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Home My WebLink About95-04848 . r~:-~::-:::; ~F. ~:~.~::-:::::-~ I . : OF CUMBERLAND COUNTY ~ ~ STATE OF * PENNA. I . -. - . . ..SllZETl'EH..STEELElAUNSE, .,...,............... I . .... No. ..95".46116..... .................19 t: . .........,..P~aintiff . ............ .....,..."..... I * . I !I! ~ V~1'8118 II . :.', ,,~H..l..l\UNSE,... ........"..,. .......... 1,'1 ! .. Defendant , . " j . . ~ ; . ~ . . _ The court retain. luri.dlctlon of the following claim. which have ~ . been rai.ed of record in this action for which a final order ha. not vet · 8,' been entered; 8 , . .:i , ...... to.. II...'....... to.. to....,.. to.. to 00>. to to.. II"" to. to... .... 10..' ., . .........,........,..,....................,......,....... .. d: , D y T~.. C 0 u r I , . --./(, LA, 1.// .. :.J.I ... ... : _ Aile"', ~'~u:'U~( I~ tVHb~ ..&'t'r~~~ J. lil L........ _~_ .:::: ~:~~~':"::~..j DECREE IN DIVORCE . .. AND NOW, . . , , , , , f.~f"JJ'7 ' . , / ~,~ , . " 19, .,.,. . .. it i, ordered and decreed that ,.",...,.""" .5UZE'l.'rE .M. ,STEELE .LAUNSE, . .,. "" plaintiff, and,..,...."......,........ ,~~l'S,~" U\\lN:>I>"."""..,.,. defendant, are divorced from the bond. of matrlmonv. ~ oJ;/f/.P? ~. (~AfJ ;ti 4-0/ o/-/r?/ 7~ /J~ dt ".yY. -"" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUZETTE M. STEELE LAUNSE, Plaintiff . I I I I . I CIVIL ACTION - LAW IN DIVORCE NO. 95-4848 CIVIL TERM v. CHARLBS M. LAUNSE, Defendant PRABCIPB TO TRAIISMIT RECORD To the prothonotary. Ple... transmit the record, together with the following information, to the Court for entry of a divorce decreel l. Ground for divorcel irretrievable breakdown under Section 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint I Hand Delivery to Charles M. Launse and his attorney, Ralph B. pinskey, B.quire, on September 12, 1995 at 9115 a.m. at the Domestic Relations Office in C.rlisle, Cumberland County, Pennsylvania, (A copy of the Certificate of Service is attached as Exhibit "A"). 3. Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Codel by the Plaintiff-- February 4, 1997, by the Defendant--February 4, 1997. 4. Related claims pending. none. Respectfully submitted, Dated I I' /'1/'1'1 2 o.......ylA~.. "',~. .... l" ..:J . i'-" N "..," l1J~~l J"l Cli_ -.' .1:,: .... l~J f" -, u.. ~~-. (,\ r, ,. ! :;; ~~.~, ' I r..'.' !tij \.Lo- h.t jD_ F-- u.. " II- r- j 0 I?' oJ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SEP 1 J /[]95 .1<_,,-.1 SUZETTE M. LAUNSE, : Plaintiff/Petitioner: . . No. 95- LIli'Y S' (~i.c~ 7(;'fll CIVIL ACTION - LAW v. CHARLES M. LAUNSE, Defendant . . In Divorce KOTIC. TO D...MD AKD CLAIK RIGHT8 YOU BAV. .... 8U.D I. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor, Cumberland county Courthouse carlisle, PA 17013 (717) 240-6200 " " " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUZETTE M. STEELE LAUNSE, : Plaintiff/Petitioner' v. No. 95- CHARLES M. LAUNSE, Defendant CIVIL ACTION - LAW In Divorce COMPLAINT IN DIVORCE COUNT I: DIVORCE AND NOW, this 11th day of September, 1995 comes Plaintiff, Suzette M. Steele Launse, by and through his attorney, Michael J. Hanft, Esquire, and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Suzette M. steele Launse, who currently resides at 708 Allen Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Charles M. Launse, who to the best of Plaintiff's knOWledge currently resides in cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. ~ ~ 4. The parties were married on December 31, 1994 in cumberland county, pennsylvania. 5. The Marriage is irretrievably broken. The foregoing facts are averred and brought under sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 6. Alternatively, plaintiff avers that the Defendant has offered such indignities to him, the injured and innocent spouse, as to render his condition intolerable and his life burdensome. The foregoing facts are averred and brought under section 3301(a)(6) of the Divorce Code of 1980, as amended. 7. The plaintiff has been advised of the availability of counseling, and that the plaintiff may have the right to request that the court require the Parties to participate in counseling. WHEREFORE, plaintiff requests Your Honorable court to enter a Decree in Divorce, divorcing the plaintiff from the Defendant. COUNT III EQUITABLE DISTRIBUTION B. paragraphs 1 through 7 are incorporated herein by reference as though the same were fully set forth herein. , ... .....'-.,,;......-"'.~... . ~~~5i,'l',~:,..,'",~\<-lf\e.'b':;','l'..' 9. The plaintiff and Defendant have acquired personal property during their marriage. 10. The plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, the plaintiff requests Your Honorable Court to equitably divide all marital property. Respectfully submitted, M ael J. Ha Attorney ID . 57976 11 West pomfret street, suite 2 carlisle, PA 17013 (717) 249-5373 .... VERIFICATION I VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unsworn falsification to authoritieD. ~1dk-~ ()J//V. ~ '.' ~ . . . l!A . :5 ... in co r-.I lh V1 ). >- ~':: t- :;.., ".~8 ~..;.:: '::: f~~ t.) . 1 t~: ".i. 2 :~, C"l!' ..... . '.' ..~ (~l L-l.', 'd- '-.r j ,'~ J '11 I'.,';. ~._~?- '" C"_ Il,: H '\J l~ t . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA S[P 1 J. 1995 ~/J-' v. M. STEELE LAUNSE, I Plaintiff/Petitioner I I I : I No. 95- J-\'? '-18' C....,'..v \ C,"1\ SUZETTE CHARLES M. LAUNSE, Defendant CIVIL ACTION - LAW In Divorce AND NOW, ORDER this ~ day of September, 1995 upon consideration of the within Petition and Exhibits the Court beinq satisfied of the truth of the averments therein, and the Court further being satisfied that Petitioner is unable to pay any of the costs of these proceedings, it is therefore Ordered and Decreed that the Petitioner may, pursuant to Pa. R.C.P. 1920.62, proceed with a divorce action in forma pauperis without payment of costs. JL F' - e--",,( (-=--- ': 1~-;~ (' 'Mnfl......mAlMVftl'.... '" \ \ ~ t I\~ ~ IIf '.. " 1i'1tl'a~' r.UHI'lI"M,D ':l "'In l't fl'1lj' l', _'..~iA SEP 1'1 2 Il~ rK '9S , ,; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUZETTE M. STE~LE LAUNSE, Plaintiff/Petitioner: I v. No. 95- CHARLES M. LAUNSE, Defendant CIVIL ACTION - LAW In Divorce PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS AND NOW this 11th day of September 1995, comes Plaintiff/Petitioner, Suzette M. steele Launse, by and through her attorneys, HANFT & VOHS, and represents as follows: 1. Petitioner, Suzette M. steele Launse, is an adult individual sui juris, who resides at 708 Allen Road, Carlisle, Cumberland county, PA. 2. Petitioner is seeking a divorce and due to financial circumstances is unable to pay any of the costs or expenses of same. 3. Petitioner has, based on income, been found eligible for free legal services by Central Pennsylvania Legal Services as evidenced by the attached referral form, attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. l """'U""'.ll'4AIMIVl,"'INlI,n .~ WHEREFORE Petitioner requests that an Order be entered granting leave to proceed in this matter in forma pauperis without the payment of costs. Respectfully submitted, HANFT & VOHS DATED: September 11, 1995 M c ael J. Ha Attorney 10 N . 57976 11 West Pomfret street, suite 2 Carlisle, PI. 17013 (717) 249-5373 Attorneys for plaintiff/Petitioner t:-wltllfYlIllC'l'lAlItdl'ftI..,.lm ~-@ , LEGAL SERVICES, INC. 8 Irvine Row Carlisle. Pennsylvania 17013 (717) 243.9400 FIIX (717) 243.802fl We51 Shore (717) 76fl,847S h'I'I~llftF"m""nt n"'.'..h",")MIllllllU1 111I11''''''' 4)1 I. w...lnttun JI".I C'ltuytbu,..h''''II)h-1"lIInlJ 111I1'''.''11 August. 7, 1996 Michael J. Hanft, Esquire Hanft & Vohs 1 West Pomfret Street Carlisle, PA 17013 RE: Suzette Steele Dear Mr. Hanft: We greatly appreciate your willingness to represent the above-referenced client. I have enclosed a copy of a Notice we have divorce referrals sign, and I've also enclosed a sample In Forma Pauperis form. If you have any questions concerning this case, or if we may be of assistance, please do not hesitate to call us. Although we are glad to assist you in any way possible, the final responsibility for this case must rest with you. We are confident that you will give this case the same high quality of service that you give to cases taken for remuneration. If th1s client has other legal problems, either now or at a later date, which are not related to the matter we are referring to you on a QLQ QQnQ basis, refer the client back to Legal Services, Inc. so that we can determine if the client is eligible for continued representation and referral without charge. We request that you complete and return to us, at the completion of the case, the enclosed Attorney Final Case Disposition and Evaluation form. When you do so, your name will be sent in to the Pennsylvania Bar Association and after you have completed two QLQ QQnQ cases, you will receive a discount coupon for PSI seminars, video tapes or audio tapes. Thank you again for your generosity and help in making the QLQ bcno system a success. Sincerely, LEG' SERVI~ES I . INC. . ~({ \-2 (>(J.(I,,{It) (~fricifl Fischer Pnvnt,o Bar COflr"dinat,-,," PF:ps ellclo"urll St:RVINC; AIIAMS. CUl\lIIERUNII. FRANKLIN ANIII'lJI.TON COUNTIES VERIFICATION I VBRIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. section 4904 relating to unsworn falsification to authorities. ~1l1kd- (Jj//V. ~ , i"j ~ ~ . .... ~IC i u ~('l"': I" ~ I (! ~., ~ " " = ~'" ..... VI CO l'.l ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUZETTE M. STEEL LAUNSE, Plaintiff v. No. 95-4848 CIVIL ACTION - LAW CHARLES M. LAUNSE, Defendant In Divorce CI.TI.ICATI O. 81RVICI AND NOW, this 24th day of January, 1996, I, Michael J. Hanft, Esquire, hereby certify that pursuant to Pennsylvania Rule of civil Procedure 400(b) (1), the following persons were served with a True and Correct copy of the Divorce Complaint filed in the above-captioned matter. True and Correct copies of the Divorce Complaint were served upon both the Defendant, Charles M. Launse, and his attorney, Ralph B. Pinskey, Esquire on September 12, 1995. Said service took place at 9:15 a.m. at the Domestic Relations Office in carlisle, Cumberland County, Pennsylvania by the undersigned handing the True and Correct copies of the Divorce Complaint to the Defendant, Charles M. Launse, and his attorney, Ralph B. Pinskey. ~, M chael J. nft, Esqu re Attorney ID o. 57976 11 West Pomfret Street, suite 2 carlisle, PI. l7013 (717) 249-5373 ~ en ~ <:) .. ~. N :;"1.'1' !B '- 13"" l,. ,~ g ii: ~-. (J~ fl.; ~. :;;.';",j N I'.~ ..,:~: [El,' - 'u"- :2, (.IJ.J r-= ., tHo.. ~ lO :s 0' {J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUZETTE M. STEELE LAUNSE, plaintiff v. No. 95-4848 CHARLES M. LAUNSE, Defendant CIVIL ACTION - LAW In Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(C) of the Divorce code was filed on September 12, 1995. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of the filing of the complaint in Divorce. 3. I oonsent to the entry of a final decree in divorce. 4. 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. 5. I understand that the costs of these proceedings will be paid for by Plaintiff. 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. section 4904 relating to unsworn falsification to authorities. Date: ..~ ILl 1((/ ~ .M. ~oZtUvv\.lL uzette M. Steele Launse '.- ..:I' '.. I.t~ -"1 (-; ~ N , ~ U.Jt' 0- .-. [f~l (L < ~,~ ~' tiL -- r.] , -- I Ii,; r.(~ III b-' I a. \- lJ- :.:J ,. r- () L." U IN THB COURT or COMMON PLEAS or PERRY COUNTY, PENNSYLVANIA SUIETTB H. STEBL LAUNSB, Plaintiff I I I I I I I CIVIL ACTION - LAW IN DIVORCE NO. 95-4848 V. CHARLES H. LAUNSB, Defendant 1IAIVlI_R~ ~I_CB or JII'rBJI'1'IOII 'l'O RBOUBST IlII'rKj_.: Y O. A DIVORCE D.CRBB OIIDIR __~:J01(c) or 'ftIB DIVORCB CODI l. I coneent to the entry of a final decree of divorce without notice. 2. I understand that I may loee righte concerning alUDony, 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 l8 Pa. C.S. 54904 relating to unsworn falsification to authorities. Dated I 'l\1.{ \~1 ttU ~O^-- u stte H. Stee e Launse e_~.AIYaIlII .... In r !2 .:J ;-.; I:; N ; -' l..: )~: UJ~--- )~:: C_Y :,7:.: c fF. r' u_ .\~j -, ... ~.. _. In I --' J;:-: L. ~ ~ ~ 0:, .,t,"j 1.I.l ia.. r~. \.>- :J It.. r- 0 C' 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUZBTTE M. STEELE LAUNSE, Plaintiff I I I I I I I CIVIL ACTION - LAW IN DIVORCE NO. 95-4848 V. CHARLES M. LAUNSE, Defendant AFPlDAVIT OP CONSBRT l. A complaint in divorce under section 330l(c) of the Divorce Code was filed on September l2, 1995. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of the filing of the Complaint in Divorce. 3. I consent to the entry of a final decree in divorcs without notice. 4. 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. 5. I understand that the costs of these proceedings will be paid for by plaintiff. 6. 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 l8 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. //'u ~/ arles M. La Datedl ,. 't- ? 1 Q~"""'JA~a& -- .:r ,.:: \"'r, .:J ~.... N 'I.p" ~;;', -" I ~:- :", ..-- "..' p..( ~ .~ .I~rl 1 ;;: .~ -/,') ~' -" L I :1' . ~" cc, '1(ll 0-"" IL) F' 1.>- ~~i I', r- (J U c' , IN THE COURT OF COMMON PLEAS OF PBRRY COUNTY, PENNSYLVANIA SUZBTTE M. STBEL LAUNSE, plaintiff I I I I I I I CIVIL ACTION - LAW IN DIVORCB NO. 95-4848 V. CHARLBS M. LAUNSE, Defendant WAIVliR OF W1'l'IC. or 11I'nft10ll 'l'O DOUBST IUlTRY O. A DIVORCE DECO. mmBR 13301(0) OF 'ftIB DIVORCB CODB 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose riqhts concerning alimony, diviBion of property, lawyer's fees or expen.es if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree i. entered by the Court and that a copy of the decree will be sent to me immediately after it i. filed with the prothonotary. I verify that the statement. I118de in this affidavit are true and correct. I understand that false statements herein are I118d. subject to the penalties of 18 Pa. C.S. 54904 relating to un.worn falsification to authorities. Dated I 2 LI 't 7 ~~//?c.~ ades M. Lauutf" Q..........1A~AI't'ILM. >. If) 1< .;J .' I '. Jr' l"l~ N } :-.'~ I . ~l:: 1 ", ~ r" .' djl I.... ..::J I' H t,-~ &" D. I !: , , r: ~~e C1!' l~ I 1'_ r- 'oj CJ rr