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S OF CUMBERLAND COUNTY ~
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: STATE OF . PENNA. :
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. Robert,James Sears 8
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Frances May Sears
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Defendant
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DECREE IN
DIVORCE
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AND NOW,.,. .r.~r.~,~.'.,~,..,..,.. 19 ,~. to.. it is ordered and
decreed that . ~.o.~E!~~. ,J:<iI!l!3.s. .9~~.r!!. , ., . . . ,. , . , , , , . , . ,. ., .. . " plaintiff,
ond .., r.r:'H19~!! ,~lilY. ,5~il.r:!l. , , , , , , ' , , . , . , . . . , , , . ' , . , . . . . . , ". defendant,
are divorced from the bonds of matrimony.
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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;
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ROBERT JAMES SEARS
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUM8ERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-5077 CIVIL 1995
v.
FRANCES MAY SEARS
Defendant
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to
the court for entry of divorce decree:
1. Ground for divorce: irretrievable breakdown under Section
3301(d) of the Divorce Code.
2. Date and manner of service of complaint: October 6, 1995.
United States mail, certified, restricted delivery, return receipt
requested, postage prepaid.
3. Date of execution of plaintiff's affidavit required by
Section 330l(d) of the Divorce Code: September 22, 1995
Date of service of the plaintiff's affidavit upon the
defendant: October 6, 1995
4. Related claims pending: None
5. Date and manner of service of the notice of intention to
file praecipe to transmit record, a copy of which is attached:
United States mail, certified, restricted delivery, return
receipt requested, postage prepaid.
"1 1 cj
Date v<-.C, ~<l)l, lit,
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Ro rt James Sears, Pro se
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ROBERT JAMES SEARS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 95-5077 CIVIL 1995
FRANCES MAY SEARS
Defendant
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE
TO: Frances May Sears:
Robert James Sears intends to file with the court the attached
Praecipe to Transmit Record on or after January 1, 1996 requesting that
a final decree in divorce be entered,
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ROBERT JAMES SEARS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
FRANCES MAY SEARS
Defendant
CIVIL ACTION - LAW
NO. 5<. '1'1 CIVIL 1995
IN DIVORCE
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 to you.
Bonnie Brooks, Family Court Director
2145 Main St. Room 226
Wailuku, HI 96793
(808) 244-2770
IP 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 00 NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFPICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Hawaii State Bar Association
1136 Union Mall PH 1
Honolulu, HI 96B13
(BOB) 537-9140
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ROBERT JAMES SEARS
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. CIVIL 1995
FRANCES MAY SEARS
Defendant
IN DIVORCE
COMPLAINT
The plaintiff, Inmate ROBERT JAMES SEARS Pro se, sets forth the
following cause of action:
COMPLAINT UNDER SECTION 33011c\ AND 33011d\ OF THE DIVORCE CODE
1. Plaintiff is Inmate ROBERT JAMES SEARS who is currently
incarcerated at the State Correctional Institution at Camp Hill,
Cumberland County, Pennsylvania 17001-0200.
Plaintiff has been
incarcerated at SCI Camp Hill since February 21, 1992.
Prior to
incarceration, Plaintiff resided in Cumberland County, PA.
2. Defendant is FRANCES MAY SEARS, who currently resides at 33
Uaoa Loop Haiku, HI 96708. Defendant has resided at this address since
October 1994.
3. Plaintiff has been a bona fide resident of the Commonwealth for
at least six months immediately previous to the filing of this
Complaint.
4. The plaintiff and defendant were married on August 2, 1969 at
Paradise, Lancaster County, Pennsylvania.
5. Plaintiff and Defendant have lived separate and apart since
October 26, 1983.
6. There have been no prior actions of divorce or for annulment
between the parties.
7. The marriage is irretrievably broken.
-. "'-
ROBERT JAMES SEARS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 1995
IN DIVORCE
v.
FRANCES MAY SEARS
Defendant
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements 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
The parties to this action separated in 1983 and have continued to
live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
1.
3. 1 understand that 1 may lose rights concerning alimony, division of
property, lawyer's fees or expenses if 1 do not claim them before
a divorce is granted.
1 verify that the statements made in this affidavit are true and
correct. 1 understand that false statements herein are made subject to
the penalties of 18 pa.C.S. S 4904 relating to unsworn falsification to
authorities.
Date:
OJ-:2 J.+I-'
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ROB T JAMES, EARS
Pro Se "
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ROBERT JAMES SEARS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 1995
9'S - 50 ??C~;.t;:r~
IN DIVORCE
v.
FRANCES MAY SEARS,
Defendant
PETITION TO PROCEED IN FORMA PAUPERIS
1. I am a prisoner currently incarcerated at the State
Correctional Institution at Camp Hill, Cumberland County, Pennsylvania
17001-0200.
2. I am the plaintiff in the above matter and because of my
financial condition am unable to pay the fees and costs of prosecuting
or defending the action or proceeding.
3. I am unable to obtain funds from anyone, including my family
and associates, to pay the costs of litigation.
4. I represent that the information below relating to my
ability to pay the fees and costs is true and correct:
(a) Name: 1<oBer-f ~ameS' Searl,;
Address: , .0. 8~p ;1,oC,
C~", tJ....1I-; 1/ RJ, !..Jpo 1- 0;;' 0 Q..
Social SecurIty Number: OI9-3<1-w3,;2;;J..
(b) Employment
If you are presently employed, state
Employer: .s. c, :r. CAmP No' /1
Address: p.o, Bo::s. ;]nCl .
C1tJ1fl )/- '11 PA. 17c:.Q I - O:l.. 0 r,
Salary or waqelLper' month: '$ .1//
Type of work: ];.l"",te..rh..r
If you are presently unemployed, state
Date of last employment: 13.Tu ..e 90
Salary or wages per. month: rv 1(..1" ),~. )
Type of work: I1dd,,,c, ()p~('iltc.-,... -
Other income within the past twelve months
Business or profession: af
Other self-employment: ~
Interest:
Dividends:
Pensions and annuities:
Social security benefits:
Support benefits:
Disability payments:
Unemployment compensation and supplemental benefits:
Workman's compensation: ~
(C)
(d)
Public 93sistance: ~
Other:
Other contributions to housppo19 support
(Wife) (Husband) Name: ~ (/l
If your (wife) (husbana) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
Contributions from parents:
Other contributions:
Property owned
C h. oI"_L'~ 'IA-e'_
as. CP.~ - ,..... - ....
Checking account: AXil e
Savings account: I.JDne
Certif icates of depos it: Alc,n e...
Real estate (including home): A.}6IIe..
Motor vehicle: Make~lCJ)~ ' Year
Cost IV , Amount Owed $
Stocks i bonds: A] /') 1J f:-
Other: Alol/(='
(f) Debts and obligations
Mortgage:
Rent:
Loans: " 7~O -
Other: II4,OO~ (.,,11.
(e)
(g)
5.
the court
permit me
Persons dependent upon
(Wife)(Husband) Name:
Children, if any:
Name: ,(JOl7e
you for support
/Voile
Age:
Other persons:
Name: t1}()>> P
Relationship:
I understand that I have a continuing obligation to inform
of improvement in my financial circumstances which would
to pay the costs incurred herein.
6. 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. S 4904, relating to unsworn
falsification to authorities.
Date, .<.. '''''pl. Ir.p~~ 1
U ~hU.l/.-' A04..t-"
ROBF: T JAM ~EARS
Pro Se
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ROBERT JAMES SEARS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. ~-5077 CIVIL TERM 1995
FRANCES MAY SEARS
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I, James Strong, hereby certify that I have served a true and
correct copy of the Complaint, Plaintiff's Affidavit and Notice to
Defend and Claim Rights on FRANCES MAY SEARS, residing at 33 Uaoa Loop
Haiku, HI 96708 by depositing a copy of same in the United States mail,
certified, restricted delivery, return receipt requested, postage
prepaid, this September 29, 1995. The receipt was returned signed by
the defendant October 10, 1995.
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Sltl IUnr 'oiitt w.o~ Sd
URN RECEIPT
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PRAECIPE
In the Court or Common Pleal o~ounty
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No. ..~~7:~o.n..........,
TO THE P~ARY: . .................................,
........................................................................................................................ ....
Please enter the appearan::e of Kenneth R. Jewell, Esq. on behalf of
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K~~~~~r~...M~t
PA Attnrney I.D. l'h. 23157
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Prothonotary
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