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Home My WebLink About00-00423 '~ -'1; , ' . . . . . . .. . .. . ,. "m 0' . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . STATE OF . WILLIAM EUGENE SAMPSON . No. . . . . . Plaintiff VERSUS . ~ VIVIAN DELORES SAMPSON . Defendant . . . DECREE IN DIVORCE ~, . . . . . . AND NOW, . DECREED THAT WILLIAM EUGENE SAMPSON . . . AND VIVIAN DELORES SAMPSON . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . PENNA. 423 2000 2000 , IT IS ORDERED AND PLAINTIFF, , DEFENDANT, 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; ./-:./</ , ' /~ a '96 c ~ PRO ONOTARY . . . . . . . NONE . ATTEST: By ,;tHE COUrT: '-\ . . . . . ~ ~ ~ ~ ~ ~ ~~ ,'--- ~' /'" ",? .' / . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . 3, / .(;J{) J . / ',?Jdf .' '> iI' ; ~ ~ -{' -'i\. . , tV_~~64~ J11~ ~w4 ~ dJ 4 . - ~ - , ., ..", ' ' <41.4'- .~ ". ^, - r -^. =-<,,~ > " ~ w..~ ~,~ ..1- WILLIAM EUGENE SAMPSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. VIVIAN DELORES SAMPSON Defendant CIVIL DIVISION NO. 423-2000 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: ~~allioown{\~ndediili:1l($)lu[ 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service ofthe complaint: 1-26-00, U.S. Mail, Return Receipt 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff ; by defendant (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: 1-19-00 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 1-26-00 .~\:-.::~:-i;1~~~4~~,:',,_,<,~ :},,__,/," Related clafmsliedfAlJ~ NUNE " . . , ",;,,,"l1 ' ",~i:-'{}~1f~i;/1L , -.,.~*;~:.... -<"St-" ....,..~ '_'~1fJ ' ',:- ;._ ,,,~, <;')"" ,t~-;",._. ,5. Complete either (a) or (b), (a) Date and manner of service of the notice of intention to file praecipe to transmit record. a 1-24-00 copy of which is attached: (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: c ~f;~ __ Attorney for Plaintiff I Defendant ~iIlIilliii~"-~"="'- --" ...:......- ....~. ,~ , ' ,b"I_~~!.."",,,_~"'""- ~~. = .......,om.." ...,~'-I.,""""""-~_~,, .~ ~ " o ~; -0..-::.:: \I"iT;"; 6;~~;; oj ~1_:: --" -- yC:,l }i;'-. :~~S~ j :'-=j -< C:) c:::-.J ~ "-q .~ ~........~ '~ 1">J U', i'.) :Jl ~: WILLIAM EUGENE SAMPSON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2000- q;;)3 CIVIL TERM IN DIVORCE VIVIAN DELORES SAMPSON 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 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 Court House, 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ~~'~ ..J. _ ~~~ ~;;i: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff WILLIAM EUGENE SAMPSON Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VIVIAN DELORES SAMPSON Defendant NO. 2000- '1..23 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301/d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through his attorney Peter J, Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1, Plaintiff is an adult individual residing at 412 N. Pitt St, Apt#2, Carlisle, PA 17013, Cumberland County, Pennsylvania and is a citizen of the United States. 2, Defendant is an adult individual residing at 408 First Street, Carlisle, PA 17013, Cumberland County, Pennsylvania and is a citizen of the United States, 3, Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 63 years and has resided continuously therein for at least six months 'prior to filing of this Complaint 4, Defendant has been a resident of the Commonwealth of Pennsylvania for 69 years and has resided continuously therein for at least six months prior to filing of this Complaint 5, Plaintiff and Defendant were married on February 28, 1958 in Cumberland County. 6, There are no children of the parties under the age of eighteen (18), .cll. - ~- COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8, There has been no prior action for divorce by either party against the other. 9, Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10, Plaintiff avers that the marriage between the parties is irretrievably broken, 11. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, but does not request the same. 12. Plaintiff and Defendant have already separated all marital property and no outstanding issues apply to the same. WHEREFORE, Plaintiff, WilLIAM EUGENE SAMPSON, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A That a decree in divorce be entered dissolving the marriage between the two parties. Respectfully submitted, ~ Peter J. Russo 61 West louther Street Carlisle, PA 17013 (717) 249-2721 Date:~ -~ A '""",>. ,PETER J, RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West louther Street Carlisle, PA 17013 (717) 249-2721 WILLIAM EUGENE SAMPSON Plaintiff Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW VIVIAN DELORES SAMPSON Defendant NO. 2000- IN DIVORCE CIVIL TERM VERIFICATION I, WilLIAM EUGENE SAMPSON, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C,S. 94904 relating to unsworn falsification to authorities. /- / '7- 00 Date: "' "":"' , ~~ " ~_,l~ B:;~ -'i1 (') 0 0 $J c: <:;) ,1 -~ <, <- 4)- "'Of;::; """ mr+; :z :::J ~ ~ b( ~ Z::Cl r- ;z:r ,"", ~5j~ --...< en J:2~ .c:- ,",:J N --.".- -<L ~C "~"! .:} 0 " .',- f 1 ''-~-n :J'O 2':0 ::l': i4(~5 " ~ ~() N c:...rn PC: ,.::i uJ :z: r;:- 55 =< (::> -< LAl ~ - ~\~~ ~ ~~ 'I.' ~,:,"__B~~~n-m;rW'II\~IIH!'tf~nta\_ W, -=-. J l' "~~, ~-- WILt.;IAM EUGENE SAMPSON Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VIVIAN DELORES SAMPSON Defendant NO. 2000 - 4~3 CIVIL TERM IN DIVORCE PROOF OF SERVICE OF PLAINTIFF'S AFFIDAVIT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, WilLIAM EUGENE SAMPSON, and certifies that on 1- ZLe -00 he did serve the ,Defendant, VIVIAN DELORES SAMPSON with a time stamped copy of the Affidavit of Plaintiff Under Section 3301(d) of the Divorce Code by placing same in an envelope, return receipt requested and addressed to VIVIAN DELORES SAMPSON at 408 First Street, Carlisle, PA 17013, and deposited same with the United States Postal Service for delivery. Respectfully submitted, c -\2t \. -\) Peter J. Russo 61 West Louther Street Carlisle, PA 17013 ~ Date: " J ~ 5"1 a <NO DiIlIlL......'tll-'iIlltMJ,jllW -'~"""~"i!lt.lli--"".i'lllJllii~ir~._'-I;E~i'rna~_D OF ',Jill r.f_:-'~ ^ v I j._t;. / ~5 P,,"'~.' ;,:': L n - "-"...-' CUi\iii:"j~~~!ij:,~\L; :: ;(,':,:U\JTV PEj\j;\i\:'Yl\II~~.;i,~ ." . I '.... "', i ~ ''- -. .-.. ~ ~ .- I Vi; PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff WILLIAM EUGENE SAMPSON Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - lit- '?:> CIVIL TERM IN DIVORCE VIVIAN DELORES SAMPSON Defendant PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, WilLIAM EUGENE SAMPSON, and certifies that on ~-7.-l ~ ~OO , he did serve the Defendant, VIVIAN DELORES SAMPSON with a true and correct copy of the Divorce Complaint filed against her alleging the parties' marriage was irretrievably broken under Section 3301(d) and Section 3301(c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, return receipt requested and addressed to VIVIAN DELORES SAMPSON at 408 First Street, Carlisle, PA 17013, Cumberland County, Pennsylvania. [.(/ Service of Plaintiff's Complaint on the Defendant, VIVIAN DELORES SAMPSON was effected on i=27 o-ev . A true and correct copy of the U.S. Postal Service Return Receipt is attached hereto and the original is affixed to the reverse of this document. HI Service of Plaintiff's Complaint on the Defendant, VIVIAN DELORES SAMPSON was effected on z..-IS'OD . A true and correct copy of Defendant's Acknowledgment of Service is attached hereto and the original is affixed to this document. ~ Peter J. Russo Date: 2/lY{J/) j__~~nlMdi'l'""'-__"'-"""""'"~~t!lh"~~ .~ '" , ~, lJ._.....,~ ,~ "" r+j :z ~7 u:' -< ~ ~~3 ........c~ 2; =< ~:=--~ ~~ ", ~- i.....) u; ;1~ ~;:c~; -_-"'--Cl ;~~~~ B ~~:-n ..~'> '.::D -< .4~~; 1':-:> r:- eD , . , " !i1;C, ) PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 WILLIAM EUGENE SAMPSON Plaintiff Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW VIVIAN DELORES SAMPSON Defendant NO. 2000 - Lt'Z--) CIVIL TERM IN DIVORCE ACKNOWLEDGMENT OF SERVICE OF COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, Defendant. VIVIAN DELORES SAMPSON, and does hereby acknowledge that on the date indicated below she did receive a verified copy of a Complaint in Divorce filed against her in the above captioned case. J~JI~ VIVIAN DELORES SAMPS DATED:~i) OJ :\~,. , ' , I ... " 'D ii ," II) Ii :;; ~ ," .c ; ~ C . 0 j " g, E ,0 " Ul Ul W II: C C <C z II: :l W II: ~ ::J g, .!! SENDER: I also wish to receive the -Complete items 1 andlor 2 for additional services. -Complete items 3, 48. and 4b. following services (for en _ Print your name and address on the reverse of this tonn 80 that we can retum this extra fee): card to you, -Attach 1hls tonn to the front of the mall piece, or on the back if space does not 1. 0 Addressee's Address pennil. 2. 0 Restricted Delivery -Wrlte"Retum Receipt Requested" on the mail piece below the article number. -The Return Receipt will show to whom the article was delivered and the date delivered. Consult postmaster for fee. 3. Article Addressed to: 4a.~rticl2 Om[;r qa 7 O?:iJ WI/' I o...vv De[l)YeS 3o..(Yl{JS6'V'- 4b. Service Type ~ed 40B ~v-St Sw o Registered o Express Mail o Insurad fu.v-IISU Pr+lIOI~ o Return Receipt for Merchandise o COO 7. Oete of Delivery ~. 26 . 5. Received By: (Prinf Name) 8. Addressee's Address (Only if requested end fee is paid) 6. Signature: (Addressee or Agent) XI )A~"".o<-/ <{'... " PS'Forin 3811 eecell'lber, 4 / Domestic Return Recei t - ~ e 1 ol " 'e ", Ul' 'S.: 'i1 " ' a: ' c' j: II: , 01' C' 'i: ::J , ~ ' 2 ::J' 0' >0 ' ...' C .. .c ... p " ~ o S <' ~r!tj 0!~; f~~ ::j -<; o S [76:; rnr~.' 2::-1:1 Cf}S; ~~ z =< -1'- - r ( -, ::: .c:- <J:) " i c,:.~ C:..' ..." i-i1 r,':::: . .;j - ~j "} N c..r; ~\J ;:'? '...' Ul --, -L,. "'D =< (:.::J ~ ...' 0lII1" ~k WILLIAM EUGENE SAMPSON Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VIVIAN DELORES SAMPSON Defendant NO. 2000 -Lf'2b CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 33011d) OF THE DIVORCE CODE 1, Check either (a) or (b): l;( I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check either (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (Ii) The marriage is not irretrievably broken. 2, Check either (a) or (b): ~ 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 for 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 affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 110 (Jrh~~J ~~ VIVIAN DELORES SAMPS N 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. :;j n c- -;" (::? o -C\ ,,'-r'\ \.-~ -- ....'(1 \.:.'~, D-'1\' I..-.t::').;:_ 7::,1:.... (j),""., (~.~,. ",-<.0:;(,,-, -Y' :;;:,,' '::.:> ~ "'" (J"', ....c~ ~-",'" ..<; I' " ~~~1!!l!OO~~~M. '_'_~"""~',_ JIM" "'F~<_JIIII'~ ,,~,~ -.' 'I~ <- -. - WILLIAM EUGENE SAMPSON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - q.J..3 CIVIL TERM IN DIVORCE v. VIVIAN DELORES SAMPSON Defendant NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN 1WENTY DAYS (20) AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301ld) OF THE DIVORCE CODE 1. The parties to this action separated in March 1, 1993 and have continued to live separate and apart for a period of at least two years. 2, The marriage is irretrievably broken. ,3. 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, I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa,C,8, 94904 relating to unsworn falsification to authorities, Date: (- / r; - 00 It' . , c: l..- (') c:> (') c- o -:"} ~ '- :::;J -oUJ ]::.'2> ;:~l?D mrn z Z::TJ N ~ott( Zr;; ~- :")'7 ~~;.. .~ (~o ~el ~ ~~~ 5>8 :3:::: ,~(? z J r::> ~frI J>c: (51 -4 Z J:'" 35 ::<! "" ~c :'-~ " _~" ~_""",~"' ....".,.,._.,~~I1'M-'~~~I\lI~lili$JII!QI-.~ """'....., ~~ ."..,--! .'~-- -"'r~lO - ...... ~'li" " . . , WILLIAM EUGENE SAMPSON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW VIVIAN DELORES SAMPSON Defendant NO. 2000 - 4;)3 CIVIL TERM IN DIVORCE NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: VIVIAN DELORES SAMPSON Defendant You have been sued in an action for divorce, You have failed to answer the complaint or file a counter-affidavit to plaintiffs affidavit. Therefore, on or after FEBRUARY 15, 2000, the plaintiff can request the court to enter a final decree in divorce, If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Respectfully submitted, ~~S Peter J. Russo 61 West Louther Street Carlisle, PA 17013 Date: \/~I-z..ooo --' i.' ~""-','~_' .r.'~IllI~~_) ~.~il!Il!"~"""' ~....;u , . ~~'- ~... . . (") '0 0 c: 0 "" -n -0 OJ '- mF1 J" Z:IJ Z :D Ze- N , '_-:"m (j) .,. -<'" :C}O ~,$ ~e -U ~~i~ ""0 :3F.: ~~ S€g ~ ,.) Z s;:- "'" =! 55 en -<