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~~