he der
Pendente Lite. The Support Officer informed the parties that the Ali~
would therefore be referred to the Support Master.
5. The Alimony Pendente Lite claim involves complex issu
6. A hearing is expected to take three hours.
ER
Clinic, moves the court to
:ribution of Property
port
nsel Fees
ts and Expenses
)ns 3301(c) and (d) of the
istribution, Alimony, and
Iay 13, 2002.
on April 24, 2002 at the
Number 632104155. A
~fficer referred the matter
~ Support Officer that she
ied liability for Alimony
any Pendente Lite claim
es of law and/or fact.
WHEREFORE, Plaintiff requests that Michael R. Rundle, Esquire, Support Master, be
appointed to hear the Alimony Pendente Lite claim simultaneouslY lwith the pending Spousal
Support claim. 1
Jennife
Certified Legal Intern
ROBERt E. ~,3(INS
LUCY JOHNSTON-WA
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-240-2968
TRACY L. BIGGS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - /
IN DIVORCE, EQUITABLE DISTRIBUTION
JAMES W. BIGGS, : NO. 02 - 2015
Defendant :
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern at the Family Law C
am serving a tree and correct copy of the attached Request for Appoint
upon James W. Biggs of 306 Clay Street, Bay Minette, Alabama 3650'
first class U.S. mail.
Jenni~q'l-Ieverly
Certified Legal Into
FAMILY LAW CI
45 N. Pitt St.
Carlisle, PA 17012
717-243-2968
Date
CIVIL TERM
[inic, hereby certify that I
nent of a Master this date
by postage prepaid,
In the Court of Common Pleas of
Phone: (717) 240-6225
DOMEb~IC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, cARLISLE, PA. 17013
County, Pennsylvania
Fax: (717) 240-6248
Plaintiff Name: Tracy L. Biggs
Defendant Name: James W. Biggs
Docket Number: 02-201 5, In DivorCe
PACSES Case Number:
Other State ID Number:
Please note: All correspondence must include the PACSES Ca~e Number.
Income and Expense Statement_
THIS FORM MUST BE FILLED OUT
r if, ou are salaried by a business of which you are own6r in whole or part, you
(If you are self-employed o Y ............ on ,~ave two of this income and expense
also fdl out the Supplemental Income statement wm,m apl~,-~o r
statement.)
INCOME STATEMENT OF _ Trac L. Bi s
Section I: Income and Insurance
must
INCOME:
l~m?oyer Pow__er Technolo ~. n a-,nc--
~.O. BOX 782 Wilke .--
'1~ of Work .
Payroll No. Gross Pay per Pay Period $ 273.00 Pay Period (wkly, bi-wklyk, etc.)
OTHER
INCOME WE~.K MONTH
Divi4~
Rents ~ ~
Ro allies ~ ~
Z~}~r.~ Account
N'orkmen's
~ 50
TOT~ $ 50
Service Type
Net Pa)' [}er Pay period $ 2 3 6 8 4 =: i
0:ill in Appropriate Co!utah)
pROPERTY
oWNED
Checking Accounts
Savings Accounts
Credit Union
Stocks/Bunds
Other
DESCRWTION
VALUE
$ 342.
350.
TOT,L I$ 692.00
* H=Hust and; W=Wife; J=Joint
owaers~ *
Form IN-008
Worker ID
Income and Expense Statement
INSURANCE
Blue Cross
Other
LXiediea!
Blue Shield
Other ~
Health/Accident
Disability Income
Dental
Other
COMPANY
* H=Husband; W--Wife; C=Child
PACSES Case Number
POLICY #
Section H: Supplemep(nl Income Statement.
a. This form is to ho filled out by a p~rson
OV
do
I'-] (1) who operates a business or practices a profession, or
[] (2) who is a member of a parmership or joint venture, or 1
[] (3) who is a shareholder in and is salaried by a closed corporation or similar entry.
Attach to this statement a copy of the following documentS relntmg to the parmershtp, jogt venture, bustuess
coq~Oration or similar entity: I
(1) the most recent Federal Income Tax Return. and
(2) the most recent Profit and Loss Statement I
Name of business: ~
Address and telephone number: ~
[] (I) parmership
[] (2) joint venture
[] (3) pm fession
[] (4) closed corporation
[] O) other
Name of accountant, controller or other person in charge of financial records:
profession,
Annual income from business:
(l) How often is income recoivecrt.
(2)
(3)
(4)
Gros~ income per pay period:
Net h~.come l~r pay period:
Specified deductions, if any:
Page 2 of 3 Form I2,I-008
Worker ID
Service Type
PACSES Case Number
Income and Expense Statement
Section III: ~
Instructions: Only show extraordinary expenses in this section unless you filled out Section II on page two. The categories
in BOLD FONT are especially important for calculating child support. If you are requesting Spousal Support/APL or if
you assert your case cannot be determined according to the guideline grids or formula, this: section must be fully completed.
*Tracy contributes about $300 a month to household bills.
EXPENSES
Mortgage/Rent
Maintenance
Oil
Water
Lunch
(Fill in Appropriate Column)
WEEK MONTH YEAR
$ $ *
$ $
~XPE.NSES
continued)
ducati0n_
Private School
~tt._tu2_ hinl School
College
Religious
~ersonal
Clothing
Food
Bar'ocr/
Hairdrc~
Credit Payments .
Credit Card
-- Charge
Memberships
W~ (Fill in Appropriate Column)
EK MONTH $ YEAR
S10 ; 25 S 300
I 5o
Personal property
Automobile
Life
gfi, olth
Other
Fuel
$ $
ITotal
Expenses:
WEEK
MONTH
s1384.67 $
YEA
s~atements herein are subject to file crlmlllat i~tu~ ~,- - .... ~
Da?// ~/Oc~ Plaintiff or Defendant/
Page 3 of 3
Service Type
t. I understand thmt false
nswom falsification to authorities.
Form IN-008
Worker ID
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
: IN DIVORCE
:
: NO. 02 - 2015 CIVIL TERM
;
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern at the Family Law C1
am serving a true and correct copy of Plaintiffs Income and Expense S'
Biggs of 306 Clay SWeet, Bay Minette, Alabama 36507 by depositing
U.S. mail, first class, postage prepaid, on this 18~ day of June, 2002. I
Date
inic, hereby certify that I
atement upon James W.
copy of the same in the
egal Inl em
FAMILY LAW C ,INIC
45 N. Pitt St.
Carlisle, PA 1701
717-243 -2968
.ROWER.TECHNOLOGY INC.
~ee Name
TRACY BIGGS, ~-~ L
~ Hours Rate
HOURLY 23.00 '13.00
HOURLYOT 0.00 19.50
45137
SOO Sec # From To __.'_C.he~c,k,?~ate
02 01 18 02. 01/25/02
Current ~
299.00 SOCSEC
0.00 FEDS
2220002
MEDICARE
22300017
226600PB
Current Amt' ~
18.54 18.54
12.98 12.98
8.37 8.37
4.34 4.34
2.99 2.99
Curr Amt Curr Ded Net Pa~
299.00 47.22 251.78~
POWER TECHNOLOGYINC.
~ee Name
TRACY BIGGS, TRACY L
~ Hours Rate
YTD Earn ~ YTD Net ~
299.00, '41 .~-- ~1.78 00045129
45244
~-~--~e~ YTD
Current ~ ~-~. 93 35.47
HOURLY 21.00 13.00
HOURLYOT 0.00 19.50
273..00 SOCSEC
0.00 FEDS
Curr Amt Curr Ded Net Pa~ YTD Earn
273.00 40.34 232.66 572.00
2220002
MEDICARE
22300017
226600PB
9.08 22.06
7.64 16.01
3.96 8.30
2.73 5.72
POWER TECHNOLOGYINC.
Employee ~ Employee Name
TRACY BIGGS, TRACY L
Earnings Hour~ Rate
- ~21.00 ~
Soc Sec #
196-58-3365
Current ~t-----~-~-~-Ded
2--f~.00 SOCSEC
HOURLY
HOURLYOT 0.00 19.50
0.00 FEDS
PA
MEDICARE
22300017
2220002
226600PB
YTD Ded YTD Net Pa Check No._
8--------V .--~ ~-~4.44 00045244
45402
Fro~ ' To Check Date
01/~ 02/01/02 02/07/02
~ C_urren---~ ' ---~TD
9.08 31.14
7.64 7.64
3.96 12.26
2.73 8.45
16.01
Curr Amt Curr Ded Net Pay YTD Earn YTD Ded YTD Ne__=.t_P~~
'owE,
TRACY BIGGS, TRACY 'L
~rninGs Hou~rs_~ ~Rat~e~ Currenot~t
27 . oo
0.00
45613
Soc Sec # From To Check Dat(
02
WHTDed ! Current Amt ' ~
socs ,c
HOURLYOT
0.00 19.50
PA 7.64 15.21
FEDS 4.90 36.0,
MEDICARE 3.96 16.2;
22300017 2.73 11.1~
2220002 16.0:
2266007B
Curr ~J~t Cur~8 Y~l~a~
~ 36.16 23 . ·
00
POWER TE~CHNOLOGY INC.
Soc Sec $ Fr~
Em lo ee # ~Em~ l~ o~ ee~oN~a~vme ~
TRACY BIGGS, TRACY -L
Hours Rate Current Amt ~
~rnin~-~--~$-~.00
HOURLY
HOURLYOT 0.00 19.50 0.00
Curr Amt Curr Ded ~~
POWER TECHNOLOGYINC.
Employee $ Employee Name
TRACY BIGGS, TRACY L
S SEC
PA
FEDS
MEDICARE
22300017
2220002
226600PB
YTD E~
1391.00 2
Soc Sec $ Fr
196-58-3365 02
Hours Rate Current Amt WH D~~
SOCSEC
'PA
FEDS
MEDICARE
22300017
226600PB
2220002
Earnings
HOURLY~ ~".21 00 ~-~.00 ~-~3.00
HOURLYOT 0.00 19.50 0.00
-~ YTD Net Pa ~-heck_~9.
~45611
45697
)m To Check Date
"~'1 02 02 17 02 02 22/02
--Current Amt ~-~
7.64 22.92
4.90 40.94
3.96 20.18
2.73 13.91
16.0]
D~YTD Net Pa Check N~_o.
~.22 1~045695
45818
~m To Check Dat~
'19/02 02/25/02 03/01/02
Current Amt YT[
.93
7.64 30.5(
4.90 45.8~
3.96 24.1,
2.73 16.6,
16.0~
'~OWE~',TF. CH HOLOGY INC.
Employee # Employee Name
TRACY BIGGS, TRACY L
Hours Rate Current Amt WHfDed
4615
Soc Sec # From To Check Dat~
196-58-3365 03/04/02 03/10/02 03/15/02
Current Amt '~
~n~x~ s ?~.00 13.00~ SOCSEC
HOURLY ~x.v ·
HOURLYOT 0.00 19.50 0.00 PA
FEDS
MEDICARE
22300017
2220002
226600PB
Curr Amt Curr Ded Net Pa Y_T_D_~a~
· o.oo
POWER TECHNOLOGY INC.
Employee ~ Employee Name Soc Sec # Fro~
TRACY BIGGS, TRACY L 196-58-3365 03/2
Hours Rate Current Amt
Earnin~_~------~-~OCSEC
HOURLY
HOURLYOT 0.00 19.50 0.00 PA
FEDS
MEDICARE
22300017
2220002
2266007B
7.64 45.8,
4.90 55.6,
3.96 32.01
2.73 22.1~
16.0~
Ded YTD Net Pa Check No,
~ 70 ~004615~
46618
To Check Date
8/02 04/03/02 04'/05/02
~rrent Amt ~
7.64 68.76
4.90 70.34
3.96 43.94
2.73 30.29
16.01
Curr Amt Curr Ded
236.84
pO~/ER T.E. CHNOLOGY INC.
Employ~ee # .,Employee Name
TRACY BIGGS, TRACY L
Earni~Qs Ho~rs ~~t ~A~ntn W~~
- 21.oo 13.oo 273.00 socsEc
YTD Earn YT--~-~ YTD Net Pa Check No:
3029.00 417=-~, ~-~ ~-~-~46618
46344
Soc Sec # F~om To Check Dat
196-58-3365 03/11/02 03/15/02 03/22/02
HOURLY
HOURLYOT 0.00 19.50 0.00 PA
FEDS
MEDICARE
22300017
2220002
226600PB
Current Amt
~.93 ~
7.64 53.4
4.90 60.5
3.96 36.0
2.73 24.8
16.0
~ .... ~ ~- u~,, vmn m=~ YTh D~H YTD N~t Pay Check Nc
-" 4653'7
POWER TECHNOLOGY INC.
Employee~ ~ Employee Name Soc Sec # From To .Check Date
TRACY BIGGS, TRACY L 196-58-3365 03/18/02 03/24/.02 03/29/'02
Hours Rate Current Amt WH~-~ ------Current Amt YTD
~arnin~_~
HOURLY
HOURLYOT
~~.00 SOCSEC
0.00 19.50 0.00 PA
FEDS
MEDICARE
22300017
2220002
226600PB
7.64 61.12
4.90 65.44
3.96 39.98
2.73 27.56
16.01
Curr Amt Curr Ded N~
273.~~.16 236.84
YTD Earn
~00
y~ YTD Net Pa Check Not
381.02 ~46536
POWER TECHNOLOGY INC.
Employee. # Employee Name
TRACY BIGGS, TRACY L
Soc Sec # Fr¢
196-58-3365 04/
SOCSEC
PA
FEDS
MEDICARE
22300017
2266007B
2220002
46797
m TO Check Date
01/02 04/07/02 04/12/02
Hours Rate Current Amt
Earnin~
HOURLY 21.00 ~.00 27-~.00
HOURLYOT 0.00 19.50 0.00
Current Amt YTD
~.93 204.-~
7.64 76.40
4'.90 75.24
3.96 47.90
2.73 33.02
16.01
Curt Amt Curt D~ YTD Earn
6~-~236.84 3302.00
2-~. 00
POWER, TECHNOLOGY INC.
YTD ~ed YTD ~No.
45----~.34 2848.66 00046~-~5
46966
Employee # E~ployee Name
TRACY BIGGS, TRACY L
Hours Rate Current Amt WH/~-~
Earnin s ~,
HOURLY z~.00 ~.00
HOURLYOT 0.00 19.50
Soc Sec # F~om To Check Dat~
196-58-3365 0~/08/02 04/13/02 04/19/02
2-~.00 SOCSEC
0.00 PA
FEDS
MEDICARE
22300017
2220002
226600PB
-- Current Amt
YT]
7.64 84.0.
4.90 80.1,
3.96 51.8'
2.73 35.7~
16.0:
POWER TECHNOLOGY INC.
Employee ~ Employee Name
TRACY BIGGS, TRACY L
~ Hours Rate
HOURLY 2~.00 ~-~.00
HOURLYOT 0.00 19.50
Soc Sec #
196-58-3365
Current Amt WHfDed
~-~.00 SOCSEC
47060
From To Check Date
04'/15/02 04/21/02' 04/26/02
Current Amt ~ YT 1['
16.93 ~
0.00
PA 7.64 91.6~
FEDS 4.90 85.04
MEDICARE 3.96 55.82
22300017 2.73 38.46
2220002 16.03
226600PB
Curr Amt Curr Ded N~
~ ~-~.16 236.84
YTD Earn YTD~Ded YTD Net Pay Check No.
~-~8.00 525.~-~ ~-~2.34
POWER TECHNOLOGY INC.
Employee ~ Employee Name
TRACY BIGGS, TRACY L
Soc Sec % FrPm To
196-58-3365 04/15/02 04/21/02
Rate Current Amt
~arninc/~_ Hours
HOURLY ~.00 ~.00
HOURLYOT 0.00 19.50
~-9~. 00
0.00
WHfDed
SOCSEC
PA
FEDS
MEDICARE
22300017
2220002
2266007B
47177
Check Date
05/03/02
Current Amt YT[
16~ 255~
7.64 99.3~
4.90 89.9~
3.96 59.7~
2.73 41.2]
16.0]
Curr Amt Curr Ded Net Pay
~6.84
2-~. 00 ~.16
POWER TECHNOLOGY INC.
Employee~ # Employee Name
TRACY BIGGS, TRACY L
Earnings Hours
HOURLY 21.00 13.00
HOURLYOT 0.00 19.50
YTD Earn YTD
4121.00 ~-~
Soc Sec % Fr
196-58-3365 04
Rate Current Amt
Ded YTD
L.82
Dm
/29/02
Net Paz Check No.
3559.18 ~
47323
To Check Date
05/05/02 05/10/02
WH/Ded
273.00 SOCSEC
0.00 PA
FEDS
MEDICARE
22300017
2220002
226600PB
Current Amt YT£
16.93 272.4-~
7.64 106.9(
4.90 94.8~
3.96 63.7~
2.73 43.9~
16.0]
POWER TECHNOLOGY INC.
Employee # Employee Name
TRACY BIGGS, TRACY L
HOURLY z~.uu
HOURLYOT 0.00
Soc Sec # From To
196-58-3365 05/03/02 05/14/.02
Curr Amt Curr Ded
2---~. 00 ~.16
POWER TECHNOLOGY INC.
4748
· Check ~Date.
05/17/02
Rate Current Amt WH/-~ ' Current Amt YTD
~.00 2--~.00 SOCSEC 16.93 28-~.42
19.50 0.00 PA 7.64 114.60
FEDS 4.90 99.74
MEDICARE 3.96 67.70
22300017 2.73 46.67
2220002 16.01
226600PB
Employee # Employee.Name
TRACY BIGGS, TRACY L
Earnings Hours
HOURLY 21.00 13.00
HOURLYOT 0.00 19.50
N~ YTD Earn YTD
236.84 4667.00 634
Soc Sec # Fr~
196-58-3365 05
)ed YTD Net Pa~ Check No.
14 4032.86 00047484
47599
To Check Date
'13/02 05/21/02 05/24/02
Rate Current .Amt
WH/Ded
273.00
· 0.00
SOCSEC
PA
FEDS
MEDICARE
22300017
2220002
226600PB
Current A~t YT£
16.93 306.35
7;64 122.24
4.90 104.64
3.96 71.66
2.73 49.40
16.01
CurrAmt
Curr Ded Net Pay YTD Earn
36.16 236.84' 4940.00
YTD~Ded/ YTD Net Pay CheCk No.
67~ 30
273.00
4269.70 0004759~
POWER TECHNOLOGY INC.
Employee # Employee Name
TRACY
Earnings
HOURLY ~.00 ~-~.00
HOURLYOT 0.00 19.50
BIGGS, TRACY L
Hours Rate Current Amt WH~
47738
Soc Sec # To Check Date
196-58-3365 05 0/02 05/26/02 05/31/02
~urrent Amt YTD
373.00 SOCSEC ~ ~.-~ 32-~.28
0.00 PA" 7.64 129.88
FEDS 4.90 109.54
MEDICARE 3.96 75.62
22300017 2.73 52.13
2220002 16.01
226600PB
Curr Amt Curr Ded Net Pay YTD Earn YTD
2--~.00 36.16 236.84 5213.00 7~
POWERTECHNOLOGYINC.
Employee # Employee Name
TRACY BIGGS, TRACY L
Soc Sec # Fro
196-58-3365 05/
Ded YTD Net Pay__Check No.
46 4506.54 0004-~
47878
m To Check Date
27/02 06/02/02 06/07/02
~ Hours
HOURLY ~-~.00 ~.00
HOURLYOT 0.00 19.50
Rate Current Amt WH/-~
234.00 SOCSEC
0.00 PA
MEDICARE
22300017
FEDS
2220002
226600PB
Current Amt YTD
~.51 337.79
6.55 136.43
3.39 79.01
2.34 54.47
1.00 110.54
16.01
Curr A~nt Curr Ded Net Pay YTD Earn
234.00 27.79 206.21 5447.00
yTD~ed YTD Net Pay Check No.
4712.75 00047878
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. 02-2015 CIVIL TERM
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this ~" day of /a~-U , 2002, between
Plaintiff, Tracy L. Biggs, who currently resides at 213 North Prince Street, Shippensburg,
Pennsylvania, Cumberland County, 17257, and Defendant, James W. Biggs, who resides at P.O.
Box 602, 306 Clay Street, Bay Minette, Alabama, 36507-4708, concerns the claims of Equitable
Distribution, Alimony, and Alimony Pendente Lite and is a full and final settlement of these
issues.
WHEREAS, Plaintiff, Tracy L. Biggs, hereinafter Wife, and Defendant, James W. Biggs,
hereinafter Husband, desire to enter into an agreement as to the claims of Equitable Distribution,
Alimony, and Alimony Pendente Lite, Wife and Husband agree to the following:
ASSETS
1. Husband will retain sole possession and ownership of the Ford Windstar, acquired
during the marriage, and will become solely responsible for repayment of the loan acquired to
purchase the vehicle.
2. Husband will also retain sole possession and ownership of the proceeds from the
2001 Federal Income Tax Refund in the amount of $1626.00.
3. Husband will also retain sole possession and ownership of the washing machine,
dryer, and refrigerator.
4. Husband agrees to pay Wife the total amount of $5500, in installments of $300
monthly, beginning in September of 2002. ..~W-o° ,~ c) ~ -2. o o Z_
5. The remaining property acqUirex~ during the marriage shall remain as already
divided.
SPOUSAL SUPPORT, ALFMONY PENDENTE LITE, ALiMON~'
6. Both parties waive spousal support, alimony pendente lite and alimony and agree
not to request them in the future.
REMEDIES
7. If either party breaches any provision of this agreement, the other party shall have
the rights, at his or her election, to sue for damages for such breach and seek any other remedy
allowed under contract law or 23 Pa.C.S.A. §3502(e).
8. Any party breaching this agreement shall be responsible for the payment of all legal
fees and costs incurred by the other in enforcing his or her rights under this agreement, or seeking
such other remedy or relief that may be available to him or her.
9. Waiver by either party of any such breach of any provision of this agreement shall
not be deemed a waiver of future breaches of that provision or any other provision of this
agreement.
INCORPORATION
10. The parties intend this Agreement to be incorporated, but not merged, into the
divorce decree.
11. The parties intend to be legally bound by the terms of this agreement and that it be
filed with the Court as satisfaction of the Equitable Distribution, Alimony, Alimony PendenteLite
Spousal Support claims. However, the parties agree that failure to file this agreement with the
court shall have no effect on the parties' obligations or the ability to utilize any remedy for
enforcement.
TRACY L. BII2GS, ' · -
Plaintiff
Jennifqf l~verly~~
Certifldd Legal Intern
THg~/~S ~i. PLACE
LUCY JOHNSTON-WALSH
Supervising Attorney
Attorneys for Plaintiff
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
/--/JAMES W. BIGGS, ~
Defendant
TRACY L. BIGGS, :
Plaintiff :
V. :
:
JAMES W. BIGGS, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
IN DIVORCE
NO. 02 - 2015
CIVIL TERM
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern at the Family Law Clinic, hereby certify that I
have served a true and correct copy of the attached Marital Settlement Agreement upon James
W. Biggs of 306 Clay Street, Bay Minette, Alabama 36507-4708 by depositing a copy of the
same in the U.S. mail, first class, postage prepaid, on the 7th day of August, 2002.
Date' -
JennifgfJI-l~erly
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
TRACY L. BIGGS
Plaintiff
VS.
JAMES W. BIG~S
Defendant
) Doc~t Number
)
) PACSES Case Number
)
) Other State ID Number
02-2015 CIVIL
531104586
AND NOW, to wit on this
ORDERED that the (~) Complaint for Support or
fried on
matter is dismissed without prejudice due to:
THE PARTIES PRIVATE AGREEMENT.
CONSENT ORDER
8TH DAY OF AUGUST, 2002 IT IS HEREBY
O Petition to Modify or O Other
4/25/02 in the above captioned
COSTS PAID BY THE COUNTY OF CUMBERLAND.
O The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
Consemed:
Date
Plaintiff Signature
Date
Defendant Signature
BY THE COURT:
JUDGE
Form OE-505
Service Type M Worker ID 21004
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
:
· NO. 02-2015 CIVIL TERM
MARITAL SETTLEMENT AGREEMEN-T
THIS AGREEMENT, made this l~Yq~ day of ./~t/~j4/t~' , 2002, between
Plaintiff, Tracy L. Biggs, who currently resides at 213 North Prince Street, Shippensburg,
Pennsylvania, Cumberland County, 17257, and Defendant, James W. Biggs, who resides at P.O.
Box 602, 306 Clay Street, Bay Minette, Alabama, 36507-4708, concerns the claims of Equitable
Distribution, Alimony, and Alimony Pendente Lite and is a full and final settlement of these
issues.
WHEREAS, Plaintiff, Tracy L. Biggs, hereinafter Wife, and Defendant, James W. Biggs,
hereinafter Husband, desire to enter into an agreement as to the claims of Equitable Distribution,
Alimony, and Alimony Pendente Lite, Wife and Husband agree to the following:
ASSETS
1. Husband will retain sole possession and ownership of the Ford Windstar, acquired
during the marriage, and will become solely responsible for repayment of the loan acquired to
purchase the vehicle.
2. Husband will also retain sole possessio, n and ownership of the proceeds from the
2001 Federal Income Tax Refund in the amount of $1626.00.
3. Husband will also retain sole possession and ownership of the washing machine,
dryer, and refrigerator.
4. Husband agrees to pay Wife the total amount of $5500, in i.nstallments of $300
monthly, beginning in September of 2002. ,~o ,,~ c_) a ~ a o Z_ ~-
5. The remaining property acquired during the marriage shall remain as already
divided.
SPOUSAL SUPPORT, Ai,~rvlOi~Ff ~NDE?~i-TE LITE, ALEvION~'
6. Both parties waive spousal support, alimony pendente lite and alimony and agree
not to request them in the future.
REMEDIES
7. If either party breaches any provision of this agreement, the other party shall have
the rights, at his or her election, to sue for damages for such breach and seek any other remedy
allowed under contract law or 23 Pa.C.S.A. §3502(e).
8. Any party breaching this agreement shall be responsible for the payment of all legal
fees and costs incurred by the other in enforcing his or her rights under this agreement, or seeking
such other remedy or relief that may be available to him or her.
9. Waiver by either party of any such breach of any provision of this agreement shall
not be deemed a waiver of future breaches of that provision or any other provision of this
agreement.
INCORPORATION
10. The parties intend this Agreement to be incorporated, but not merged, into the
divorce decree.
11. The parties intend to be legally bound by the terms of this agreement and that it be
filed with the Court as satisfaction of the Equitable Distribution, Alimony, Alimony PendenteLite
Spousal Support claims. However, the parties agree that failure to file this agreement with the
court shall have no effect on the parties' obligations or the ability to utilize any remedy for
enforcement.
TRACY L. BI(JGS,
Plaintiff
Jennif~ Fl~verly ~3
Certifl~/d Legal Intern
OBI~]~I~, RAINS
THO~IAS M. PLACE
LUCY JOHNSTON-WALSH
Supervising Attorney
Attorneys for Plaintiff
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
/
~JAMES W. BIGGS, ~
Defendant
AUG 1 2,002
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
'.
: NO. 02-2015 CIVIL TERM
:
ORDER OF COURT
ANDNOW, this)$~t4~ dayof ~ ,2002, with the consent of the
parties, the attached Marital Settlement Agreement is hereby made an Order of Court.
BY THE COURT,
CC~
fFamily Law Clinic, Attorneys for Plaintiff
,/James W. Biggs, Defendant
P.O. Box 602
306 Clay Street
Bay Minette, Alabama, 36507-4708
(251) 937-5402 or (251) 232-8553
~/An,kCjNN~d
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CA/%~Y QUESENBERRY, :
Appellant :
:
V. :
:
COMMON-WEALTH OF PENNSYLVANIA:
DEPARTMENT OF TRANSPORTATION:
Appellee : 02-2015 CIVIL TERM
ORDER OF COURT
AND NOW, this 23rd day of September, 2002, it
appearing to the Court that we know the appellant in this case,
the Court Administrator is to reassign this matter to another
judge. The parties will be notified as to the appropriate date
for hearing. Pending the rescheduled hearing, the supersedeas
shall remain in effect.
Edward E. Guido, J.
George Kabusk, Esquire
For the Commonwealth
Candy Quesenberry, Pro se
it
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: IN DIVORCE, EQUITABLE DISTRIBUTION
: NO. 02- 2015 CML TERM
AFFIDAVIT OF CONSENT
2002.
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 25,
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 tree 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.
13tte - '
J~~es W. Biggs, Defenc~ant
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION -
: IN DIVORCE, EQUITABLE DISTRIBUTION
:
: NO. 02 - 2015 CIVIL TERM
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Imern at the Family Law Clinic, hereby certify that
on this 2~ day of October, 2002, I am serving a true and correct copy of the Defendant's Affidavit
of Consent on James W. Biggs of P.O. Box 602, 306 Clay Street, Bay Minette, Alabama 36507-
4708, by depositing a copy of the same in the United States Mail, postage prepaid.
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
71%243-2968
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
IN DIVORCE, EQUITABLE DISTRIBUTION
NO. 02- 2015 CIVIL TERM
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 thc
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
W. Biggs, Defendant
RECEIVED SEP 1 3 21 [12
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION -
: IN DIVORCE, EQUITABLE DISTRIBUTION
:
: NO. 02 - 2015 CIVIL TERM
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern at the Family Law Clinic, hereby certify that
on this 2nd day of October, 2002, I am serving a tree and correct copy of the Defendant's Waiver
of Notice of Intention to Request Entry of Divorce Decree on James W. Biggs of P.O. Box 602,
306 Clay Street, Bay Minette, Alabama 36507-4708, by depositing a copy of the same in the
United States Mail, postage prepaid.
Jen~l:l~V~c~tifi~Sgal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
TRACY L. BIGGS, :
Plaintiff :
v. : CWIL ACTION
: IN DIVORCE
JAMES W. BIGGS, : NO. 02 - 2015
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL TERM
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above matter, having been granted divorce
from the bonds of matrimony on the 23rd day of October, 2002, hereby elects to retake and
hereafter use her previous name of Tracy Lea Paffos and gives this written notice avowing her
intention to do so pursuant to the provisions of 54 Pa. C.S. §704.
T~5~_CY LEA BIGGS - ! r
Wishes To Be Known As:
TP,~CY LEA PAFFOS
COMMONWEALTH OF PENNSYLVANIA :
:
COUNTY OF CUMBERLAND : SS.
On the ~Sh0-/~/ day of/~/~~//~ , 2002, before me, a Notary Public,
personally appeared Tracy L. Biggs, known to me to be the person whose name is subscribed to
the within document, and acknowledged that she executed the foregoing for the purpose therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal.
NOTARY PUBLIC
Notarial Seal
Pamela R. Knowlton, Notary Publlo
Carlisle Borough. Cumberland County
My Commission Expires November 9, 2006
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, EQUITABLE DISTRIBUTION
: NO. 02- 2015 CIVIL TERM
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 ora 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 tree and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. CS. §4904 relating to unswom
falsification to authorities.
ate
Tracy L. Biggs,,Plaintiff
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: IN DIVORCE, EQUITABLE DISTRIBUTION
: NO. 02- 2015 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 25,
2002.
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. §4904, relating to
unsworn falsification to authorities.
Da~e
Tracy L. Biggs, Plaintiff
TRACY L. BIGGS,
Plaintiff
JAMES W. BIGGS,
Defendant
To the Prothonotary:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION
: IN DIVORCE
:
: NO. 02 - 2015 CIVIL TERM
.
PRAECIPE TO TRANSMIT RECORD
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 (c) of the Divorce
Code.
2. Date and manner of service of the complaint: Defendant was served on May 13, 2002
by certified mail, restricted delivery, return receipt requested. Proof of Service was filed on May
20, 2002.
3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the
Divorce Code: by the plaintiff, October 15, 2002; by the defendant, September 3, 2002.
4. Related claims pending: none.
5. Date plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary:
October 16, 2002.
Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the
prothonotary: October 16, 2002.
Jennif~-Ieverly ~)
C~ed~Legal Intern
TR~BOEM~RT~. ~i~AsCE
LUCY JOHNSTON-WALSH
Supervising Attorney
FAMlLY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717)243-2968
IN THE COURT OF COMMON PLEAS
Tracy L. Biggs,
Plaintiff
VERSUS
James W. Biggs,
Defendant
CF CUMBERLAND COUNTY
ST/~ TE Of PENNA.
02 - 2015
NO.
DECREE IN
AND NOW,
DIVORCE
DECrEed That Tracy L. Biggs
, PLAINTIFF,
AND James W. Biggs . 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.
ATTEST:
PROTHONOTARY