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Home My WebLink About03-0394 MICHEAL R. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : CIVIL ACTION - LAW : NO. 2003- 3 q 'I CIVIL TERM LAUREL A. WILSON, Defendant : 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 will proceed without you and a decree in divorce or annulment may 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 or 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MA Y 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 Bar Association 2 Liberty A venue Carlisle, Pennsylvania 17013 (717)249-3166 MICHEAL R. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : NO. 2003- 3</'f CIVIL LAUREL A. WILSON, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (0 OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Micheal R. Wilson, plaintiff herein, by and through his attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is Micheal R. Wilson, an adult individual, currently residing at 802 Highland Court, Mechanicsburg, Cumberland County, Pennsylvania 17007. 2. Defendant is Laurel A. Wilson, an adult individual, currently residing at 5002 Wynnwood Road, Harrisburg, Dauphin County, Pennsylvania 17109. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on December 5, 1998 in Dover, York County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This rnarriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, {-:J..,7-o3 (~~ M.V ; 'oq 'lin,M. v'rn,y,E,q~ Supreme Ct. !D. 23167 44 South Hanover Street Carlisle, P A 17013 (717)243-9190 Attorney for Plaintiff VERIFICA nON I verify that the statements made in the foregoing divorce complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 1/25/0\ D~te , I/llllli Micheal R. Wilson, Plaintiff 0 c::; ~ c c..~, < ~ -oi:."- ~- nlj'-i ,."" z. :'_. -.'" 2~ 1 r'","' J (/\ ~ -' -_J A [\ r:~ ~. J;r- :c>~ ~~~: C1 ; ~ Z :::.::' :<! ::-:? \0 :n ............ -< "'- ~ ..1.\ w \ 0 W ()'... ~ 0 G ~\ d MICHEAL R. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : CIVIL ACTION - LAW : NO. 2003-394 CIVIL TERM LAUREL A. WILSON, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C-P. 1930.4 (c) COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Jacqueline M. Verney, Esquire, being duly sworn according to law, deposes and says that she is the attorney for plaintiff, Micheal R. Wilson, and that she did serve a true and correct copy of the divorce Complaint that was filed in the above matter, by U,S. mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the defendant, Laurel A. Wilson, on February 19,2003. The receipt form is attached hereto as EXHIBIT "A", acq ine M. Verney, Esquire #23 7 44 S. Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Plaintiff ~1" ~ ~ day of ~003. Sworn to and subscribed before me this ~ J'~~''''''''''''ft. ~ KATHLEEN:(vSIAJiiAI. SCAt Car/iSI '. HAW 1,,:1..~i My Com~f:~o, Cl1mb~~I..~tacry PUblic ~lS'on Expires Dee Ounty ---.....;.:,:,:_ . 22, 2fJ03 --.;...;;~ ...... -:t\.~> SENDER COMPLETE THIS SECT/ON . 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 Addressed to: DYes o .No l-AIAi!.LL A-. tv,/SOtV 500 2- /;J y AI /II W Q (. 'i> ]) (l.. U A-IZ.../l ( s.b 4 t2C'o , ~. n 10 ? o Agent o Addressee : C. Date of Delivery 2. Article Number 100 0 /~ 70 CCt:l I (Transfer from service label) Sl'g~ '7 7 7..;J... PS Form 3811, August 2001 Domestic Return Receipt 1 02595-02-M-l 035 EXHIBIT "A" - ~ 0 << c '. --- ~~,... -"t) t"11 ~.C'. .) J-- .~I....-' ,.) ~2\~ .:: cO ..-r. ~ :r-" c ~('"'1 f(. n PC ~ ....)"'l - .-..~~ MICHEAL R. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2003-394 CIVIL TERM LAUREL A. WILSON, Defendant : IN DIVORCE PRAECIPE TO STAY COMPLAINT TO THE PROTHONOTARY: Please stay the above captioned Divorce Action. Respectfully submitted, :;-;2.3-03 (1 .~ lit. V~ ,bd-. Verney, Esquire #2316~ (I 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff e ~ "'Ow ~~ zc <n~; ~c:~' ~c.) 5>~ ~ o (...) :x ;po -< N W o ..." --I --.- f.,~ :!J ..,.,M; -:59 :~c') ::~1'-i ~. L. -n ,~)-~ :="c) '.\.--rn S 'J'> ~ J:7o :x C>> .. ,::> &'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ! ) n 1.~hI m niClLt'Y J pi1hrtiff Vs FileNo._ill -~~~ Li\J II IN DIVORCE Dcu f f (\ leu ~y TDefendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] - prior to the entry of a Final Decree in Divorce, or L after the entry of a Final Decree in DivoI1:e dated,..j \ ill 0 l L hereby elects to resume the prior surname of \.) I U'Y\ pe>r , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: L I~ \6Ll \I (1 h n ~J) ~:ignature ~t~b COMMO~rn OF PENNSYLV ANlA ) COUNTYOFC:"rYj her/MId On the!f'l' day of Ju L'f ' 200~L. before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the PUIpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL JODY S. SMITH, NOTARY PUBLIC Carlisle Boro, Cumberland County My Commission Expires April 4, 2005 " k,1tCn;,ft Notary lie 70 "iq, 0 ..... => ~ c: => ~ ;-.) ~';:7 Z- -~ ;,,~. '- -I In ',:- c: ff.:!:' 8 ~?' .- .r:;; -. (J. I ~6 P ::.::~ CD ~; -v ..,...,.; -v ____-r"1 ...0 ~~-~ :;;; C!o ~ F N ESn"j L- ~~:~ t) -' .t=" -c: :;.1 -l "~, ~ GAIL L. MARCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DANIEL E. MARCH Defendant : NO. 03-394 CIVIL TERM : IN CUSTODY MOTION FOR LEAVE TO WITHDRAW AS COUNSEL Ronald E. Johnson, Esquire respectfully represents the following in support of this Motion: 1. On February 25, 2002 Petitioner, Ronald E. Jolmson, Esquire was retained by Defendant, Daniel E. March to represent him at a custody conciliation. 2. Your Petitioner also represented Daniel E. March as Plaintiff with the Defendant being Tiffany M. Bridi in a separate custody case said action having been filed in the Court of Common Pleas of Cumberland County, Pennsylvania to Number 04-372. This action involved a child named Raven S. March and a custody conciliation was held on February 26, 2004. 3. Your Petitioner has had telephone and letter contact with the attorney representing the Plaintiff, Gayle L. March but in spite of attempts on his part, the Petitioner has had no response or contact with the Defendant in this matter for some period of time. 4. In the custody proceeding referenced in paragraph 2 above a further custody conciliation was scheduled for May 14,2004 but the Defendant failed to appear. 5. Your Petitioner left several phone messages for Defendant to contact him, but the Defendant failed to do so. 6. As a result of the Defendant's failure to appear or otherwise contact the Petitioner, the Petitioner sent a letter to the Defendant dated June 8, 2004 advising the Defendant that he would no longer represent him. A copy of that letter is attached hereto and marked Exhibit A and made a part hereof. 7. Your Petitioner has had absolutely no contact from the Defendant prior to or subsequent to the letter dated June 8, 2004 and seeks leave of court to withdraw as counsel in the above captioned case. WHEREFORE, Petitioner prays Your Honorable Court to issue a Rule to Show Cause returnable within 15 days of service directing the Defendant to Show Cause why his counsel Ronald E. Johnson, Esquire should not be granted leave to withdraw as counsel in the above captioned case. ANDREWS & JOHNSON By: Ronald E. Jo Attorney for 78 W. Pomf Street Carlisle, P A 170 \3 (717) 243-0123 GAlL L. MARCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. DANIEL E. MARCH Defendant : IN CUSTODY : NO. 03-394 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on this date, _, 2004, I mailed a copy of Motion for Leave to Withdraw as Counsel to the following person at the following address by regular U.S. Mail, delivered to addressee only: Daniel E. March 166 Cold Spring Road Carlisle, PA 17013 Jane M. Alexander, Esquire Attorney for Plaintiff 148 South Baltimore Street Dillsburg, P A 17019 I verify that the statements made in the foregoing Certificate of Service 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. ANDREWS & JOHNSON By: Ronald E. Johnson, Esq. Attomeys for Defendant 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 ANDREWS & JOHNSON Attorneys at Law 78 W. Pomfret Street Carlisle, PA 17013-3216 TAYLOR P. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 June 8, 2004 Daniel E. March 166 Cold Springs Road Carlisle, P A 17013 RE: Custody hearing regarding Raven Dear Dan: We previously had a continued Custody Conciliation H~aring scheduled for May 14,2004 on the above captioned matter. I had no prior contact from you regarding this hearing nor in spite of several attempts to reach you, have I heard anything further from you regarding this matter. Since you did not appear at that hearing it was continued generally but I have had some discussion with Tiffany's attorney, Sean M. Shultz, regarding a resolution to 1his matter. Since however you have not responded to any of my messages I presume that I am no longer representing you and that you will either be proceeding on your own or obtain other representation. This is including the support conference scheduled for June 11, 2004 at 9:00 a.m. For purposes of the fee retainer you previously paid I am agreeable to accepting that retainer as payment in full for services rendered through this date and there will be no further billing. Should you have any questions, please feel free to contact me. Sincerely, ANDREWS & JOHNSON Ronald E. Johnson, Esq. REJ:ss Enclosure cc: Sean Shultz, Esquire EXHIBIT I A (") c ;~-: ..... .~.~ rf' ~ '~: ;.~ :c (fi :~. ~('. /;( ~~~ ~'1 -< ..., c.=> = ""- (/) ,...., " I W -0 ~ - ~ -t I n,:D ,-- -om :pO ()(.L Sj.-d ~~? ;~~ (")n1 ~ --< 'i? r:J CO DANIEL E. MARCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW TIFFANY M. BRIDI Defendant : NO. 03-394 CIVIL TERM : IN CUSTODY MOTION FOR LEAVE TO WITHDRAW AS COUNSEL Ronald E. Johnson, Esquire respectfully represents the following in support of this Motion: 1. In January 2004 Petitioner, Ronald E. Johnson, Esquire was retained by Plaintiff, Daniel E. March to institute a custody action and represent him at a custody conciliation. 2. The custody action concerned the custody of Raven S. March and a conciliation conference was held on February 26, 2004 at which the Plaintiff and your Petitioner were in attendance. 3. At the time of that custody conciliation a further conciliation conference was scheduled for May 14, 2004 but the Plaintifffailed to appear at that conference. 5. Your Petitioner left several phone messages for Plaiintiffto contact him, but the Plaintiff failed to do so. 6. As a result of the Plaintiff's failure to appear or otherwise contact the Petitioner, the Petitioner sent a letter to the Plaintiff dated June 8, 2004 advising the Plaintiff that he would no longer represent him. A copy of that letter is attached hereto and marked Exhibit A and made a part hereof. 7 . Your Petitioner has had absolutely no contact from the Plaintiff prior to or subsequent to the letter dated June 8, 2004 and seeks leave of court to withdraw as counsel in the above captioned case. WHEREFORE, Petitioner prays Your Honorable Court to issue a Rule to Show Cause returnable within 15 days of service directing the Plaintiff to Show Cause why his counsel Ronald E. Johnson, Esquire should not be granted leave to withdraw as counsel in th~ above captioned case. ANDREWS & JOHNSON By: DANIEL E. MARCH Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. TIFFANY M. BRIm : CIVIL ACTION - LAW Defendant : NO, 03-394 CIVIL TERM : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, , 2004, I mailed a copy of Motion for Leave to Withdraw as Counsel to the following person at the following address by regular U.S. Mail, delivered to addressee only: Daniel E. March 166 Cold Spring Road Carlisle, PA 17013 Sean M. Shultz, Esquire Attorney for Defendant 19 Brookwood Avenue Suite 106 Carlisle, P A 17013 I verify that the statements made in the foregoing Certificate of Service are hue 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. ANDREWS & JOHNSON By: Ronald E. Johnson, Esq, Attorneys for Deflendant 78 W, Pomfret Street Carlisle, PA 17013 (717) 243-0123 ANDREWS & JOHNSON Attorneys at Law 78 W. Pomfret Street Carlisle, PA 17013-3216 TAYLORP. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 June 8, 2004 Daniel E. March 166 Cold Springs Road Carlisle, P A 17013 RE: Custody hearing regarding Raven Dear Dan: We previously had a continued Custody Conciliation Hearing scheduled for May 14, 2004 on the above captioned matter. I had no prior contact from you regarding this hearing nor in spite of several attempts to reach you, have I heard anything further from you regarding this matter. Since you did not appear at that hearing it was continued generally but I have had some discussion with Tiffany's attorney, Sean M. Shultz, regarding a resolution to this matter. Since however you have not responded to any of my messages I presume that I am no longer representing you and that you will either be proceeding on your own or obtain other representation. This is including the support conference scheduled for June 11,2004 at 9:00 a.m. For purposes of the fee retainer you previously paid I am agreeable to accepting that retainer as payment in full for services rendered through this date and there will be no further billing. Should you have any questions, please feel free to contact me. Sincerely, ANDREWS & JOHNSON REJ:ss Enclosure cc: Sean Shultz, Esquire Ronald E. Johnson, Esq. I eXHIBIT .4 ....,.,.;' l'';':; , ~ .~~ (/J [~ ~_s:: (' " >?+~: ."7 ~ (') fF '" => = J<" U, r<1 -0 I W -0 ~ o .,., :::l fJ-;:':! r- -om 6'( __,0 Q~~ ("'~~ III j .:-{ 55 ~-< w = "" MICHEAL R. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA VS. : CIVIL ACTION - LAW : NO. 2003-394 CIVIL TERM LAUREL A. WILSON, Defendant : IN DIVORCE PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Please withdraw the complaint in the above captioned Divorce Action. Respectfully submitted, '~ ;It ~ ,. . acq ine M. Verney, ESqUire~ 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff '.""-J (.,