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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
. 9•
STATE OF 6-rw? PENNA.
_KATHLEEN A. WILDAUER,_..__ _....-
4805 99
No ......................... ................. 19
-.-Plaintiff
Versus
DAVID DEVRIES,
_ Defendant _
DE CRE E IN
DI VO RC E
AND NOW, ..........J7. !-.. ..... 19 ...... 99 , it is ordered and
KATHLEEN A. WILDAUER
decreed that .................................................. plaintiff,
and ..... ,DAVID DEVRIES ................................. • , , 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
...........................................................................
irr ??. rs. .A:• +W,
B T Court:
Allest:
Prothonotary
J
? THERESA BAnw WALE
7L COUMELOR AT LAW
I IS PINE STREET
HARRissm, Pe NLSnvAN1A t7101
(717) 233-3220
y
Theresa Barrett Male
Supreme Court X46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v : NO. 99-4805
DAVID J. DEVRIES,
Defendant CIVIL ACTION - 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:
1. Ground for divorce: irretrievable breakdown under § 3301(c) 3301(d)(1) of the
Divorce Code.
2. Date and manner of service of the complaint: Acceptance of Service signed by
defendant on August 14, 1999, and filed of record on August 17, 1999.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution ofZfia a ndavit of consent required by § 3301(c) of the Divorce
Code: by plaintiff: November 17, 1999; by defendant: November 17, 1999.
(b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: N/A
(2) Date of filing and service of the plaintiff's affidavit upon the respondent: N/A
4. Related claims pending: None
5. (Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached: N/A
(b) Date plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the
Prothonotary: concurrently with the filing of this praecipe.
Date defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary:
concurrently with the filing of this praecipe.
wu??c?kt?LL?C?? `?-
Counsel For Plaintiff
Dated: November 19, 1999
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Theresa Barrett Male
Supreme Court X46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v
DAVID J. DEVRIES,
Defendant
?1 r rte.
NO. Q /?- 'Ydor U l f ` _ /
CIVIL ACTION - 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
importult 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, Cumberland County Courthouse, South Hanover Street, 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 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
Cumberland County Courthouse - 4th Floor
1 Courthouse Square
Carlisle, PA 17013-3387
(717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
BY THE COURT.-
I.
2
Theresa Barrett Male
Supreme Court #46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
V.
NO. 9 7e r-^
DAVID J. DEVRIES,
Defendant CIVIL ACTION - DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Kdthleen A. Wildauer [Social Security # 148-38-04521, who currently
resides at 27 Circle Place, Camp bill, Cumberland County, Pennsylvania since August 1997.
2. Defendant is David J. Devries [Social Securuty # 057-36-5777], who currently
resides at 4177 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania since
August 1997.
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 parties were married on September 21, 1987 in Lancaster, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The marriage is irretrievably broken within the meaning of section 3301 (c) of the
Divorce Code.
7. Neither party is a member of the armed forces of the United States or its allies.
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.
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce under section
3301(c) of the Divorce Code, as amended.
Theresa Barrett Male, Esquire
Supreme Court ii 46439
115 Pine Street
Harrisburg, Pennsylvania 17101
(717) 233-3220
Counsel For Plaintiff
Date: August 9, 1999
2
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VERIFICATION
I, Kathleen A. Wildauer, state upon personal knowledge or information and belief that
the averments set forth in the foregoing document are true.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§ 4904, relating to unsworn falsification to authorities.
Kathleen A. Wildauer
Date: August , 1999
THERESA BARREIT MALE
MUNSELOR AT LAw
115 PwE STREET
HARMIRM. PE a7YLVANA 17101
(717) 233-3220
Theresa Barrett Male
Supreme Court #46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v
NO. 99-4805 Civil Term
DAVID J. DEVRIES,
Defendant CIVIL ACTION - DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on August
10, 1999.
2. The marriage of plaintiff and 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.
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.
l/ /
DeVries
Date: November / 7 , 1999
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.. THERESA BARREIT MALE
COUNSELOR AT LAW
ma==r, 115 PM SnEEr
HAUt==. ftminvAWA'17101
(717) 233-3220
Theresa Barrett Male
Supreme Court #46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v
. NO. 99-4805 Civil Term
DAVID J. DEVRIES,
Defendant : CIVIL ACTION - DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on August
10, 1999.
2. The marriage of plaintiff and 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.
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.
J61§We9,0 /?-• i?4 4' &C'4 ?
Kathleen A. Wildauer
Date: November 7 , 1999
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Theresa Barrett Male
Supreme Court #46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v NO. 99-4805 Civil Term
DAVID J. DEVRIES,
Defendant CIVIL ACTION - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand 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.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
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
unswom falsification to authorities.
Date: November-, 1999
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' THERESA BARRL 1VlALE
COUME .at AT utw
-- 115 Pen Srucr
HURtsetam, PuasnmmA 17101
(717) 233-3220
Theresa Barrett Male
Supreme Court X46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v . NO. 99-4805 Civil Term
DAVID J. DEVRIES,
Defendant CIVIL ACTION - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand 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.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
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.
/?-?c.l M.2PyI #v ?(/I t,,xN.ti(,?Y
Kathleen A. Wildauer
Date: November I 7 , 1999
?- w<_
Thoreau Barrett Male
Supreme Court X46439
115 Pine Street
Harrisburg, PA 17101
(717) 233-3220
Counsel for Plaintiff
.. THERESA BARRETT MALE
COLR'QELOR AT LAW
115 Pt,%STRUT
. . °u"r, PcWa WMA'17101
(717) 233-3220
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN A. WILDAUER,
Plaintiff
v NO. 99-4805 Civil Term
DAVID J. DEVRIES,
Defendant CIVIL ACTION - DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce.
Date: August 1999
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