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HomeMy WebLinkAbout95-00706 - - .{ J . 1 , , , - - f , " u ~ - . ~ J . ~. , ~ ", ! ,i.! ,~-~~~~~~~~~-~~._~--*~)~,~:~'*._--~~"~ . _,___~""___'-"______""'4'_''''''''''_-'_'-''''''.__'''_____ _.__~ _____...-...---~....."_....__._....._.._____..........._____________ ... . ~! ~ ~I ~ ~I ~ ~\ ..'\ , , WI ','I ~I !ii~ ~l ~) '/ ~:' ~I ~'. ;/ , , , , -,,' " . " , '" ~ .~~.~.~.~~..~.~.~*.~~~-**-**_.~~*~.*~.**~.~. IN THE COURT OF COMMON PLEAS ~ <;> OF CUMBERLAND STATE OF .. COUNTY ~ ',' PENNA. b ~ ~ .... .;, " w ',' LINDA A. CAMPBELL, PLAINTIFF II 706 CIVIL 95 19 No, ,;, ~ ,', ~ Vl'r~lI~ s FRANK L. CAMPBELL, :r:: ~ p ~ 3S. ()D bu.-e eOUVlfy ~ ~ ',' DEFENDANT i: " ~ '.' 8 DEeRE, DIVO~ ~ '.' s! ~ ,; .;, " AND NOW, ' , , , M ~,,. , :~, , , , , , , , , , , " , , LINDA A. CAMPBELL, decrAed thot "",."""""""""""" FRANK L. CAMPBELL ond """"""""",."""""""""" ore divorced from the bonds of matrimony. ...., --.-......Y..., $ ~.' M ,.' ~ '.' ~ ',' ~ The court retoins iurisdiction of the following claims which have been raisfld of rflcord in this action for which a final order has not yet been entered; ~ ~ .... NONE ~ ..................... ......... ......... ... ...... ... ... ........, w ',' Dy The.citX:~ O~(, AlIest: J~(,'tt<<.L:( E'. ~~: ,.tt~,-7'::;/ y{]fI" ;;.G#/~ k ~t1t". ~~ V j' Pf6lhonolnry ~ ........... ...... ....... .,... .... ............... ~ .' $ i ',' i '.' ~ '.' ,;, ~ ,', * ,;, ~ !:i " i '.' ~ ...' ~ ',' ~ .... w ...' ~ '.' ~ I~ ~ ,'~ ~ ~ '.' .;, " ,:" ~ ~ ',' ,', ~ * i '.' ~ ',' ~ .', (~ I~ .. I~ I: I~ I'" J~ ,.. ,!!. .~ :~ I,', ~ FEB 1 0 1991,,,, LINDA A, CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE FRANK L. CAMPBELL, Defendant : NO. 95- 7P4CIVIL 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 ami 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. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 LINDA A, CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. FRANK L. CAMPBELL, Defendant : NO. 95- 7tJ' CIVIL TERM COMPLAINT The plaintiff, Linda A. Campbell, by and through her attorneys. the Family Law Clinic, sets forth the following cause of action: COUNT I. DIVORCE UNDER 23 Pa.C,S. SECTION 330Hd) OF THE DIVORCE CODE 1. Plaintiff is Linda A. Campbell, whose current residence in Cumberland County is not being revealed herein, but is known to her counsel. 2. Defendant is Frank L. Campbell, who currently resides at 315 Paige St., Apt. 1, Schenectady, NY, 12307, 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 January 5. 1975, in Poughkeepsie, Dutchess County, NY. 5, Plaintiff and defendant have lived separate and apart since August 10, 1992. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken, COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS. I verify that Ihe statements made in this Divorce Complaint 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 unsworn falsification to authorities. Date: ,4-? -9S- /;;},/, ' /) ~) ~ LJl , ".Ate/~ Ll {2Z~u . f-- LINDA A. CAMPBELL," Plaintiff ' 'I;) 0 ~ ~ f't) Ln ". rJ') - ~ " ;~"; ~ ' .~., c--, -0 .u .~ , , FEB 1 0 1995 J,>' LINDA A, CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE FRANK L. CAMPBELL, Defendant : NO. 95- '10/.. CIVIL TERM ORDER OF COURT I ' tfl- r--l.A\.{.{CL~,tl AND NOW, this ,'";) day of I ~, (J' 1995, on consideration of the attached petitioner's Affidavit, leave is granted to the petitioner to proceed in fonna pauperis to the extent that she is relieved of all costs in this action. By the Court, ,t-(,. ,''i f::::- -/ , 1:,. :;. ;1'1', '" t r: " .:10. L'_ L. r~ [/ R3J -.. ,........' ......--.--.-.....-. - '- -, --=...... ...~..... -~--,-'_'., .0- ,._ . LINDA A, CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE FRANK L. CAMPBELL, Defendant : NO, 95- '/()(, CIVIL TERM PETITION TO PROCEED IN FORMA PAUPERIS Linda A. Campbell, plaintiff in the above titled action, respectfully requests this Honorable Court to grant her leave pursuant to Pa.R.C,P. 1920.62 to proceed in forma pauperis to the extent that she be relieved of all costs attendant to this action. Date ?-/-=+ I ~1 G L.v~L2 ~ ~ LINDA E, FISHER Supervising Attorney THOMAS L. PEELER Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 0- f. . L-V'Y' 1C;~-: f 1"S;'::::~ LINDA E. FISHER Supervising Attorney THOMAS L. PEELER Staff Attorney LINDA A. CAMPBELL, Plaintiff :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE FRANK L, CAMPBELL, Defendant : NO. 95- 10 (, CIVIL TERM A~~~Y'S ::IDAVIT SUPPORTING PETITION F VE PROCEED IN FORMA PAUPERIS I, Kathryn Price, of the Family Law Clinic, attorney for the party petitioning to proceed in forma pauperis, certify that I believe petitioner is unable to pay the costs of instituting this action and that I am providing free legal service to petitioner. Plaintiffs Affidavit showing inability to pay the costs of litigation is a~tached hereto. Date :J-!1!blS FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 (b) I do not have infonnation or knowledge as to whether my husband has any money, owns an automobile, owns real estate, or has any other personal property or assets, (c) My husband is unemployed. 7. I have three children: Frankielyn Campbell (D,O.B.: 11-21-72); Christopher F. Campbell (D.O.B.: 06-24-74); and Jamie S. Campbell (D.O.B.: 10-29-75). All three of my children are financially independent and do not reside with their parents, 8. I am presently employed, part-time, at a local establishment, My work address has not been revealed but is known to my counsel. It has not been revealed publicly because my husband has abused me in the past. Should the court so desire, my counsel can reveal this infonnation under a protective order. 9. My social security number is known to my counsel. It has not been revealed publicly because I do not want my husband to obtain it. Should the court so desire, my counsel can reveal the number under a protective order. 10. I have the following monthly income: (a) Approximate Salary ($5.25/hour): (b) Food Stamps (approximately): (c) TOTAL MONTHLY INCOME: $455.00 $ 50,00 $505,00 11. My monthly expenses are as follows: (a) Rent: (b) Medicine (Theodore, asthma inhalers, insulin and needles): (c) Bills (debt owed for back bills is $580.00 cumulative) $200.00 $168,00 Electric monthly payment: $ 25,00 Gas monthly payment: $ 70.00 Water monthly payment: $ 30.00 (d) Food: $120.00 (e) Cigarettes: $ 55.00 (t) TOTAL MONTHLY EXPENSES: $668,00 12. My husband and I did not maintain a checking account throughout our marriage, 13. I do not own an automobile. 14. I understand that I have a continuing obligation to infonn the court of improvement in my financial circumstances which would pennit me to pay the costs incurred herein. 15. 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. WHEREFORE, petitioner prays that this Honorable Court grant petitioner leave to proceed in fonna pauperis in the above titled action without fee or cost to the petitioner. Date ;:9- '7 - 9_") ~' /7. 1 ../': '1,. , "/ / ' / /' (' ./ ~~. '-)' ' LV /{ ,,,,,,It II (U ",-/.{-,(. UNDA A. CAMPBELL / UNDA A, CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE FRANK L, CAMPBELL, Dcfendant ; NO. 95-706 CIVIL TERM RETURN OF SERVICE I, 1erry 1. Webb, hereby certify that I am a competent adult who is not a party to these proceedings and that I served a true and correct copy of the Divorce Complaint ,on the defendant Fmnk L. CamDbell, by hand delivering a copy of the same to Fmnk L, Campbell at ?/'5 "j)~/'r,-~ 5/ ,at/I:f2'am/~on :z ....,Z7- ,1995. - I {ADDRESS] [TIME] [DATE] I verify that the statements made in this Return of Service 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 unsworn falsification to authorities. Date: e -Z/....'7 ''5H ~(c' 5-, Addr.l, '/ ~(;11f h,/C ~ - >- ",'" .,>- W/'-- r (.) (,... .~) -I l:'~~-:~ ~..:.. ~ n-C:" ; ~=z:~' _') oJ..... ....- ....._,./1 __ .-. 'c r. _..~L...I~ ~ :r (1)1..., .~ "'SH "- .' Of..' :5 o N 0') r- --. ~ LINDA A, CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE FRANK L. CAMPBELL, Defendant : NO. 95-706 CIVIL TERM CERTIFICATE OF SERVICE I, Kathryn Price, Certified Legal Intern, Family Law Clinic, hereby certify that I have served a true and correct copy of the Notice Of Intention To Request Entry Of Divorce Decree and a Defendant's Counter-Affidavit under Section 330l(d) of the Divorce Code on Frank L. Campbell, at 315 Paige St., Apt. 1, Schenectady, NY, 12307, by depositing" the same in the United States mail, first class, postage prepaid, this 21st day of March, 1995. ~~Vl~l~ ~athryn Price Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 240-5204 v, IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE LINDA A, CAMPBELL. Plaintiff FRANK L, CAMPBELL, Defendant NO. 95-706 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 330Hd) OF TIlE DIVORCE CODE Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (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 three years. (ii) The marriage is not irretrievably broken, 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 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 II /3 /7::. '( / ? NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. f i)'o VYl ,i-l-e.(\, J- Pd l.1 ~ r W-C[ vlT VI 0 Td-l-, In S c( q d 5 tl -e I 'S II, C! I 1. () () () () v () " j eTI. / ~l J "I c-'l/ll ( , I'Jt f~{J V'l\ /lL-(2.