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HomeMy WebLinkAbout02-5861DAVID H. WILDERNU~N, : Plaintiff : VS. : JULIA A. WILDERMAN, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ! CIVIL ACTION - LAW 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 in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PENNSYLVANIA 17013. IF YOU DO NOT WISH TO FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GP3~NTED, YOU MAY LOSE THE RIGHT TO CLAIM ANy OF THEM. YOUR 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, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 240-6200 DAVID H. WILDERMAN, : Plaintiff : VS. : JULIA A. WILDERMAN, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, ECHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I DIVORCE 1. Plaintiff is David H. Wilderman, who currently resides at 202 North 23rd Street, Camp Hill, Cumberland County, Pennsylvania 17011 since 1974. Plaintiff's Social Security Number is 016-34-8496 2. Defendant is Julia Ao Wilderman, at 20A West Coover Street, Mechanicsburg, Pennsylvania 17055 since October 1, 2002. Security Number is 202-42-6794. 3. who currently resides Cumberland County, Defendant's Social Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 28, 1999, in Flathead County, Montana. 5. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted, Lori /K. ~erratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 C.S. Section 4904, relating to unsworn falsification to authorities. the statement made in the foregoing Complaint ida. David H. Wilderman DAVID H. WILDERMAN, Plaintiff vs. JULIA A. WILDERMAN, Defendant : IN THE COU~T OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5861 : CIVIL ACTION - LAW : : IN DIVORCE AFFIDAVIT OF SERVICE I, Lori K. Serratelli, Esquire, being duly sworn according to law, depose and say that I served the Divorce Complaint in the above-captioned matter, by depositing it in the United States mail, Certified Mail, Restricted Delivery, Return Receipt Requested, addressed as follows: Julia A. Wilderman 20A West Coover Street Mechanicsburg, PA 17055 The return receipt card is attached hereto. Dated: Sworn and Subscribed to before me this /'/ day of ~t~~ , 2002. NOTARY PUBLIC My Commission Expires:~---7-~O0~ Lori~K.~erratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Rd., Ste 201 Harrisburg, PA 17110-9483 (717) 54,0-9170 Attorney for Plaintiff _ NOTARIAL SEAL D, EBRA A. EVANGELISTI, Notary Public ,Susquehanna Twp., Dauphin County IM~/Commission Expires Ma)/7, 2004 Postage CerUfied Fee Return Receipt Fee (Endorsement Required) Re~,icted Delivery Fee (Endorsement Required) Total Postage & Fees Postmark Here Sent To \ . ~ I', . I .......... ............................. [ Street, Apt. ~.; ~ -- ~ I .................. -I City, State, ~.~+~4_1 _ ~ ~ ~ A , .... I · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressedto: 2. Article Number (Cop~, ................. 7001 1140 Il A. Received by (Please Print Cle~ly) L lC. Signature If Y~S, ~nter ~liv~ edd~s ~low: 3. St.S_~ce TyI~9 /~S]-Certified Mail [] Express Mail / [] RegistenKJ [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. ~. _,- 4. Restricted Delivery? (Extra Fee) ,~Yes / - 00000019 0567 PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-17~ DAVID H. WILDERMAN, Plaintiff vs. JULIA A. WILDERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5861 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) OF THE DIVORCE CODE (i) (2) (3) (4) (s) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 9, 2002. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce without formal notice of the intention to request entry of a divorce decree. 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 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. Sec. 4904 relating to unsworn falsification to authorities. DAVID H. WILDERMAN, Plaintiff vs. JULIA A. WILDERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5861 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) OF THE DIVORCE CODE (1) (2) (3) (4) (5) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 9, 2002. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce without formal notice of the intention to request entry of a divorce decree. 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 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. Sec. 4904 relating to unsworn falsification to authorities. Jul~ A. Wilderman DAVID H. WILDERMAN, Plaintiff JULIA A. WILDERM3E~, Defendant IN THE COURT OF COMMON PLEAs OF CUMBERIJ~ND COUNTY, PENNSYLVANIA : NO. 02-5861 CIVIL ACTION - LAW : : IN DIVORCE PRAECIPE TO TRA~fSMIT RECORD TO THE PROTHONOTARy: by Section 3301(c) of the Divorce Code: by Defendant 4. 5. was filed with the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery__on_December 13, 2002. 3. Date of execution of the affidavit of conse~t~eq~ired by Plaintiff __ 5/13/03 Related claims pending: None. Date plaintiff,s Waiver of Notice in §3301(c) 5/19/03 Date defendant,s Waiver of Notice in §3301(c) was filed with the Prothonotary:_ 5/__19/03 _5/i3_/0%; Divorce Divorce BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff iN THE COURT OF COMMON DAVID H. WILDERMAN, Plaintiff VERSUS JULIA A. WILDERMAN, Defendant OF CUMBERLAND COUNTY STATE Of .~~ PENNA. No. 02-5861 PLEAS CIVIL DECREE IN DIVORCE DECREED THAT David H. Wilderman , PLAINTIFF, AND Julia A. Wilderman ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOL~OW]NG CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No claims remain. BY ATTEST:~i~ J' PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID H. WILDERMAN, : Plaintiff : vs. JULIA A. WILDERMAN, : Defendant : 02 - 5861 IN DIVORCE NOTICE TO RESUME PRIOR SURNAMri Notice is hereby given that JULIA A. WILDERMAN, Defendant, in the above matter, (select one by marking "x") ___ prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated June 2, 2003, hereby elects to resume the prior surname of JULIA A. KUHARIC, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. UHARIC COMMONWE~TH OF PE~SYLVANIA : : SS. COUNTY OF CUrE,AND : On this, the ~day of Dece~er, 2003, before me, the under- signed officer, personally appeared JULIA A. WILDERMAN, kno~ to me (or satisfactorily proven ) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the s~e for the purposes therein contained. IN WITNESS ~E~OF, I hereunto set my hand and official seal. ~otary ~blic ~ - My Commis~ios~~