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Home My WebLink About03-2274KATHRYN M. WILLIAMS, Plaintiff VS. RICHARD J. W. BRASHEAR, Defendant 1/10/03 TRANSFERRED TO CUMBERLAND COUNTY. : IN THE COURT OF COMMON PLEAS : CAMERON COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NUMBER: 2002-2955 · IN DIVORCE ORDER TO TRAl~ISFER CAS~. AND NOW, this ~/~ day of ~ c~9/~ upon consideration of the within Motion to Transfer Venue, it is hereby ORDERED and DECREED that the above divorce action is transferred to the Court of Common Pleas of the County of Cumberland. Pursuant to Pa.R.C.P. No. 213(i), the Prothonotary of the Court of Common Pleas of the County of Cameron is directed to immediately transfer the record together with a certified copy of the docket entries to the Prothonotary of the Court of Common Pleas of the County of .nd. BI/' THE COURT: IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY Fifty - Ninth Judicial District NO: 02- 2955 RECORDED: 07/25/02 BOOK: PAGE: KIND: DIV 0 DEBT: $ 0.00 SURCHARGE: 10.00 PRO: 40.50 JCP FEE: 5.00 SAT DATE: 01/10/03 <PLAINTIFF> 1 WILLIAMS KATHRYN M <DEFENDANT> 1 BRASHEAR RICHARD j W JULY 25, 2002 - Plaintiff's Complaint in Divorce filed by CHARLES E. PETRIE, ESQ. SAME DATE: Certified copy of Complaint with endorsement thereon to plead to same, issued for service upon the defendant. Verification and Affidavit of Non-Military Service filed. AUGUST 26, 2002 - Letter received from Defendant, together with various RESPA forms, copies of checks, etc. All documents returned to Richard Brashear with letter to defendant from David Reed, prothonotary. DECEMBER 26, 2002 - Motion to Transfer Venue to Cumberland County filed by Atty. Petrie. Entire file sent to Judge in Misc. packet. JANUARY 10, 2003 - ORDER TO TRANSFER CASE - AND NOW, this 26th day of December 2002, upon consideration of the within Motion to Transfer Venue, it is hereby ORDERED AND DECREED that the above divorce action is transferred to the Court of Common Pleas of Cumberland County. Pursuant to PA.R.C.P. 213(f), the Prothonotary of the Court of Common Pleas of the County of Cameron is directed to immediately transfer the record together with a certified copy of the docket entries to the Prothonotary of the Court of Common Pleas of the County of Cumberland. BY THE COURT /s/ John H. Foradora, Specially Presiding. JANUARY 13, 2003 - Copies sent to the Court of Common Pleas of Cumberland County, Charles E. Petrie, Esquire and file. ~:~ · meron Co. KATHRYN M. WILLIAMS, Plaintiff VS. RICHARD J. W. BRASHEAR, Defendant : IN THE COURT OF COMMON PLEAS : CAMERON COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NUMBER: 2002-2955 : : IN DIVORCE MOTION TO TRANSFER VENU~ NOW COMES the Plaintiff, KATHRYN M. WILLIAMS, by and through his attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is KATHRYN M. WILLIAMS, who currently resides at 424 Walnut Street, Carlisle, County of Cumberland, Pennsylvania. 2. That Defendant is RICHARD J. W. BRASHEAR, who currently resides at Rappohanick Regional Jail, Stafford, Virginia. 3. That at the time of the filing of the Complaint in Divorce, Plaintiff believed that the divorce matter would be resolved with~u~ t:he necessiw of a master's he~ing 4. That Defendant has indicated the need for a master's e i g to resolve the issue of equitable distribution. 5. That Plaintiff is a resident of Cumberland CounW and Counsel for Plaintiff is a resident of Dauphin County. ~¢:<!!:l,;~ Irom ~ Plaintiff respectfully requests that Your Honorable .... O meron Oe. ' ourt enter an Order transferring venue to the Court of Common Pleas of Cumberland County, Pennsylvania, and directing that the Prothonotary of Cameron County transfer the case file to the Prothonotary of Cumberland County. Respectfully submitted, Charles E. Petrie 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff KATHRYN M. WILLIAMS, · Plaintiff · VS. · RICHARD J. W. BRASHEAR, · Defendant · IN THE COURT OF COMMON PLEAS CAMERON COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 2002-2955 IN DIVORCE CERTIFICATE OF SERVICe. I certify that I sent a copy of the foregoing Motion to Transfer Venue to the Defendant, RICHARD J. W. BRASHEAR, at Rappohanick Regional Jail, Stafford, Virginia, 22555, on December 24, 2002, by U.S. First Class Mail, postage prepaid. Respectfully Submitted, Charles E. Petrie 3528 Brisban Street Harrisburg, PA 1711 i (717) 561-1939 Attorney for Plaintiff KATHRYN M. WILLIAMS , Plaintiff VS. RICHARD J. W. BRASHEAR, Defendant · IN THE COURT OF COMMON PLEAS · CAMERON COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT.~ 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 Cu~t0dy visitation of your children. ,; ~ When the ground for the divorce is indignities or irretrievable b~reakdown of the marriage, you may request marriage counselihg; A: oI marriage counselors is available in the Office of the Prothonota~ Cameron CounW Courthouse, Emporium, PA. ~ i 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. DAVID J. REED, PROTHONOTARY CAMERON COUNTY COURTHOUSE EMPORIUM, PA 15834 (814) 486-3355 KATHRYN M. WILLIAMS, Plaintiff VS. RICHARD J. W. BRASHEAR, Defendant · IN THE COURT OF COMMON PLEAS · CAMERON COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW : · IN DIVORCE COMPLAINT UNDER SECTION 3301{c) OF THE DIVORCE COD~. Plaintiff is KATHRYN M. WILLIAMS who currentl~y r sides at 424 Walnut Street, Carlisle, County of Cumberland, ' PennsyJv~ma, since May 30, 2001 2. Defendant is RICHARD J. W. BRASHEAR, who ~n curr fly resides at Rappohanick Regional Jail, Stafford, Virginia, since Fe})r~{al-y~) 5,2002· 3. 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 June 22, 1998, in Leesburg, County of Loudoun, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken· 7. 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. 8. Neither party is a member of the Armed Forces of the United States of America or any of its Allies. 9. After ninety (90) days have elapsed from the date of service of this Complaint, plaintiff intends to file an Affidavit consentin~ td a'~ divorce. Plaintiff believes that defendant may also file such an a~ffidavit. WHEREFORE, if both parties file affidavits consenting to ~ d~v6~ce after nine~ (90) days have elapsed from the date of se~ice of this ~ ~.~ Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301 (c) of the Divorce Code. 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. Section 4904, relating to unsworn falsification to authorities. DATE: KATHRYhlrM. WILLIAMS , PLAINTIFF CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 ATTORNEY FOR PLAINTIFF KATHRYN M. WILLIAMS, Plaintiff VS. RICHARD J. W. BRASHEAR, Defendant ' IN THE COURT OF COMMON PLEAS · CAMERON COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NL~ER:' 2002- · IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICF, I, Plaintiff herein, do hereby depose and say that I am ad, vi,sed~ an~ believe that the above named Defendant is not presently in thd a?i? military service of the United States of America and I aver thatlth~e Defendant is not a member of the Army of the United States, ~ni~e~/. States Navy, the Marine Corps, or the Coast Guard n~ i .... ~__d ~ ca · -, ..... ~ nut lan omce.r~ of the Public Health. ServiCe detailed by proper authority for du~y ~ith tl~ Army or Navy; nor is Defendant engaged in any military or NeW dniiS covered by the Soldiers and Sailors Civil Relief Act of 1940 and~ designated therein as military service; nor has Defendant, to th'~ l~e~ of~'° my knowledge, enlisted in the military service covered by this act. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. 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. Section 4904, relating to unsworn falsification to authorities. DATE WILLIAMS KATHRYN M. WILLIAMS, Plaintiff VS. RICHARD J. W. BRASHEAR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: ~' ~~ IN DIVORCE PRAECIPE TO WITHDRAW Please withdraw Plaintiff's Complaint in Divorce transferred to Cumberland County Court of Common Pleas on January 23, 2003. DATE CHARLES E. PETRIE, ATTORNEY FOR PLAINTIFF