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Home My WebLink About06-5721 .. Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE Stacey Canady, Defendant :'NO.O.- S?~I 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, LA WYER'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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION 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. . Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE Stacey Canady, Defendant :' NO. ob - ~7;tf CIVIL TERM DIVORCE COMPLAINT The plaintiff, Billy Canady, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. ~~3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Billy Canady, who currently resides at 26 Kerrs Avenue, Carlisle, Cumberland County, PA 17013 since June 2006. 2. Defendant is Stacey Canady, who currently resides at 651 Erford Rd., Camp Hill, Cumberland County, PA 17011 since October 2005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing ofthis complaint. 4. Plaintiff and Defendant were married on September 24, 1994 at Harrisburg, Dauphin County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since the beginning of October 2005. 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. Date ~fj O(p ~~. Suzttnne Sekutowski Certified Legal Intern ~{f~~-~ THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney F AMIL Y LA W 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. 94904, relating to unsworn falsification to authorities. Date C( -dS T;I;; Plaintiff ~ c;"? ~ /' Billy Cady ~ , -cJ o <;; r-:) c::::> c::.", 0" cf> rn -'t) 1"-' U) 'J :-fl .-\ :r: -("', PIC ~.~ \~;J :.).Cl :--.~ -'1' j :;;t1 :;:.. '~l?~:' :~)(r\ ..:..\ ~? :E. - -- N -J Billy Canady Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY ; NO. rb-C~:ll CIVIL TERM Stacey Canady Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Billy Canady, 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~ fA (om Respectfully submitted, ~~$' Suz e Sekutowskl Certified Legal Intern ~JL2~-~ ROBER . . INS . THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 .717-243-2968 ,.....~ g 0 0.... -n ~ ~-r' -0 rn f-: N !Ii \.D '1" C~~ -1'-, --~ " N CO Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE Stacey Canady, Defendant : NO. 06 - 5721 CIVIL TERM CERTIFICATE OF SERVICE I, Suzanne Sekutowski, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Stacey Canady, residing at 651 Erford Rd., Camp Hill, P A 17011, 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 Stacey Canady, on the the 13th day of October 2006 as evidenced by the attached green card. ()~+. I ~ ;}(t)~ Date ' -4 A,~' Suz~towski Certified Legal Intern Robert Thomas . Place Anne Macdonald-Fox Lucy Johnston-Walsh Megan Riesmeyer Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 C> C) "-.) ~ + ~ is ~ ~ 0-. ...~ 7 ;.,: ~ ~.:rJ ~ --~. ..:.. ~ "'\! :t~ f~:~~. ~ '3h= ..f"'ro"" :i.:~' -.'" :;"':-'1 ,,'!.:' ~ YJ fi * II :5 C) a I'\) ~ (, .." .0 cJ:J: r . (") c ~ m ~ -of Ul ~ c.n . 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. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: i~?? ~Lar ./ Lr/;n/ ,e,/4 ~~ //I/71J// 3. Service 'I}tpe ~lfled Mall 0 Expl'8l8 Mall o Registered ~eturn Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~es 2 7005 0390 0003 2632 2620 PS Form 3811 , July 1999 102595-99-M-1789 Domestic Return Receipt Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LA W : IN DIVORCE . Stacey Canady, Defendant : NO. 06-5721 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 99 3301(c) of the Divorce Code was filed on 9/29/06. 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. 94904, relating to unsworn falsification to authorities. Date 1- ;{8 -() 1 , H~ (') c ~ -utu rnrn -:;;""..-'v.-, ~$'." -< ' r-: I~~ z ::;1 ... ,..." = = -..I .." I"T1 co ~ ~:n -uhl :n9 90 :?-r ':J ..,.1 -0.,..(") Om ~ :n -< (Jl -0 X W .. o Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE Stacey Canady, Defendant : NO. 06-5721 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6330l(c) OF THE DIVORCE CODE I. 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 !~~-.ol ifI~ /Billy ady, Plain Iff (") c ~ -ocr; ITifI..( -;?" ..,~ :!=;;f-' ~L r" <::: ~~~-) S;C Z :< g ~ ~i -~-d ~ 2~ o CiJ ~ o ~ N Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LA W : IN DIVORCE Stacey Canady, Defendant : NO. 06-5721 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under SS 3301(c) of the Divorce Code was filed on 9/29/06. 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. 94904, relating to unsworn falsification to authorities. Date J / I q / () 'I . 2 ~ -r.ll'O rnrr, :?(' (fJ ~'. -~ ~' ~c:: 2';( .~;;~:: ~ r-.,:) ~ ..." ~ - cJ\ -0 :.;: w .. o N ~ ~':::n ....hj ~~ ~"'f' -... B -\Ii 9 ~ Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE Stacey Canady, Defendant : NO. 06-5721 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(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 i/,q jo '7 o ~ :5>. -0 rri Gr+ ~~ (;:.~ (r~" :' .....t:"......-l-:.'; !:;2Ci ~(:~ ,""': (..." )>c: ~ .....:l = c:::;) --' .." I'T1 Q::) U1 ~ :t!::n 011_ -om :.r; t;J o~- ~ nO' . ~, ( - -0 Om ~ ~ -0 3: ':? o N Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION-LAW : DIVORCE Stacey Canady, Defendant : NO. 06-5721 CIVIL TERM CERTIFICATE OF SERVICE I, Suzanne Sekutowski , Certified Legal Intern, Family Law Clinic, hereby certify that I will serve a true and correct copy ofthe Affidavits of Consent, Waivers of Notice and Praecipe to Transmit Divorce on Stacey Canady, residing at 651 Erford Rd., Camp Hill, PA 17011, by depositing a copy of the same in the United States mail, regular, first class on this 15th day of February 2007. 2/{S/07 Date Suzann ekutowski Certifi d Legal Intern ~ ,1 ~d ~/~ Anne McDonald-Fox, Esq. Lucy Johnson-Walsh, Esq. Thomas M. Place, Esq. Robert E. Rains, Esq. Megan Riesmeyer, Esq. Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 (") c <: "Oct; ~~*! U? " ~e )>,,, .<~ ('->~; >-c z =<: r--:> <::::) <::::) --a ..." ["t1 c::g ~ ~~ m :89 06 -3-n "J_ -n ~- '5 ?rl ~ ~ CJ'I -0 :x W .. <::> N -.. Billy Canady, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY Stacey Canady, Defendant : No. 06-5721 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 93301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Stacey Canady, October 13, 2006. 3. Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce Code: by plaintiff- January 20,2007; by defendant-January 19,2007. 4. Related claims pending: none 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: February 15,2007. Date Defendant's Waiver of Notice was filed with the Prothonotary: February 15, 2007. d 11.5/07 , Date ~ rt Suz e Sekutowski Certified Legal Intern ^/J ~ it1~lt .f~ OBE T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTOB- WALSH MEGAN RIESMEYER Supervising Attorneys F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, P A 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff a c tL "'Q (' \ IJi -; ~.t.,." to ). -~'c., \........ ~ ~it~~ 'poc ~ - ~ ~ '3~ .-n b3 .'. - ~~Q c.Jl ~~i <:2 !!.1~ ,.", /- " a :::::-\ ~ ..." :::s- ea o r'> ?~~~ ~~~~~~~~ ~~~~~~~~~~~~~~~ ~ ~ ~ '+; '+; '+; '+; ~ '+; ~ '+; ~ '+; ~ ~ + '+; ~ ~ '+; '" ~ ~ '+; + '" '" ~ '+; ~ '+; '+; + '+; ~ + + ~ '+; ~ + + + '" '" '" '" "" "" + + + '" + + + + + + + + + + '" + '" + + ~ '+; ~ + + '+; + + + ~ + '+; + + + + '+; + + '" + ~ + + '" '+; + '" + '" + + + '+; + ~~~~~~~~~~~~~~~~~~~~~~ ~ "''+;~~'''~'+;'+;~~~'+;~~'+;'+;~'+;'+;~~'+;~~~'+;~~~~ IN THE COURT OF COMMON P AS OFCUMBERLANDCOUNTY STATE OF Billy Canady Plaintiff VERSUS Stacey Canady Defendant PENNA. No. 06-5721 DECREE IN DIVORCE AND NOW, F e.\l'"~'#l , 1(Jt) 1 , IT ISO ~ '" + ~ ~ + ~ ~ '" + '" + '" + '" + + + '" '" + '" ~ ~ ~ + + '+; '" + '" + + ~ + + + '" '+; + + '" + '" + ~ ~ + ~ + ~ + +::f. ~:f.:f.:f.:f +:+::+::+::.f~ l..D DECREED THAT Billy Canady AND Stacey Canady DANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIM HICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL OR y ~ R HAS NOT None By THE COURT: PRO ONOTARY ~~~~~~~~~+~:f.++++++~+++++++++++:+~+~+~+~++++ J. ;::fip f ~ 9P')!u, c.P 1 . [ 7~ '! ~~,J~ LO.1E " . -----