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Home My WebLink About06-6140Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW IN DIVORCE Satecha Townsend, CIVIL TERM Defendant : N0.06- (o ~ ~~ 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 ent lose mone t ooru roperty or otherarights important t yours these papers by the plaintiff. You may Y p 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 ES BEFORE A DI ORCE~OR ANNULMENTOIS GRANTED, LAWYER'S FEES OR EXPENS YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIO TELEPHONE THE OFFICE SETO ORTH BELOW NOT HAVE A LAWYER, GO TO THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WI ELI BOLE PERSONS AOT A REDUCED FEE OR NO F EE.FER LEGAL SERVICES TO 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 availanablements must be made at lea t 72 hours priorf for any h wring please contact our office. All arr g or business before the court. You must attend the scheduled conference or hearing. Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW IN DIVORCE Satecha Townsend, CIVIL TERM Defendant : NO. 06- (~ ~ ~{~ DIVORCE COMPLAINT The plaintiff, Lee Thomas Townsend, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S 3301(d) OF THE DIVORCE CODE Plaintiff is Lee Thomas Townsend, who currently resides at 1422 Bradley Drive, Carlisle, Cumberland County, PA 17013 since 2000. 2. Defendant is Satecha Townsend, who currently resides at 1608 Broomfield Road, Cheraw, Chesterfield County, SC 29520 since 1993. 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 or about August 19, 1996 at Chesterfield, Chesterfield County, South Carolina. 5. Plaintiff and Defendant have lived separate and apart since November of 1999. 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. <~~~ Lauren McHale Certified Legal Intern ~/~ll (G~ ~ ' r ~~~~~' 2 ROBE T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY 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. §4904, relating to unsworn falsification to authorities. ~~ Date i/; 01 ~ /~ G Plaintiff ~ y~~ , ~ ~~ l~~- -~~`~' Lee Thomas Townsend Q ° -~, ~= ~ o ''' ~ rn ~ :.: -~~ ~ .v c~ -c; -n ~~ ~ ~ . T, 1> ~= __,_ ~ rn _;~ -> _: N -..J Lee Thomas Townsend : IN THE COURT OF COMMON PLEA5 OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW IN DIVORCE Satecha Townsend Defendant. : N0.06 - L~~ CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in November of 1999, and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. 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. 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 zr~%,r ~ C/..~",.~...r1. ~~;~~ Lee Thomas Townsend Plaintiff C'~ ~ c~ ~~ ' ,:1 rr t;zf . ~ - "'1 F7'~r O ~ _ t._; _. r _ ~T} ...~ R,) J ~..1 --G Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW IN DIV ORCE Satecha Townsend Defendant NO. 06-fo~~~CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Lee Thomas Townsend, Plaintiff, to proceed in forma paupens. The Family Law Clinic, attorneysthe cos P and that we are providing freeelegal servlice to that we believe the party is unable to pay the party. Respectfully submitted, Date I D • 1b ' ~~ ~ ~~~n ~~~ Lauren McHale Certified Legal Intern ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 w r_ _ ~., -~; i `; c~ ~.zr; ~ ~ ,. ~ , _~= ' " ~ ~ r ~ C1 ` _ ~ f y 'f 'r.. __ ' - r I'I ~~t q "C ~ Lee Thomas Townsend, Plaintiff v. Satecha Townsend, Defendant IN THE COURT •OF Ci:~NIMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 06- 6140 CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. Date - ~s weC~~ live be~~' Ise hQs~'} df ~ho~ST[x~~.: Defendant ~ ICI ~~2.9g a1s~ C~~~`- `f ~(. alp M a_.+~°~.~1 Satec~a Tc ~~ O ~ ~- pg *~J~~uM ~I~°3 8o Lee ~y G~c~ Sole ~e .d~Yi ,a~c~'/~/ ~ CJ9~1wY,~V' t`: -- ~' ~-'~ - ~: _ G~ _ ~~ f'3 _'-} ~7 ir=;' i V::) . "~ ._ -_ _, .. ~* ~ -- :c'; ~~ .. ':. i ='j 6'~; -~C Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE Satecha Townsend, Defendant : N0.06- 6140 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 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 INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 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. Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW TN DIVORCE Satecha Townsend, Defendant : N0.06- 6140 CIVIL TERM AMENDED DIVORCE COMPLAINT The plaintiff, Lee Thomas Townsend, by his attorneys, the Family Law Clinic, amends his previously filed divorce complaint as follows: DIVORCE UNDER 23 Pa.C.S. 3301(d) OF THE DIVORCE CODE Plaintiff is Lee 'Thomas Townsend, who currently resides at 1422 Bradley Drive, Carlisle, Cumberland County, PA 17013 since 2000. 2. Defendant is Satecha Townsend, who currently resides at 821 S. Church Street, Lot 4, Cheraw, Chesterfield County, SC 29520 since 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 or about June 29, 1991 at Chesterfield, Chesterfield County, South Carolina. 5. Plaintiff and Defendant have lived separate and apart since September of 1998. 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. Samara Gomez Certified Legal Intern ~~ ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY 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. §4904, relating to unsworn falsification to authorities. Date (~ ~ Plaintiff Lee Thomas Townsend C"") r-.~ C .` "`~ '~ ::~ _77 "T'f -~ - f.~ , ~:ve ~- F'~ l~ ~.:_: ._ ~~ _, ~~ :~J CS' '~ Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Satecha Townsend, Defendant N0.06- 6140 CIVIL TERM CERTIFICATE OF SERVICE I, Samara Gomez, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Amended Divorce Complaint on Satecha Townsend, residing at 821 South Church Street, Lot 4, Cheraw, S.C. 29250 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 Satecha Townsend, on the the 13 ~' day of February 2007 as evidenced by the attached green card. Samara Gomez Certified Legal Int/e~rn Megan d2iesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 N C 3 ~ `~ . -n ~' -~, ! .~ ~~n+y /YJ f ry 17 I - . -~ f.~,, ., } { .-+ } _ 1 ( ) )' ~ '=.a' i. '~ ~ + ~` `^ f ,s ^ Prlnl y~r~ ~ ' sc 1tM~t wr- ~rrn tMl1~!' pia yap,: ~ ^ AtboR ~liMl c~M~ 1~r ~ ~t ~ cr on gtr tF prr~hll~. 'R to diii~r i~on- Illm t? ~. ~e~O1s AddaMed w: I[ 1T$ awn' ~Y 1rddM~s bbwt !~ No L.~ t y ~. s.+~,.~ a 9~ s~ o a: 2. ArtlCle Number rirr ~7[3~15 039a OOQ3 2632 -5393 PS Form 3 ~ . ~ po~1~~Yr,,,,yMr~gt o ~... N~ ~~ ~.~. ~ ~• ~ ~,~ to2sss-az-M-~sao f Lee Thomas Townsend, Plaintiff v. Satecha Townsend, Defendant IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE N0.06- 6140 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 and separation for two years under § 33010 of the Divorce Code. 2. Date and manner of service of the complaint: First Class U.S. Mail with an Acceptance of Service form. Defendant signed the Acceptance of Service and acknowledged receipt of the Divorce Complaint on December 6, 2006. Additionally, the Amended Divorce Complaint was served on Defendant via certified mail, return receipt requested, restricted delivery. Service was accomplished on February 13, 2007. 3. Complete either paragraph (a) or (b): (b)(1}Date of execution of the affidavit required by § 3301(d) of the Divorce Code: October 20, 2006; (2) Date of filing and service of the plaintiff s affidavit upon the respondent: Filed on October 20, 2006 and served December 6, 2006. 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: Service by First Class U.S. Mail on April 18, 2007 . i Date y (l~,(~_ /~ Samara Gomez Certified Legal Intern ~~~ ~~ Rob_-- e~ains, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire Megan Riesmeyer, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ,~ t t ~~~r~1~1~~~J~~~~ z ~ ~~~ ~~ ~ ~ ~~n ~ooz ,~~~ ,~.~ ~ ~ ~o ~~ _` Lee Thomas Townsend, Plaintiff v. Satecha Townsend, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : 1N DIVORCE N0.06- 6140 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file acounter-affidavit to the § 3301(d) affidavit. Therefore, on or after April 18, 2007, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or acounter-affidavit by the above date, the court can enter a final decree in divorce. Acounter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE 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, PA 17013 (717) 249-3166 •l AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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. ~i'~~'h~nSNPJ~ z ~ ~~~ ~~ ~ ~ ~~~ ~d~~ ,~~`~~GI~~~~~1~~~ 31-x. 3 Lee Thomas Townsend, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW. IN DIVORCE Satecha Townsend, Defendant : N0.06- 6140 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): () (a) I do not oppose the entry of a divorce decree. O (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): () (i) The parties to this action have not lived separate and apart for a period of at least two years. () (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): () (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. VERIFICATION I verify that the statements made in this counter-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 Satecha Townsend z s ~~t ~~ ~ ~ ~~n Boaz i10Y~4'i~i.d~:.1.~+L~ ~fu. ~Q I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. = ~~- - . = Plaintiff NO. oti-tip 4n VERSUS Defend DECREE IN DIVORCE AND NOW, ~ ~O ~~~~ lT iS ORDERED AND DECREED THAT Lee Thc~maG Tnwn~en.C~ PLAINTIFF, AND ~ata~fi~ T..~`~nsen-sl 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; * ~r V BY THE y.OURT: ATTEST: \ J . PROTHONOTARY -~~ ~ ~ '.~et~ ~°' h s ~~ ~ ~o ~ s t i ca~< < ~ Ate, ~~~ ~~~ 4' ~1 ~~aT" F: st .,~ ~\ ~~