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Home My WebLink About02-3154CAROL SCOTT, Plaintiff RONALD KEVIN SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CiVIL ACTION - LAW :IN DIVORCE : NO.o,i -..?~WIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the cia/ms 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 child. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list ofmamage 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 DET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Lilberty Avenue Carlisle, PA 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 heating or business before the court. You must attend the scheduled conference or heating. CAROL SCOTT, Plaintiff RONALD KEV1N SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE : NO.~I,~ ~..~I..~qCIVIL TERM COMPLAINT UNDER 23 Pa.C.S. §§ 3301(c) and 3301(d) OF THE DIVORCE CODE The plaintiff, Carol Scott, by her attorneys, the Family Law Clinic, sets fo~h the following cause of action: I. Plaintiffis Carol Scott, who currently resides at 7 Pine Road, Apt. 105, Mount Holly Springs, Pennsylvania, 17065. 2. Defendant is Ronald Kevin Scott, whose current residence is unknown, but whose mailing address is 309 Lansvale Street, Marysville, Pennsylvania 17053. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on June 7, 1989 in Port Charlotte, Florida. 5. Plaintiff and Defendant have lived separate and apmt since, July of 1996. 6. There have been no prior actions of 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 or defendant may have the fight 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. Megan ~[alone Certified Legal Intern LUCY JOHNSTON-WALSH Supervising Attorney FAMILY LAW CL1NIC 45 North Pitt Street Carlisle, PA 17013 717/243 -2968 CAROL SCOTT, Plaintiff RONALD KEVIN SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :iN DIVORCE : NO. CIVIL TERM VERIFICATION I verify that the statements made in this Complaint for Divorce are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S § 4904, relating to unswom falsification to authorities. Date: ?/~/~/~D. C~ CAROL SCOTT, Plaintiff RONALD KEVIN SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND : COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE : : NO~,~ CIVIL TERM ~ ,.t,/,~-¥ PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: IGndly allow Carol Scott, (Plaintiff), to proceed in forma pauperis. The Family Law Clinic, attorneys for the pa~y proceed/ng/n forma pauperis, certifies that we believe the party is unable to pay the and that we are provid/ng free legal service to the party, costs Date~ Respectfully submitted, Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON_WALSH Supervising Attorneys FAM/LY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 CAROL SCOTT, Plaintiff RONALD KEV1N SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW :IN DIVORCE : NO. 02-3154 CIVIL TERM PROOF OF SERVICE I, Megan Malone, Certified Legal Intem, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Complaint for Divorce on Ronald Kevin Scott residing at 309 Lansvale Street, Marysville, Pennsylvania, 17053 by depositing a copy of the same in the United States mail, certified, restricted delivery, retum receipt requested. Service was complete upon receipt by Ronald Kevin Scott on the 5th day of July, 2002, as evidenced by the attached green card. Date: Megar~alone Certified Legal Intern C<m,de~ Items 1, 2, end 3..NIo (x)mptl~ tram 4 If ~ DdtvlP/Il dldred. · p¢.~t your rm~m~ md ~ on the m 1. Atlk~ ~ to: FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ?001 g - lflPOgAI3O3 [] tr~ur~ u~ ID c.o.D. 2510 0003 44A2 1A39 PS Form 3811, August 2001 Domestic Return Receipt CAROL SCOTT, Plaintiff RONALD KEVIN SCOTT Defendant :iN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :iN DIVORCE : : NO. 02-3154 CIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in July 1996 and have continued to live seapate and apart for a period of at least two years. The marriage is irretrievably broken. I understand that I may lose rights concerning alimony, division of propemj, 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 tree 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 CAROL SCOTT, Plaintiff RONALD KEVIN SCOTT Defendant :iN THE COURT OF COMMON PLEAS OF :CUMBERLAND C. OUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW :iN DIVORCE · NO. 02-3154 CIVIL TERM CERTIFICATE OF SERVICE I, Megan Malone, Certified Legal Intern, Family Law Clinic, do hereby certify that I have served a true and correct copy of Plaintiff's Affidavit under §3301(d) of the Divorce Code on the following person by placing a copy of the same in the United States mall, postage prepaid, on this the 21st day of November, 2002. Ronald Kevin Scott 309 Lansvale Street Marysville, PA 17053 Date: ~ Megaif Malone Certified Legal Intern CAROL SCOTT, Plaintiff Vo RONALD KEVIN SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW :IN DIVORCE : : NO. 02-3154 CIVIL TERM CERTIFICATE OF SERVICE I, Heather Fine, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit Record and Vital Statistics form on Ronald K. Scott by first class United States mail, at the following address: Ronald K. Scott 38 Paradise Park New Bloomfield, PA 17068 Date: Heather Fine Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 245-2058 CAROL SCOTT, Plaintiff RONALD KEVIN SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW :IN DIVORCE : : NO. 02-3154 CIVIL TERM CERTIFICATE OF SERVICE I, Heather Fine, hereby certify that I served a Counter-Affidavit and a Notice of Intention to Request Entry of a Divorce Decree on Ronald K. Scott on February 7, 2003, by first class United States mail, at the following address: Ronald K. Scott 38 Paradise Park New Bloomfield, PA 17068 Date: Heather Fine Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 245-2058 CAROL SCOTT, Plaintiff Vo RONALD KEVIN SCOTT Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW :IN DIVORCE : : NO. 02-3154 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 Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: July 5, 2002, by United States mail, certified, restricted delivery, return receipt requested. 3. Date of execution of the Plaintiff's Affidavit required by § 3301(d) of the Divorce Code: November 19, 2002; Date of service of the Plaintiff's Affidavit upon the Defendant: November 21, 2002. 4. Related claims pending: none. 5. record, a copy of which is attached: February 7, 2003. Date ~, ~[,~}"l '7..0~ Date and manner of service of the notice of intention to file praecipe to transmit United States mail, first class, postage prepaid on Heather Fine Certified Legal Intern ROBERT E: RAINS THOMAS M. PLACE Supervising Attorney LUCY JOHNSTON-WALSH Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 Carol Scott Ronald Kevin iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~_ PENNA. NO. 02 - 3154 VERSUS Scott DECREE iN DIVORCE DECREED ThAT Carol Scott AND Ronald Kevin Scott , 2003, it iS ORDERED AND , PLAINTIFF, , 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 PrOThONOTArY