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HomeMy WebLinkAbout01-03555 , "",,-_., ,-~ . ,- ~, .. . ff. '" "'if. ;F.;t; . . . . . .. . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. . STATE OF . ROY E. WILLIAMS. JR., . . plaintiff, No. 2001-3555 VERSUS YOLANA JO SHOCKEY, Defendant. . . . DECREE IN DIVORCE . . . s, p.t .-, ~c j 2. L-, 2DO I , IT IS ORDERED AND AND NOW, DECREED THAT Roy E. Williams , Jr. , PLAINTIFF, AND Yolana Jo Shockey , 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. . . . .. By THE COURT: ATT T: ~ J. .~" OTHONOTARY . . iF. iF. iF. '" ff. ;tiff. ff.ff. "';t; ff. '" ff. ff. , ~rr'T .,r, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . j\f<:\~C . ""-,.,. ,;.(, ,i ~lll!.,,,,,".. . -~~liliil1~~"li",,;",,_'~~il:I;!~ill- tf.d~ .t)/ fcZ '/J( ~~ v., u "~"_ ",' '_' ^'>___ .,-,..,> ,"",,,,,,,,,,",,,,_, ~~_ =,_,_ -"'_. "'_~ __So _, ^" lfIt.llilltlb.:~",..,,~ ~ -, '>,' f!d-(}y~ ~ 4 '71~~ ~~~ " , ..~ '-'-=" .' - ~ ~,- """" '''~,oiO;'"-'--- - ,I U] ~ - n , !. Michael S, Travis ill No, 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR., Plaintiff, vs. ) ) ) ) ) ) No. 2001-3555 YOLANA JO SHOCKEY, Defendant. CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under 9 3301(d)(I) of the Divorce 2. Date and manner ofserviee of the complaint: June 152001, Affidavit of Service attached hereto. Note that the eomplaint incorrectly states the defendant's name in the caption. Caption was corrected by amended complaint on June 27, 2001. 3. (a) Date of execution of the affidavit required by!i 3301(d) of the Divorce Code: by plaintiff July 20, 2001; (b) Date of filing and service of plaintiff's affidavit upon the respondent: July 23, 2001 (filed), July 25, 2001(served). 4. Related claims pending: No claims were raised by the complaint. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy ofwhieh is attached: August 15,2001, US ail first class postage prepaid. . Travis Attorney for Plaintiff -'I"!Il'l ,-:,:,:~,>; '; ","",,', ',- ''I;',y~" <, ." ~'\ I""l~ _;> d ',,'~-- ~..;l I '" ,. , "','0'"',","" "", , ,,,.,,,",' "" "- " .- '" ~ ~'- ,1 , _~~,'_ ,'"_ _'",~\ _--'~C<_"~'!,;,~ ",., ,_,~,~; " ," "'~~",,,,~~'''''' "''''IIW] III' mlllH]l1T I L T ("" ~"nri (') c s:: 'UCO rrtm 2;rj 2;r Cf)b -<"". !,20 ?:o ~o -c z ::< (] C> c.:; <:.:> o " C') 1"'1 -0 '::11.::rJ -nfT! :"3jC5 :-;~!~~~ g~ 't;j 5j -< c::; v -';;'~ ~ U1 a _ ~~j;U$~,"",~~~I!~1r ""!""W:"'~f':'Fl~' " " . , , In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR., Plaintiff, ) ) ) ) ) ) No. 2001 - 35.5')' CIVIL TERM IN DIVORCE vs. YOLANDA WILLIAMS, Defendant. 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 aetion. 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage eounselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 J~i ,1,H" ,,/.i",'~,"" -"',~ "^_ >, -,',~.'-, '_- !~"111 e_.' 'f"-' .,,' ,'- ,-, . , In tbe Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR, Plaintiff, ) ) ) ) ) ) No.2001- 365c5' CIVIL TERM IN DIVORCE vs. YOLANDA WILLIAMS, Defendant. NOTICE OF A V All..ABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302( d) ofthe Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. '~""l; _" ~ ~. r',1 _ 0-'1"':-. )~~,.-l_, '_~,,_ _ ..-' _,' I~ 1'''''' ~ , ..0"" 'T' - ~ ,- . , Michael S, Travis ill No, 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANDA WILLIAMS, Defendant. ) ) ) ) ) ) No. 2001- 3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by his attorney Michael S. Travis, respectfully represents: 1. Plaintiff is Roy E. Williams, Jr., who resides at 716 State Street, Lemoyne, Cumberland County, Pennsylvania, 17043, since Oetober 15, 2000. 2. Defendant is Yolanda Williams, who resides at 1406 S. Mattis Avenue, Champaign, Champaign County, Illinois, 61821, for an unknown period of time. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on Apri112, 1998, in the Country of Broward, Florida. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdietion. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. c."".. .I".,_.~ c,'''~_'.'"',~,_'_ __ "c" "-"1::"1,,' ,c.._ _",r_ <-";',' -.' '~"~r--~ ~,_ '"-., '--~- . ~ ," ~~,-',,,- - r . , , 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Neither plaintiff nor defendant are in the Military Service in the United States Armed Services. Neither plaintiff nor defendant are within the provisions of the Soldiers' and Sailors' Relief Aet of Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of divorce. I 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. 94904, relating to unsworn falsification to authorities. Date: G{o-oIOI ~~i~~~~' Plaintiff ael S. Travis Attorney for Plaintiff J.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731.9502 Fax 731-9511 ~'l _ ",<,'." -".-' "-fT' ,- 'l , - , In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 ROY E. WILLIAMS, JR., Plaintiff, vs. CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF S 3301(d) DIVORCE DECREE TO: Yolana Jo Shockey 1406 Mattis Avenue Champaign, IL 61821 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the S 3301(d) affidavit. Therefore, on or after September 5, 2001, the other party can request the court to enter a final deeree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court ean enter a [mal decree in diVorce, A counter-affidavit, which you may file with the prothonotary of the court, is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE TillS 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 >,,~. '-, II . In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR., Plaintiff, YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 CIVIL TERM IN DIVORCE vs. COUNlER.AFFIDA VIT UNDER ~ 3301(d) OF THE DNORCE CODE 1. Check either (a) or (b): D ( a) I do not oppose the entry of a divorce decree. D (b) I oppose the entry of a divorce decree because (eheck (i), (ii) or both): o (i) The parties to this action have not lived separate and apart for a period of at least two years, o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): D (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. D (b) 1 wish to claim eeonomic reliefwhieh may inelude alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my eeonomic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce deeree may be entered without further delay. 1 verifY that the statements made in this counter-affidavit are true and eorreet. I understand that false statements herein are made subjeet to the penalties of 18 Pa. e.S. ~ 4904 relating to unsworn falsification to authorities. Date: Y olana 10 Shoekey, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT Fll..E THIS COUNTER-AFFIDAVIT. "t",","~ " ,'-1' rl .> I . . In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. CERTIFICATE OF SERVICE I, Michael S. Travis, certify that a true and correct copy of the Notice of Intention to Request Entry of Section 3301(d) Divorce Decree together with Counter-Affidavit Under Section 330l(d) of the Divorce Code was served upon the Defendant on August 15, 2001, by first class mail, postage prepaid, on the following person, addressed as follows: Yolana Jo Shockey 1406 Mattis Avenue Champaign, IL 61821 Dated: f-/p",,,1 ~- ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff '-'-~""__ A' n -.."-" <, ~':,]j, .< ~-', ~- "";~ -"I;~ - ~,_ --. ""T" . -~ .~-~~. ~ . ~~II! - -, ~~ IIIJD i1 . g Cd I"', :rl ;?: (/) -..-; -00:: 01 -T~ mil''. -0 \ l':t.; Z:T_J ;~\~, zr' 0 ~3E ~c'; ~; ~~ ~~~ ~Q .~, S;CJ r;.;> oil; , c:: ~ z c- ~ ~ GO cG Cc, ~1ilIi~~fJf'_~"W"~~i0!iW-}}tl~,*}~~~1I1",,-li',",'~W'1"-w.l~'~~ , ; ,~ .. In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF TIIE DNORCE CODE L Cheek either (a) or (b): D (a) I do not oppose the entry of a divoree decree. D (b) I oppose the entry of a divoree decree because (check (i), (ii) or both): D (i) The parties to this aetion have not lived separate and apart for a period of at least two years. D (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): D (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. D (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. 1 understand that in addition to ehecking (b) above, I must also file all of my eeonomic claims with the prothonotary in writing and serve them on the other party. Ifl fail to do so before the date set forth on the Notice of Intention to Request Divorce Deeree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: Y olana Jo Shockey, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ',"'..,,,,- M_"'.__,_ 'f'I ;-'1 "- ~ ~""'''''< . " ~ . .... J: In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 ROY E. WILLIAMS, JR., Plaintiff, VS. CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Michael S. Travis, certify that a true and correct copy of the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code together with Counter-Affidavit Under Section 3301(d) of the Divorce Code was served upon the Defendant on August 15, 2001, by first class mail, postage prepaid, on the following person, addressed as follows: Yolana Jo Shockey 1406 Mattis Avenue Champaign, IL 61821 Dated: 1-jp,..~/ . hae S. ravis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, P A 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff ,0",_,", ',- n I -,,,,,", ~;t1~A; ."~--'~~ "~. ~O ,_ $N~yr r --, :. . ""'" "'"',-" , ~''''f'l'IlI 1111' IUbi! 4. '. . () CJ 0 ~ -n (/) ..... -00:1 r-1 ~fi ~~ mrn -0 Z:TJ -,--r~ ZC;:; C> ~~~~ (nJ;:~ ~""'.::. ~o -0 ~,~2~ ~o ::<: -0 I:Y t;m >c: --4 Z t=" ~ =< co (.5 c~ ~.~~~~(t~;~,*i0Ml~f#\~_~I~Il:$J~m~~R1;~~l ,,", ., .',--)"', <_r_.,,~ '-', ,'--" _ .'-,.,'-', ill Qpmpleteitetns 1,2, and 3, AlSo complete il'em 4 if Restricted Delivery is desired. . Prl~t your name and address on the reverse t- we can return the card to you. card to the back of the mallpiece, ont if space permits. ~;;;:;;, "",u.;h7'J' 1,,/t){.A~O~ ~ (!'M71foM"~- f'l, ~/5~1 2. Artie "~-_.~ , - PS Fo~ I" ' 1^-~' -, t, ~, o Agent o Addressee DYes ONo 3. es I !595-00.M-0952 (, '~~.... +; In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. AFFIDAVIT OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned aetion for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. 70001670000089540212, return receipt requested, by depositing the same in the United States mail on June 8, 2001, pursuant to Ru1e 1920.4 of the Amendments to the Pennsylvania Ru1es of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was reeeived by the Defendant on June 15,2001. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. clia . ravis 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 ;C-,_ , __=__ , -,~ - . ~,- II - I I. F il II H " !:I u H !':}i_ " .. -<-','"" !l"~,_"""" . "" ';"', ,'i (") <::> 0 ~ -r, en :~::-1 -om rT1 t~~~ m,n -0 Z:::D ~~~, zt.. Cl cn.J:; '-'(L !2C) :z -:..'-.''''' "'c ~ r~")r:;; 26 -";."...... ):>c ~ ~'" L. ,f;"" ~ -' -< (}:) <f G . ", _..,~".8!l.lli:~ ~- llffimI'~Jj'~Wyktl1:1!l~"0\'ll~~r>P'-:.oI~it'!~f.>Ji~IW,~11,11f;!~!J!!!U~~~~ i In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001 - 3555 ROY E. WILLIAMS, JR., Plaintiff, vs. CIVIL TERM 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 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: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 ~., . ~ ~ " -i.,'1~1 . I --.'. , ' In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant, ) ) ) ) ) ) No. 2001- 3555 CIVIL TERM IN DNORCE ROY E. WILLIAMS, JR., Plaintiff, vs. NOTICE OF A V All..ABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in aceordance with Section 3302( d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Offiee, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days ofthe date on which you receive this notice, Failure to do so will constitute a waiver of your right to request counseling. -~,. 7"" ~ - - . ,,,"",- - ,~,- IT Michael S, Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR., Plaintiff, ) ) ) ) ) ) No. 2001 - 3555 CIVIL TERM IN DIVORCE vs. YOLANA JO SHOCKEY, Defendant. AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE AMENDED TO CORRECT CAPTION AND DATE OF MARRIAGE Plaintiff, by his attorney Michael S. Travis, respectfully represents: Paragraphs 1 - 10 of the original complaint are incorporated by reference herein. 11. Plaintiff is Roy E. Williams, Jr., who resides at 716 State Street, Lemoyne Cumberland County, Pennsylvania, 17043, since October 15,2000. 12. Defendant is Y olana Jo Shockey, who resides at 1406 Mattis Avenue, Champaign, Champaign County, Illinois, 61821, since April 1999. 13. The caption of the original divorce complaint incorrectly states that the name of the Defendant is Yolanda Williams. The correct spelling of the defendant's name is Y olana Jo Shockey. Defendant did not take the plaintiff's name when they married 14. Plaintiff requests that the eaption be amended to indicate the correet spelling of defendant's name. 15. The parties were married September 6,1998, in the County ofBroward, Florida, not April 12, 1998 as originally stated in plaintiff's complaint. 16. Plaintiff requests the court to enter a decree of divorce. I I i i i I I I !"-;"'''lM:l!I! - ^ "~ ',.,'1':1, . .:1' "~ I verify that the statements made in this Amended Complaint 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: fb J a<,fOi 1 t'.uJ~ Roy E. Williams, Jr., Plaintiff , ichael S. Travis Attorney for Plaintiff J.D. # 77399 4076 Market Street, Suite 209 Camp Hill, P A 17011 (717)731-9502 Fax 731-9511 ~, - ~ 1" In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001 - 3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. CERTIFICATE OF SERVICE I, Miehael S. Travis, certify that I have this day served a true and correct eopy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Y olana Jo Shockey 1406 Mattis Avenue Champaign, IT., 61821 Dated: 6- -A7-e> I . . el. Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff '^'\ffl~ 1"'1 II I ~ ~ - ~' " 'J;'. ,~ , " ~ "'~~ ~~ - ,~ ~ . .,," , ~,.~/. I T Q 0 C. C) ~ '., ~ ! " ::::c.. ~ ~} c.,' n-, , t -::-.... "" L [- "'~ ~'? , '-~ rv ~0 s i~~ N , -'"1 .;:-:;. C. --.' ('~j '- )c; (.:...: c:' C., ,Hi 1 ? z: :11 ':'r:~ -,~ jj v, -< .1'" -C:: -< '" S f"J (.0 ~"'-' , "._,.,..,.".,I!'~~-iti~-r~_1~-i!il>'Y-!'0'''~'F;~;':':k',W~'0::f'':;,W~fJj~i''f*i.W~ih''1t'~i",")F;'10f_'''<;!lffl;JH!~~j~~~ In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR., Plaintiff, YOLAN' A . JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 vs. CIVIL TERM IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted: AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or before October, 1998, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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. ~ 4904 relating to unsworn falsification to authorities. Date: .7/;)....b~1 I ".I", '~'-_-"".-"';:~"_1'_~ ---.-~, ~_'I__~~C '.' ;-,-::,!:"'-'r"1 ~- ~-~-":' '> , " I' "., - ~--,"-,...,~ ,~ . , Ii ii " ii ii i:",.I.- "_,"~ '" ,H" '. '''''' . .'''~:~'-''~ '",')\ '.-- "' ~. ~~[QJ 0- o ~ ('> N VI w ,.j '" "" ) --_f~~ _ ,'__ _''.__ _,_~f'ltlWt~ m C) ~ ~C-,--:: I. L ".) C,,':;. (S ~ ~~~~!t'r,~~.,,~. . (It,,! ~. ,<i'-"1~~ MICHAEL S. TRAVIS ATTORNEY AT LAW 4076 MARKET STREET, SUITE 209 CAMP HILL, PA 17011 TELEPHON,E (717) 731-9502 FAX (717) 73lM9511 September 19, 2001 HAND DELIVERED Curtis R. Long Prothonotary One Courthouse Square Carlisle, P A 17013 RE: Roy Williams, Jr. v. Yolana Shockey, No. 2001-3555, In Divorce Dear Mr. Long: Enclosed please fmd the plaintiff's Amended Certificate of Service for plaintiff's Affidavit Under Section 3301(d) of the divorce code with correct date of service upon defendant. The date of service was incorrectly stated on the original Certificate of Service but correctly stated on the Praecipe to Transmit Record. Kindly have the Court enter the divorce decree. Please contact me should you have any questions or concerns. s, c ae S. Travis Attorney for Plaintiff MST/hm Enc!.: Certificate of Service pc: Plaintifti'Defendant : 'Vi ~_ ,~ " _'"_Y_'o , ,"O,"",=_,_~__,"",;_;-"".~,_, ., ~- ____~L.", _,~:- ;- -FI'-" ' _ ,,'~' ...,~ . "\'-C'O- -,'- ^.', _I .'_ "'--', ~ -"." ,_."... I I I I~r ,~ ~, '"'- (5 CO - '~-' -,--.~--~ - .." -- 0_.. ", ~. c. , ,,~_". ',1-' ',',,__ ..',< , .co",'",,',-,,;"O,,",-.."""" -",- "1l.'-~'''fr1rIil1l'1 ' .- 11m WI ,~, ,'"~ -". 7", iTi:nTl"i ~......",",~;J\Ut~,~f\IfflF~~~'-~;~~~$j~I~~~~I~I~.lIt~, _ .>;". _l~_~: . , In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. AMENDED CERTIFICATE OF SERVICE I, Michael S. Travis, eertify that a true and correct copy of the Plaintiff's Affidavit Under Section 3301 (d) of the Divorce Code together with Counter-Affidavit Under Section 3301 (d) of the Divorce Code was served upon the Defendant on July 25,2001, by first class mail, postage prepaid, on the following person, addressed as follows: Y olana Jo Shockey 1406 Mattis Avenue Champaign, IL 61821 Dated: cJ-/f-t?1 i e . ravis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff :'""" '''r''l L _ ~. .~o -------- , d In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. wn.LIAMS, JR., Plaintiff, YOLAN A . JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 vs. CIVIL TERM IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be adnlltted: AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or before October, 1998, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is gtanted. I verify that the statements made in this affidavit are true and eorreet. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: "7!J.-b1v1 / R~ IAJ~ ~ Roy iams, Jr., P amV Pl, . ' ~ -f,-."r.'>' "1 . r-I,' " ",' ~ =~,'""""'" " ~' .' ,-/. /. . In the Court of Common Pleas of Cumberland County, Pennsylvania YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 CIVIL TERM IN DIVORCE ROY E. WILLIAMS, JR., Plaintiff, vs. COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF TIlE DIVORCE CODE 1. Check either (a) or (b): o (a) I do not oppose the entry of a divorce deeree. o (b) I oppose the entry of a divorce decree because (cheek (i), (ii) or both): o (i) The parties to this aetion have not lived separate and apart for a period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (a) I do not wish to make any elaims for economic relief. I understand that I may lose rights eoncerning alimony, division of property,lawyer's fees or expenses if! do not claim them before a divorce is granted. o (b) I wish to claim economic relief which may inelude alimony, division of property, lawyer's fees or expenses or other important rights. 1 understand that in addition to checking (b) above, I must also :file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notiee of Intention to Request Divorce Deeree, the divoree decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. Date: Y olana Jo Shoekey, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ~ ~"'-,'-""~ ,,--=,,;,:,^,~ I~ I ~ r k.! i."..,..,. '.~,'O .~''i" "'~. "",, " -~;.- '-j'., .. .... . ".....,". .. .,..'" ..",. u ., .. "1m I. Ii' 0 c) ',.,-" 0 C --'1 '":':"" c/') -ocf t" -;) { rnn' ''0 z::;:: -- .. z,.' ,---) cI5 '? \.0 f , -<:, .C} ...t:> t<c; :c-',. , l.. -,"I ~o ~~- ~~f'~ >8 5 ,..J ~ ~ '" ~ c,,) -< N W .'h S [5 [0 -,,,I'" ~.,.e.~~...~J~4ijr:l~~W!WJ~~~.~~~~~!l;~'J~fj~IVf!:lh~~'~1."N~'_P;u Michael S, Travis IV No. 77399 4076 Market Street, Suite 209 Camp Hill,PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania ROY E. WILLIAMS, JR., Plaintiff, YOLANA JO SHOCKEY, Defendant. ) ) ) ) ) ) No. 2001-3555 vs. CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORID To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under 9 3301(d)(1) of the Divoree 2. Date and manner of service of the complaint: June 15 2001, Affidavit of Service attached hereto. Note that the complaint incorrectly states the defendant's name in the caption. Caption was corrected by amended complaint on June 27, 2001. 3. (a) Date of execution of the affidavit required by 9 3301(d) of the Divorce Code: by plaintiff July 20, 2001; (b) Date of filing and service of plaintiff's affidavit upon the respondent: July 23, 2001(filed), July 25, 2001(served). 4. Related claims pending: No claims were raised by the complaint. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: August 15, 2001, US Mail first class postage prepaid. A Attorney for Plaintiff >1'" '. r'".~,-' '1'1 ,~' . .'~"" "r;,'_~~,__,,_. ~-~"", ,-"-"\C-,,,,,\~~,,-- o c: ? f:J ..~ ~CL ""1"-- 2~! ~!;:" :-< >- r--';:::'-- ~l_,-,' p- Z" '--n' ):>e z -/ -< rs [d '" Uillr1 rr w'" Q ,~ '__.J -n- U) '.. v r"1 :1'_ ,--:: '..c. ..; ::'"J , " c~~' (jfT: "'I b 0'0 -< ~ -'11~ 9 1'0 .::- ~- -: ."1"!, ' , _ _,.. _, ",~_", i_=r~,_]IT .,_,,_~_~_ --"-'-""c" __,Jrr~ .,"" ;~~W~~~ffi"fm'w1~~1~fff\!ImE~~i{~J!ijj'~~~~~~~ -,,,,",""""-1""_, ROY E. WILLIAMS, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW YOLANA JO SHOCKEY, : Defendant NO. 01-3555 CIVIL TERM ORDER OF COURT AND NOW, this 17ili day of September, 2001, upon consideration of Plaintiff's Praecipe To Transmit Reeord, and the eertifieate of service of Plaintiffs Affidavit under Seetion 3301(d) of the Divoree Code indieating that Plaintiffs affidavit was served at the same time as Plaintiffs Notice of Intention To Request Entry of ~3301(d) Divoree Deeree, in eontravention of the holding in Burdick v, Burdick, 41 Cumberland L.J. 64 (1991) (Bayley, J.), a divoree deeree will not be entered at this time, without prejudice to the parties' rights to eorreet the deficieney and file a new praeeipe to transmit.! BY THE COURT, 9_ J1.of c+ o ~ 0 ""of2 0) n"1 ('f{ rTJ i 5:~ -0 r::$ z,",' ...., c ~~' 'So- C) -" ~.- :::&: J:;-.....) ~ ~~ ~ C; () ~n Miehael S. Travis, Esq. 4076 Market Street Suite 209 - CampHill,PAI7011 ~ fYV'.'~'~ Attorney for Plaintiff ";'1 ::7] :re Bi~: ';:";'I-h _~':r:' (51111 i;! _0 "-<;; 1 The praecipe to transmit indicates that a correct sequence of service was followed, and it may be that an amended certificate of service is all that will be necessary to correct the deficiency, ,,~ <-~, - - . ,00""\\':':1',<-,. ,,:,z ,- .'_c, ;.'>'0 7J_'_,~.' ',n' _,_ ,re,''''I">I'- , ,~.