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IN THE COURT OF COMMON PLEAS
.
John Michael Wilson, Jr.
OF CUMBERLAND COUNTY
STATE OF f ~..Y..
~~cr'
PENNA.
No. 97-3124
1997 Civil
VERSUS
Nelly Buzar Wilson
.
.
.
DECREE IN
DIVORCE
AND NOW, January
II
c.:;f"" /. . J'I plY/ .
2000 ,IT IS ORDERED AND
.
DECREED THAT .John ~lich8el Wilson, Jr.
, PLAINTIFF,
.
AN D Nell... Buzar Wilson
, DEFENDANT,
.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
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;
None.
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ATTEST: J.
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PROTHONOTARY
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NOTICE TO DEFEND AND CLAIM OF 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 wlthoul 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 visilatlon of your children.
When the ground for the divorce Is Indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A Iisl of marriage
counselors is available in the Office of the Prothonotary at:
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: 240-6195
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 RIGHTTO 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, FOURTH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
JOHN MICHAEL WILSON, JR,
Plaintiff
v.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97- 3/.;1.'( (J,,;,u: T...........
NELLY BUZAR WILSON,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
Section 3301 (c)
1. Plaintiff Is John Michael Wilson, Jr., an adult Individual, who currently
resides at 4344 Carlisle Road, Gardners (Dickinson Township), Cumberland County,
Pennsylvania 17324.
2. Defendant Is Nelly Buzar Wilson, an adult Individual who currently
resides at 550 Craig Road, Carlisle Barracks, Cumberland County, Pennsylvania
17013.
3. The Plaintiff and Defendant have been bona fide residents of the
Commonweallh of Pennsylvania for a period of more than six (6) months Immediately
preceding the filing of this Complaint. The Plaintiff and Defendant have been bona
fide residents of Cumberland Counly for a period of more than six (6) months
Immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on May 14,
1992, in the country of the Philippines, and ever since that time have been,
and are now, husband and wife. The parties entered into a church
marriage ceremony on May 15, 1993 in Carlisle, Cumberland County,
Pennsylvania. A copy of the parties' Carlisle marriage certificate is attached hereto
as Exhibit "A."
5. There has been no prior action for divorce or annulment Instituted by
either of the parties In this or any other jurisdiction.
6. The plaintiff has been advised of the availability of marriage counseling
and of the right to request that the Court require the parties to participate in
counseling.
7. The marriage of the parties is irretrievably broken.
8. After ninety (90) days have elapsed from the date of the filing of this
Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff
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JOHN MICHAEL WILSON, JR,
Plaintiff
v.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97-3124
IN DIVORCE
NELLY BUZAR WILSON,
Defendant
AFFIDAVIT OF CONSENT,WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE,
AND WAIVER OF MARRIAGE COUNSELING
1. A Complaint in Divorce LInder Section 3301 (c) of the Divorce Code was
filed on June 12, 1997. By Order of Court dated June 25, 1999, the Plaintiff's Motion to
Amend Complaint in Divorce was granled and the Complaint was Amended and
Restated as set forth in Exhibit "An to Plaintiff's Motion of [sic] Amend Complainl in
Divorce to Add Additional Ground filed on June 25, 1999.
2. The marriage of Plaintiff and Defendant is irrelrievably broken and ninety
days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final Decree of Divorce after service of Notice of
Intention to Request Entry of the Decree.
4. I undersland 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.
5. I understand that I will not be divorced until a Divorce Decree is enlered
by the Court and that a copy of the Decree will be sent to me immediately after il is filed
with the Prothonotary.
6. I understand that the Court maintains a list of marriage counselors in the
Domestic Relations Office, which list is available to me upon request.
7. Being so advised, I do not request that the Court require my spouse and I
participate in counseling prior to a Divorce Decree being handed down by the Court.
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JOHN MICHAEL WILSON, JR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97.3124
IN DIVORCE
v.
NELLY BUZAR WILSON,
Defendant
AFFIDAVIT OF SERVICE
STEPHEN D. TilEY, Esquire, being duly sworn according to law deposes and
says: That he Is the attorney for the Plalnliff In the above caplioned aclion In divorce;
that he did file a Complaint in Divorce on behalf of the Plaintiff with the Prothonotary of
the Court of Common Pleas of Cumberland County, Pennsylvania, on June 12,1997,
and received from the Prothonotary a true and correct copy of the same; that he did
send a true and correct copy to the Defendant, Nelly Buzar Wilson, at her last known
address, to wit: 550 Craig Road, Carlisle Barracks, Pennsylvania, 17013 via Certified
Mail No. P 492 365 328 deposited in the United States Posl Office in Carlisle,
Pennsylvania on June 13, 1997; that said Defendant did receive the same on June
19, 1997, as evidenced by the retum receipt card for said certified mail, which card Is
attached hereto and made a part hereof; and that the foregoing facts are true and
correct to the best of his knowledge, infonnalion and belief.
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. Seclion 4904 relating to unswom falsifications to authorities.
DATE:t/_.2~ /7? 1
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S ph D. Tiley ,
Frey & Tiley
Attomey for Plaintiff
5 South Hanover Street
Carlisle, PA 17013
(717) 243-5838
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97-3124
IN DIVORCE
JOHN MICHAEL WILSON, JR,
Plaintiff
NELLY BUZAR WILSON,
Defendant
AMENDED AND RESTATED COMPLAINT IN DIVORCE
Count I - Section 3301(c)
1. Plaintiff is John Michael Wilson, Jr., an adult individual, who currently resides
at 4344 Carlisle Road, Gardners (Dickinson Township), Cumberland County,
Pennsylvania 17324.
2. Defendant Is Nelly Buzar Wilson, an adult individual who previously resided
at 550 Craig Road, Carlisle Barracks, Cumberland County, Pennsylvania 17013, and
who currently resides at 2154 Ritner Highway, Carlisle, PA 17013.
3. The Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for a period of more than six (6) months immediately
preceding the filing of this Complaint. The Plaintiff and Defendant have been bona
fide residents of Cumberland County for a period of more than six (6) months
immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on May 14,
1992, in the country of the Philippines, and ever since that time have been,
and are now, husband and wife. The parties entered into a church marriage
ceremony on May 15, 1993 in Carlisle, Cumberland County, Pennsylvania. A
copy of the parties' Carlisle marriage certificate is attached hereto as Exhibit "A."
5. There has been no prior action for divorce or annulment instiluted by either
of the parties in this or any other jurisdiction.
6. The plaintiff has been advised of the availability of marriage counseling and
of the right to request that the Court require the parties to participate in counseling.
7. The marriage of the parties is irretrievably broken.
8. After ninety (90) days have elapsed from the date of the filing of this
Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes
that Defendant may also file such an affidavit.
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JOHN MICHAEL WILSON, JR,
Plaintiff
v.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97.3124
IN DIVORCE
NELL V BUZAR WILSON,
Defendant
AMENDED AND RESTATED COMPLAINT IN DIVORCE
Count I - Section 3301 (c)
1. Plaintiff Is John Michael Wilson, Jr., an adult Individual, who currently resides
at 4344 Carlisle Road, Gardners (Dickinson Township), Cumberland County,
Pennsylvania 17324.
2. Defendant Is Nelly Buzar Wilson, an adult Individual who previously resided
at 550 Craig Road, Carlisle Barracks, Cumberland County, Pennsylvania 17013, and
who currently resides at 2154 Ritner Highway, Carlisle, PA 17013.
3. The Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for a period of more than six (6) months immediately
preceding the filing of this Complaint. The Plaintiff and Defendant have been bona
fide residents of Cumberland County for a period of more than six (6) months
immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on May 14,
1992, in the country of the Philippines, and ever since that time have been,
and are now, husband and wife. The parties entered into a church marriage
ceremony on May 15, 1993 in Carlisle, Cumberland County, Pennsylvania. A
copy of the parties' Carlisle marriage certificate is attached hereto as Exhibit "A."
5. There has been no prior action for divorce or annulment instituted by either
of the parties in this or any other jurisdiction.
6. The plaintiff has been advised of the availability of marriage counseling and
of the right to request that the Court require lhe parties to participale in counseling.
7. The marriage of the parties Is irretrievably broken.
8. After ninety (90) days have elapsed from the date of the filing of this
Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes
that Defendant may also file such an affidavit.
DIt8r MIt'
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JOHN MICHAEL WILSON, JR,
Plaintiff
v.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97-3124
IN DIVORCE
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NELLY BUZAR WILSON,
Defendant
MOTION OF AMEND COMPLAINT IN DIVORCE
TO ADD ADDmONAL GROUND
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
Plaintiff, by his attorney, Stephen D. Tiley, Esquire, respectfully represents and
moves this Court as follows:
1. Plaintiff is John Michael Wilson, Jr., an adult individual, who currently
resides at 4344 Carlisle Road, Gardners (Dickinson Township), Cumberland County,
Pennsylvania 17324.
2. Defendant Is Nelly Buzar Wilson, an adult individual who previously
resided at 550 Craig Road, Carlisle Barracks, Cumberland Counly, Pennsylvania
17013, and who currently resides at 2154 Ritner Highway, Carlisle, PA 17013.
3. A Complainl in Divorce was filed to the above term and number on June .
12, 1997.
4. The Complaint, as filed, alleged the following ground for divorce: mutual
consent pursuant to Section 3301 (c) of the Divorce Code.
5. Plaintiff wishes to amend his CDmplalnt to add a two year separation
count pursuant to Section 3301 (d) as the two years have now passed.
6. The form for a consent and a two-year separation divorce set forth at
Pa.R.C.P. 1920.72(a) is idenllcal however the form set forth by Plaintiff in his June 12,
1997 Complaint specifically referenced only Section 3301 (c) of the Divorce Code.
7. Plaintiff desires to amend and complelely restate his Complaint by filing
the form of Complaint attached hereto as Exhibit "A."
WHEREFORE, plaintiff respectfully moves your Honorable Court to allow
JOHN MICHAEL WILSON, JR,
Plaintiff
v.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97-3124
IN DIVORCE
NELLY BUZAR WILSON,
Defendant
AMENDED AND RESTATED COMPLAINT IN DIVORCE
Count I . Section 3301(c)
1. Plaintiff Is John Michael Wilson, Jr., an adult individual, who currenlly resides
at 4344 Carlisle Road, Gardners (Dickinson Township), Cumberland County,
Pennsylvania 17324.
2. Defendant is Nelly Buzar Wilson, an adult Individual who previously resided
at 550 Craig Road, Carlisle Barracks, Cumberland Counly, Pennsylvania 17013, and
who currenlly resides at 2154 Ritner Highway, Carlisle, PA 17013.
3. The Plaintiff and Defendant have been bona fide residents of the
Commonweallh of Pennsylvania for a period of more than six (6) months Immediately
preceding the filing of this Complaint. The Plaintiff and Defendant have been bona
fide residents of Cumberland County for a period of more than six (6) months
Immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on May 14,
1992, in the country of the Philippines, and ever since that time have been,
and are now, husband and wife. The parties entered into a church marriage
ceremony on May 15, 1993 in Carlisle, Cumberland County, Pennsylvania. A
copy of the parties' Carlisle marriage certificate Is attached hereto as Exhibit "A."
5. There has been no prior action for divorce or annulment instituted by either
of the parties in this or any olher jurisdiction.
6. The plaintiff has been advised of the availability of marriage counseling and
of the right to request that the Court require the parties to participate in counseling.
7. The marriage of the parties Is irretrievably broken.
8. After ninety (90) days have elapsed from the date of the filing of this
Complaint, Plaintiff intends to file an Affidavil consenllng to a divorce. Plaintiff believes
that Defendant may also file such an affidavit.
DIfIfI1' Nit-
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5 South Hanover Street
eerllsle, PA 17013
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MR. JOHN MICHAEL WILSON, JR.
4344 CARLISLE ROAD
GARDNERS, PA 17324
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