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Home My WebLink About06-7121w. i Louann S. Speese-Stanley, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Henry H. Stanley, Defendant : NO.06-l? j 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. Louann S. Speese-Stanley, Plaintiff V. Henry H. Stanley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 06- 71a / CIVIL TERM DIVORCE COMPLAINT The plaintiff, Louann S. Speese-Stanley, by her attorneys, the Family Law Clinic, sets forth the following cause of action for divorce: DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Louann S. Speese-Stanley , who currently resides at 110 East Main Street, Shiremanstown, Cumberland County, PA 17011, since 2001. 2. Defendant is Henry H. Stanley, whose last known address is 460 Campbelltown Rd., Fl 2, Palmyra, Lebanon County, PA 17078. 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 December 23, 2001 at New Cumberland, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since August 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 t Suzmldl a Sekutowski Certified Legal Intern 71U"_ Robe ains 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 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. 6uEI Date ? Plainti S. . Sp se-Stanley n ? c? L ' _ " }fv! -! Louann S. Speese-Stanley Plaintiff V. Henry H. Stanley Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 06--7 IyICIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Louann Speese-Stanley, 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 j o'7?J1 I o Respectfully submitted, Suz Sekutowski Certified Legal Intern ROBE S THOMAS PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C's ^' ) r Louann S. Speese-Stanley, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Henry H. Stanley, Defendant : NO. 06-7121 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. Aw Louann S. Speese-Stanley, : IN THE COURT OF.COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Henry H. Stanley, Defendant : NO. 06- 7121 CIVIL TERM AMENDED DIVORCE COMPLAINT The plaintiff, Louann S. Speese-Stanley, by her attorneys, the Family Law Clinic, hereby amends the Divorce Complaint filed on December 14, 2006 and sets forth the following cause of action for divorce: DIVORCE UNDER 23 Pa.C.S. §3301(c) OF THE DIVORCE CODE 1 2. 3. 4. Plaintiff is Louann S. Speese-Stanley, who currently resides at 110 East Main Street, Shiremanstown, Cumberland County, PA 17011, since 2001. Defendant is Henry H. Stanley, who currently resides at 110 East Main Street, Shiremanstown, Cumberland County, PA 17011. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on December 23, 2001 at New Cumberland, Cumberland County, Pennsylvania. 5. Other than a prior Divorce complaint filed under this docket on December 14, 2006, there have been no previous filings for divorce or annulment. This complaint is intended to supersede and replace the prior complaint filed in this matter. i 6. The marriage is irretrievably broken. 7. 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. 0? 3v7 Da en ertified Legal Intern Az- Robert' 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 r 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 Plaintif " /Ax-" w ouann S. Speese tanley {) ?, ~ __., c_.. ,? ??= ?? , -? _ ? _,;; ,? -,. ? -?; -- . ' _ t . ;?, , a . _ . _ , „ . ;: ? . :_c= ? Louann S. Speese-Stanley Plaintiff v. Henry H. Stanley Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 06-7121 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Louann Speese-Stanley, 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 V, 1( 1 Respectful submitted, W i led Legal Intern ROBE INS 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 ? C ?..? ? Q , r- - _..J _ . . .,_' .. ?? J? ? LOUANN S. SPEESE-STANLEY, Plaintiff vs. HENRY H. STANLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-7121 CIVIL ACTION IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint in the above-captioned case. Irene Hwan Certified Legal Intern Robert E. Rains Thomas M. Place Anne MacDonald-Fox Megan Riesmeyer Lucy Johnston-Walsh SUPERVISING ATTORNEYS FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Attorneys for Plaintiff H t`?J . ? ... ' :: :7 f C? ?e - r r; :. __ . ?.."?j r rt -, ?'` LOUANN S. SPEESE-STANLEY, Plaintiff V. HENRY R. STANLEY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 06-7121 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow LOUANN S. SPEESE-STANLEY, 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 l 02 o'Z C) Respectfully submitted, 'JA Takara Strong Certified Legal Intern A NALD-F Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: (717) 243-3639 Attorneys for Plaintiff ?:?, ,_?? - _??, _ ?-=, ,, = ,.,., - -,; x ,.. =,r tom: N .,.? r-? ?, f ??? i'?j Louann S. Speese-Stanley, Plaintiff V. Henry H. Stanley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 06-7121 CIVIL TERM SECOND AMENDED DIVORCE COMPLAINT The plaintiff, Ms. Louann S. Speese-Stanley, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: COUNTI DIVORCE UNDER 23 Pa.C.S. §§3301(,cc) AND 3301(d) 1. Plaintiff is Ms. Louann S. Speese-Stanley, who currently resides at 35 S. West Ave Shiremanstown, Cumberland County, Pennsylvania 17011, since 2008. 2. Defendant is Henry H. Stanley, who is believed to reside at either 2706 Cheverly Drive, Cheverly, Prince Georges County, Maryland, 20785, or at 2532 Chain Bridge Rd apartment 102, Vienna, Fairfax County, Virginia, 22181. 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 December 23, 2001 at New Cumberland, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since November 2008. 6. Plaintiff has filed a prior Divorce Complaint under this docket on December 14, 2006. Plaintiff has also filed an Amended Divorce Complaint under this docket on July 5, 2007. Otherwise, there have been no prior actions for divorce or for annulment between the parties. This complaint is intended to supersede and replace the prior complaint filed in this matter. 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. COUNT II EQUITABLE DISTRIBUTION UNDER 23 Pa.C.S. % 3502 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. During the course of the marriage, the parties acquired marital assets and debts subject to equitable distribution under Section 3502 of the Divorce Code, including, but not limited to the following: a) 1997 GMC Truck, financed through Belco Community Credit Union. The loan pay-off amount of the 1997 GMC truck is $3, 3826.72; this amount is effective until March 20, 2009. WHEREFORE, Plaintiff request the court to enter a decree of divorce and to equitably divide the debts between the parties and grant such other relief as the Court deems just. D& /01 Date ,y f TrudiA M,..-Kirby Certifiegal Intern ROBE AT 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 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing second amended 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. ,n 1 Dat duann S. Spe se-Stanle , Plaintiff U THE 2009 APR -a Air! 10: 59 {? f Louann S. Speese-Stanley, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Henry Stanley, Defendant NO. 06 - 7121 CIVIL TERM CERTIFICATE OF SERVICE I, TrudiAnn Kirby, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Henry Stanley, residing at, 2532 Chain Bridge Rd. Apartment #102, Vienna, Virginia, 22181,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 Henry Stanley, on the the 21 st day of April, 2009, as evidenced by the attached green card. i n' P_ o- o Ln rq 0 C3 C3 a -21 a ? r O O r LL T M. Ki C e A d gal Intern Anne Vfau6umald-Fox Robert E. Rains Thomas M. Place Megan Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 FILED-CD =-.?J-: OF THE PC`- "TAI Y 2609 APR -44 °i 12: 36 Louann S. Speese-Stanley, Plaintiff, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE Henry H. Stanley, Defendant. NO. 06-7121 CIVIL TERM PRAECIPE FOR DISCONTINUANCE To The Prothonotary: Pursuant to Rule 229 of the Pennsylvania Rules of Civil Procedure, kindly discontinue Count II for Equitable Distribution in the Second Amended Divorce Complaint, docketed at 06 - 7121 and filed on April 6, 2009. Date: d am D. Truong Certified Legal Intern ROB T E. RAINS CE Y c _ry THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney E.f] cv ra FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Counsel for Plaintiff Louann S. Speese-Stanley, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE Henry H. Stanley, Defendant. : NO. 06-7121 CIVIL TERM CERTIFICATE OF SERVICE I, Lam D. Truong, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe For Discontinuance on Henry Stanley, residing at 2532 Chain Bridge Rd., Apartment #102, Vienna, Virginia 22181, by depositing a copy of the same in the United States Mail, first class, postage prepaid, on the 25 h day of February 2010. am D. Truong Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 n Czl 77 N U! Louann S. Speese-Stanley, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE n Henry H. Stanley, Defendant. : NO. 06-7121 CIVIL TERM AFFIDAVIT OF CONSENT i 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was file r _.Api6, 2009. C -4 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. i Date a2? /v S. Spee tanley, Ptiin-tifT---J Louann S. Speese-Stanley, Plaintiff, V. Henry H. Stanley, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE :NO. 06-7121 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. cn r? 7, K:7 T1 ?,zr 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 rolinn S. Speese tanley, Plainti Louann S. Speese-Stanley, : IN THE COURT OF COMMON PLEAS OF- Plaintiff, : CUMBERLAND COUNTY, PENNSVAIA--T. V. : CIVIL ACTION - LAW IN DIVORCE cam' Henry H. Stanley, Defendant. : NO. 06-7121 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on April 6, 2009. 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. Date Ild flerfry H. ey, De en Louann S. Speese-Stanley, : IN THE COURT OF COMMON PLEA: OF,Y Plaintiff, :CUMBERLAND COUNTY, PENNSI'VAIA_-i Ei 7M V : CIVIL ACTION - LAW = P-; . IN DIVORCE == c { ' Henry H. Stanley, Defendant. : NO. 06-7121 CIVIL TERM - WAIVER OF NOTICE OF INTENTION TO REQUEST r 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 U Henry H. S tatf, dart IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Ms. Louann Speese Stanley V. Mr. Henry H. Stanley : NO. 06-7121 DIVORCE DECREE AND NOW, -DQc~J-4L 7 , P%/a it is ordered and decreed that Ms. Louann Speese-Stanley , plaintiff and Mr. Henry H. Stanley, defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") N By Attest: J. Prothonotary' C y C-OiY - Ne-L)/tl OkA.?1ty, ?:Z/q