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Home My WebLink About02-51131N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. 0,).- b~l/3 ~,L~.4.ff "-[--~"~ VS. JOSEPH NATHANIEL DICKERSON. Defendant. 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 retief 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. There is a list of counselors available at the Prothonatary's office, at S. HANOVER STREET, CARLISLE, PA 17013. 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 4TM FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 TELEPHONE: 717-240-6200 MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff Address: P.O. BOX 113 MECHANICSBURG, PA 17055 Telephone: 717-580-3807 1N THE COURTS OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. COMPLAINT IN DIVORCE FILED ON BEHALF OF: MARION LAVERNE WILLIAMS-DICKERSON Plaintiff P.O. BOX 113 MECHANICSBURG, PA 17055 Address 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff; CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. COMPLAINT IN DIVORCE UNDER SECTION 3301 ( C ) OF THE DIVORCE CODE AND NOW COMES, the Plaintiff, MARION LAVERNE WILLIAMS-DICKERSON, who by filing Pro Se, and who is filing this Complaint in Divorce, a statement of which is as follows: 1. The Plaintiff is MARION LAVERNE WILLIAMS-DICKERSON, an adult individual who presently resides at P.O. BOX 113, MECHANICSBURG, PA 17055, and Plaintiffs Social Security number is: 195-56-8334. 2. The Defendant is JOSEPH NATHANIEL DICKERSON, an adult individual who, on information and belief, presently resides at 800 W. CHURCH RD., MECHANICSBURG, PA 17055, and Defendant's Social Security number is: 164-58-2281. 3. MARION LAVERNE WILLIAMS-DICKERSON resided in the Commonwealth of Pennsylvania for at least six months immediately previous to the commencement of this action. 4. The parties were married on SEPT. 26, 1992, in PHILADELPHIA, PENNSYLVANIA.~ 5. The Plaintiff avers that: (a) The marriage between the parties is irretrievably broken. 6. No prior action for divorce or annulment has been filed in this or any other jurisdiction. 7. Plaintiff avers that this action is not collusive. Page 1 of Complaint in Divorce 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. Count 1 - Child Custody and Support 9. Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint in Divorce as though fully set forth herein. 10. The following children may have been bom or adopted of this marriage, and their names, dates of birth, social security numbers and address of residence respectively are: JOSEPH NATHANIEL DICKERSON JR., DOB 10/8/92, SSN# 172-74-8053; LA ELLA GRACE DICKERSON, DOB 3/5/97, SSN# 204-76-7029. P.O. BOX 113, MECHANICSBURG, PA. 11. WHEREFORE, the Plaintiffrequests this Honorable Court to order custody, visitation, care, control and support of the said child(ren) to be awarded as follows: PRIMARY, PHYSICAL, LEGAL CUSTODIAL PARENT SHALL BE MARION LAVERNE WILLIAMS- DICKERSON. THE FATHER MAY VISIT AS OFTEN AS HE WOULD LIKE TOO. 12. Starting on ~vL-/.~ , and continuing on the same day of each month thereafter, JOSEPH NATHANIEL DICKERSON should pay to MARION LAVERNE WILLIAMS-DICKERSON, for each of said minor child(ten) which are not in his custody, the sum of $360.00 per month per each of said children for support and maintenance until each such child attains legal age or is emancipated or enters the military or until further order of the Court. Child support will be paid on a be-weekly basis, in the amount of $360.00 bi-weekly. Count 2 - Equitable Distribution 13. Plaintiff incorporates by reference paragraphs 1 through 12 of the Complaint in Divorce as though fully set forth herein. 14. Plaintiff and Defendant have acquired personal property during the marriage. 15. WHEREFORE, Plaintiffrequests this Honorable Court to order that each of the parties will retain and own the personal property that is in their respective possession. All personal property has been distributed to the parties mutual satisfaction. Page 2 of Complaint in Divorce 19. WHEREFORE, Plaintiff requests this Honorable Court that the wife be allowed to restore her former or maiden name of WILLIAMS. A Notice of Intention to Retake former or prior name will be filed with this action. Page 3 of Complaint in Divorce 20. WHEREFORE, Neither party is a member of any branch of the military service. 21. WHEREFORE, Plaintiffrequests this Honorable Court to enter a Decree 0f Divorce. 22. WHEREFORE, Plaintiff requests that because this marriage is irretrievably broken, the Plaintiff requests relief. k' Pla[ntiS- I verify that the statements and averments made in this Complaint in Divorce herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Dated ~ laintiff' ~j~ ~ SUBSCRIBED AND SWORN to before me, on the __day of My commission expires: Notary Public in and for Page 4 of Complaint in Divorce IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff; CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) Before me, the undersigned authority, a Notary Public in and for the Commonwealth of Pennsylvania and CUMBERLAND County, appeared MARION LAVERNE WILLIAMS- DICKERSON, the Plaintiff, in the above entitled action, who being duly sworn according to the law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his or her knowledge, information and belief, and that he or she is authorized to make this Affidavit. SUBSCRIBED AND SWORN to before me on Ills ¢ day of ~:~i~ My commission expires: NOTARIAL SEAL BARBARA A, SCARBORO, Notary PublicJ Tredyffrin Twp,, Chester County LMY Commission Expires Nov. 18, 2002 PLAINTIFF'S STATEMENT "I am (your name); I am the wife (husband) of(spouse's name). I am the Plaintiff in this action and I have lived and resided in Pennsylvania for more than six months immediately ,rthe filing of my Cqmplaint in Divorce. The Defendant and I were married at .~,1~ ~d. On ~0'{_~ $; , 19 ~. The grounds for this Divorce a~e: (state your grounds which were on the Complaint- usually irretrievable breakdown of ~ _ . ,~ . . / __ mm'riage)i,~ ,, .~//xt~-~ ~ ; JI~O~a~, Then say the Defendar~t is in c~efanlt and has not appe-~e~l herein.* ;Fherefore I ~'eauest that the Court terminat~Jsaid marriage and grant the Plaintiffa divorce." (Numb~r,o.f~c,hildren) have been bom of said marrial!e.r~Tt~.eir names and a~,esare: ~ ~ , , . The children are now livingl~.~ ~/t;) ~-~t*-t~J ~,, %/_¢.o~ rd}/] ~[~2-~ ~.d / "The Complaint I have filed has not been objected to by the Defendant The provisions o,/ the Decree of Divorce contain the requests and arrangements that are i~ my Complaint. ~[ ask the court to approve the requests and arrangements set forth in my Complaint and · Decree of Divorce." *If your spouse signed an "Entry of Appearance and Waiver" and a "Consent" form, instead of saying "the Defendant is in default", say, "the Defendant has signed an Entry of Appearance and Waiver in this matter and an Affidavit of Consent." After being signed by the Judge, the Final Decree in Divome must be filed with the Court Clerk. Now you are divorced unless the Judge asks for changes to be made in your papers. If changes are required, you must have the Docket Clerk set another heating date and appear with the papers corrected. At this Stage, the Judge should approve ail the Complaint and Decree and declare the case closed. If the Judge changes the order to something that is not in the Complaint, write down the change so that you can change the Decree later. Be certain that you get his/her wording or meaning for the filing of the new Decree. If there was real estate involved in your Divorce action, get a certified copy of the Divorce Decree which was signed by the Judge and have it recorded by the County Clerk of the County in which the real estate is located. Do this recording as soon as possible. Also, if there was real estate involved, as soon as possible you must have the deed and/or other necessary documents properly prepared and signed and thereafter have such necessary deeds and/or other documents recorded by the County Clerk of the County in which the real estate is located. COPYRIGHT Q 2000 HALLWOOD 1NC. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA FAMILY DIVISION MARiON LAVERNE WiLLIAMS-DICKERSON' Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON- Defendant. ACCEPTANCE OF SERVICE I accept setwice of Complaint in Divorce under Section 3301 (c) of the Divorce Code. DATE: Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA FAMILy DIVISION MARION LA VERNE WILLIAMS-DICKERSON, Plaintiff, VS. CASE NO. JOSEPH NATHANIEL DICKERSON. Defendant. WAIVER, ACCEPTANCE OF SERVICE AN Comes now the Defendant jOm.,~.. ~ D ENTRy OF GENERAL , ocrH NATHANIEL DiCKER~r~x' . . ~r~EARANCE ~'~'t~, who ~s the Defendant in the above- captioned cause of action, who acknowledges receipt ora copy of the NOTICE TO DEFEND AND CLAIM RIGHTS, and the Complaint in Divorce and cause of action, and adm}ts the allegations in said Complaint in Divorce, and consents to a final Decree in this matter without further notice to the Defendant, and waives all notice of disposition of this case. The Defendant hereby acknowledges that he/she has been advised of h/s/her right counsel in this matter and knowingly and intelligently waives the same. to Furthermore, Defendant hereby accepts and agrees with all the provisions and arrangements requested in the Complaint in the above-captioned cause. SUBSCRIBED AND SWORN to before My commission expires: Notary Public THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. ~;,p. o~//x VS. JOSEPH NATHAN/EL DICKERSON. Defendant. TYPE OF PLEADING: AFFIDAVIT OF CONSENT FILED ON BEHALF OF: MARION LAVERNE WILLIAMS-DICKERSON Plaintiff COUNSEL OF RECORD FOR THIS PARTY: NONE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under {Section} 3301 (c) of the Divorce Code was filed on (date) 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ora 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: ~ Plainti~.~ ~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. TYPE OF PLEADING: AFFIDAVIT OF CONSENT FILED ON BEHALF OF: JOSEPH NATHANIEL DICKERSON DEFENDANT COUNSEL OF RECORD FOR THIS PARTY: 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. AFFIDAVIT OF CONSENT Date:~.L 1. A Complaint in Divorce under {Section} 3301 (c) of the Divorce Code was filed on _~ 0.~(])~..~ (date>. 2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date offillng and service of the Complaint. 3. I consent to the entry ora 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. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(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 ill 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: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(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 ifI 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: (Defendant) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, VS. JOSEPH NATHANIEL DICKERSON. Defendant. CERTIFICATE OF SERVICE FILED ON BEHALF ON: MARION LAVERNE WILLIAMS~DICKERSON Plaintiff COUNSEL OF RECORD FOR THIS PARTY: NONE iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DICKERSON. Defendant. CERTIFICATE OF SERVICE I hereby certify that I, MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, of the Commonwealth of Pennsylvania, that a true and correct copy of the attached Complaint in D~orce was mailed J>y Certified Mail, Return Receipt Requested, Restricted Delivery on this ~ day °f~0~-~ O~, _,to: JOSEPH NATHANIEL DICKERSON 800 W. CHURCH RD. MECHANICSBURG, PA 17055 Commonwealth of Pennsylvania. Dated: __~ ~ Q~ by depositing a true copy of the same enclosed in a post-paid properly addressed wrapper, in a depository under the exclusive care and control of the U.S. Postal Service within the Plaintiff-MAl~ION ~A~RN~c ..... ~, ~r, r: WtLLIAMS-DICKERSON 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WiLLiAMS-DICKERSON, CASE NO. 0~ - 5't/3 Plaintiff, VS. JOSEPH NATHANIEL DICKERSON. Defendant. STATE OF PENNSYLVANIA) COUNTY OF CUMBERLAND) ss. AFFIDAVIT REGARDING THE UNIFORNI CHILD JURISDICTION ACT MARION LAVERNE WiLLIAMS-DICKERSON, being first duly sworn an oath, deposes and says: 1. I am the Plaintiff in the above-cited action. 2. That my spouse and I have TWO child(ren) as a result of this marriage. The names and dates of birth of these children are: JOSEPH NATHANIEL DICKERSON JR., DOB 10/8/92; LA ELLA GRACE DICKERSON, DOB 3/5/97. 3. That the aforementioned child(ren) presently reside as follows: P.O. BOX 113, MECHANICSBURG, PA WITH MOTHER SINCE BIRTH. 4. That neither the Plaintiff nor the Defendant have participated as a party, witness, or in any other capacity, in any litigation concerning the custody of these children in this or any other state. 5. That there is no custody proceeding concerning these children pending in any Court in this state or any other state. Page 1 of AFFIDAVIT IN RE UNIFORM CHILD JURISDICTION ACT 6. That there is no other person, not a party to these proceedings, who has physical custody of the children herein who claims to have custody or visitation rights with respect to the minor children. ~ ~ . ~ SUBSCRIBED TO AND SWORN before me on this day of My commission expires: Notary Public Page 2 of AFFIDAVIT IN RE UNIFORM CHILD JURISDICTION ACT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. 0,~ -~"/I-~ Q. V-. VS. JOSEPH NATHANIEL DICKERSON. Defendant. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: JOSEPH NATHANIEL DICKERSON, (Defendant) MARION LAVERNE WILLIAMS-DICKERSON{Plaintiff} intends to file with the court the attached Praecipe to Transmit Record on or after //~ 5A , , requesting that a final decree in divorce be entered. ~'~ -- ~ (/~ ~ ~ I !'~ Plaintiff ~-- 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. O-~. VS. JOSEPH NATHANIEL DICKERSON. Defendant. STATE OF PENNSYLVANIA) COUNTY OF CUMBERLAND) ss. AFFIDAVIT OF NON-MILITARY SERVICE Comes now the Plaintiff who, after being duly sworn under oath, deposes and says that the Defendant in the above-entitled matter is not now a member of the United States Armed Forces and was not a member of the United State Armed Forces at the time of commencing this action. This Affidavit is in compliance with the Soldiers' and Sailors' Civil Relief Act of 1940, as amended, Title 50 USC 520. Dated this _ day of SUBSCRIBED AND SWORN TO before me on ~ My commission expires: Plaintiff-' day of Notary Public for MARION LAVERNE WILLIAMS-DICKERSON Name of Plaintiff P.O. BOX 113 MECHANICSBURG, PA 17055 Address of Plaintiff COUNTY COURT OF COMMON PLEAS INTAKE THIS FORM MUST BE FILLED OUT IF YOU ARE FILING A DIVORCE OF CUSTODY ACTION IN THE PROTHONOTARY'S OFFICE: Date: Case Number: Please check one of the following: Divorce filing -- No children X Divorce filing -- With children under 18 years of age X Custody filing -- With children under 18 years of age Plaintiffs name and address: MARION LAVERNE WILLIAMS-DICKERSON P.O. BOX 113 MECHANICSBURG, PA 17055 Defendant's name and address: JOSEPH NATHANIEL DICKERSON 800 W. CHURCH RD. MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION MARION LAVERNE WILLIAMS-DICKERSON, Plaintiff, CASE NO. VS. JOSEPH NATHANIEL DiCKERSON. Defendant. NOTICE TO FILE SOCIAL SECURITY NUMBERS PURSUANT TO THE 23 P.S. SECTION 4304.1 {a} (3) PARTIES TO A DIVORCE ARE REQUIRED TO PROVIDE THEIR SOCIAL SECURITy NUMBERS TO THE COURT. PLEASE SUBMIT THE SOCIAL SECURITY NUMBERS OF THE PARTIES TO THIS DIVORCE ACTION TO THE PROTHONOTARY. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE -- THESE INFORMATION SHEETS WILL BE KEPT IN A SEPARATE FILE. Date: Docket No: Plaintiff's Name: MARION LAVERNE WILLIAMS-DICKERSON Plaintiff's Social Security Number: 195-56-8334 Defendant's Name: JOSEPH NATHANIEL DICKERSON Defendant's Social Security Number: 164-58-2281 TO: Office of Clerk of Records Prothonotary Division County Courthouse