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HomeMy WebLinkAbout97-04349 ~ i I i ! ~ \l ~ ....... 'It ~ ~ \. \I j 1 I \. " ? i I ..... . .. I "':) i _ 1 ! , j t ~ ' ~) ~. Q ~ ! DARRELL L. WALKER . IN THE COURT OF COMMON PLEAS OF . Plaintiff I CUMBERLAND COUNTY PENNSYLVANIA . . v. I No. 97-4349 : AMEY R. WALKER, I CIVIL ACTION - LAW Defendant . IN DIVORCE . PRAECIPB TO WITHDRAW COUNT TO THE PROTHONOTARY: Kindly withdraw Count II - Equitable Distribution in the above referenced divorce as the issues have been settled. ~t.. ~ 'f Matthew J. Law Office 2108 Marke Camp Hill, ID' 72655 II I' 'I I, " 'I " Ii ,I '; !! I ! sQbmitted, [ shelman, Esquire of Patrick F. Lauer, Jr. Street, Aztec Building Pennsylvania l7011-4706 Tel. (717) 763-1800 \\ 1 I I i ,I DARRELL L. WALKER Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. : : No, 97-4349 : : CIVIL ACTION - LAW : IN DIVORCE AMEY R. WALKER, Defendant PRAECIPB 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: Irretrievable breakdown under S 3301(c) S 3Jll1(d) (1) of the Divorce Code. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Service by certified mail t P 160 937 194 delivered on August 29, 1997. See Attached Affidavit of Service. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by the Plaintiff November 30, 1999 1 by the Defendant Januarv 31. 2000 . (b) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: 1 Date of filing of the Plaintiff's affidavit upon the respondent: 1 Date of service of the Plaintiff's affidavit upon the respondent: . 4. Related claims pending: None all matters settled, and Counts Withdrawn in Divorce ComDlaint. Date: 5. (Complete either paragraph (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which i. attached, 1 (b) Date Plaintiff's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: December 14, 1999 1 Date Defendant's Wa ver of Notice in S 3301(cl Divorce was filed with the ftO.'l onotx, ' fil:" ",,,.It".eo..', w/PraeciDe . 1'.~ , ( ...... Matthew J. shelman, Esquire # 2108 Marke Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ~, . IDt 72655 Tel. (717) 763-1800 Attorney for the Plaintiff "S: v. IN TUB COURT OF COMMON PLKAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. (i7' 4.j 4 q (Li tLl L DARRELL L. WALKER, Plaintiff AMEY R. WALKER, Defendant 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 the Cumberland County Courthouse, 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 TAD THIS PAPBR TO YOUR LAWYER AT OHCB. IF YOU DO IfOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TBLBPBONE TBB OPPICB Sft FORTH BBLOW TO FIND OUT WBBRB YOU CAN G8'l' L8GAL BBLP. COURT ADMINISTRATOR CUMBBRLAND COUHTY COURTHOUSB 1 COURTBOUSB SQUARE CARLISLE, PA 17013 (717) 240-6200 DARRELL L. WALKER . IN TBB COURT OF COMMON PLKAS OF . Plaintiff : CUMBBRLAHD COUNTY PBHHSYLVANIA : (',". I r;.~ v. . No. '/?- "11 " 'i . : AMEY R. WALKER, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) or 3301(d) OF TBB DIVORCE CODE The Plaintiff, Darrell L. Walker, by and through his attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce and, in support thereof, avers as follows: 1. The Plaintiff, Darrell L. Walker, is an adult individual who currently resides at 3915 Gettysburg Road, Cumberland County, Pennsylvania 17011. 2. The Defendant, Amey R. Walker, is an adult individual who currently resides at 3915 Gettysburg Road, Cumberland County, Pennsylvania 17011. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. COUNT I - DIVORCB 4. Paragraphs one through three are incorporated herein by reference. 5. The Plaintiff and the Defendant were married on October 8, 1994 in Granville, Mifflin County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. This action is not collusive. 10. There are no dependent children to the marriage. COUNT II - EQUITABLE DISTRIBUTION 11. Paragraphs one through ten are incorporated herein by reference. 12. The parties have legally and beneficially acquired property, both real and personal, during their marriage. 13. The Plaintiff and the Defendant have been unable, as of the date of this Complaint, to agree as to an equitable division of said property. DARRBLL L. WALKER : IN TUB COURT OF COMMON PLKAS OF Plaintiff : CUMBBRLAHD COUNTY PBHHSYLVANIA : v. : No. . . AMBY R.WALKER, . CIVIL ACTION - LAW . Defendant . IN DIVORCE . VERIFICATION I, Darrell L. Walker, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 5 4904, relating to unsworn falsification to authorities. Date: ~ Signature: jl~.JiL~ ~&- DARRELL L. WALKER I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY PENNSYLVANIA I v. I No. 97-4349 I AMBY R. WALKER, . CIVIL ACTION - LAW . Defendant I IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 330lfcl OF TBB DIVORCE CODE 1. A complaint in divorce under Section 3301Ic) of the Divorce Code was filed on August 12, 1997. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of 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 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. 5 4904 relating to unsworn falsification to authorities. DATEI _ Signature I ~tJI L li/t Darrell L. Walker , DARRELL L. WALKER . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY PENNSYLVANIA . : v. : No. 97-4349 . . AMBY R. WALKER, . CIVIL ACTION - LAW . Defendant I IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301rcl OF TUE DIVORCE CODE 1. A complaint in divorce under Section 3JOllc) of the Divorce Code was filed on August 12, 1997. 2. The marriage of the Plaintiff and the 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 of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. S 4904 relating to unsworn falsification to authorities. ; DATE: I / ~IIG(; r , Signature: .~1..(;~JU- '- Amey R. Walker ....