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Home My WebLink About04-0276IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON P. WILES, Defendant : NO. 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 relief requested in these papers by the Plaintiff You may lose money or property or other rights important to you. When the grounds 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 Court House, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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. 1F 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 ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON E WILES, Defendant NO. CIVIL ACTION - LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe tomar accion con pronfitud. Se le avisa que si not se defiende, el caso puede proceder sin usted y decreto de divorcio o anularniento puede set emitido en su contra pot la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados pot el demandante. Usted puede perder dinero, o propiedades y otros derechos importantes para usted Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Permsylvania 17013. SI USTED NO RECLAMA PENSION AL1MENTICIA, PROPLEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USED PUEDE PERDER EL DER. ECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA 1NDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telefano: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kara G. Wiles, : NO. (~ -- o~9]o Plaintiff : : CIVIL ACTION - LAW Deron P. Wiles, : Defendant : IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Kara G. Wiles, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and 1 participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: Kara G. Wiles IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON P. WILES, Defendant NO. Oq -- CIVIL ACTION - LAW 1N DIVORCE COMPLAINT IN DIVORCE AND NOW, this ~ day of January, 2004, comes the Plaintiff, Kara G. Wiles, by her attorney, G Patrick O'Connor, Esquire, Office of G Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: 1. The Plaintiff, Kara G. Wiles, is an adult individual who currently resides at 509 Grant Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Deron P. Wiles, is an adult individual who currently resides at 2500 Lisbum Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiffand Defendant were married on or about May 3, 2000, and separated on or about March 15, 2001. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of counseling and the fight to request that the Court require the parties to participate in counseling. 7. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiffrequests your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely, Respectfiffiy submitted, 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 ID No. 64720 Attorney for the Plaintiff VERIFICATION I, Kara G. Wiles, state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unswom falsification to authorities under 18 Pa.C.S. Sec. 4904. KARA G. WILES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON E WILES, Defendant NO. 04-276 Civil Term CIVIL ACTION - LAW IN DIVORCE .AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA. R. CIV. P. 1920.4 G Patrick O'Connor, Esquire, being duly sworn according to law, deposes and says that he mailed a copy of the Complaint in Divorce filed in this matter by certified mail, return receipt requested, addressee only, to the Defendant c/o SCI-Rockview, Box A, Route 26, Bellefonte, Pennsylvania 16823. The return receipt signed by the Defendant is evidence of delivery to him and is attached as Exhibit "A". I verify that the facts contained above are true and correct to the best of my knowledge, information and belie£ I understand that the facts herein are verified subject to the penalties for unsworn falsification to authorities under Crimes Code, Section 4904 (18 Pa.C.S. §4904). 3105 Old Gettysburg Road Camp Hill, PA 1701 l Phone 717-737-7760 Attorney for Plaintiff 7002 0460 0000 9761 8091 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON P. WILES, Defendant NO. 04-276 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 21, 2004 and service made on the Defendant on January 29, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 1 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. Kara G. Wiles, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON E WILES, Defendant NO. 04-276 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 aider it is filed with the Prothonotary. I verify that the statements made in the foregoing are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARA G. WILES, Plaintiff VS. DERON E WILES, Defendant NO. 04-276 Civil Term CIVIL ACTION - LAW : 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 21, 2004 and service made on the Defendant on January 29, 2004. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry ora 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. Section 4904 relating to unswom falsification to authorities. DATE: ~ Dfft~i IZ Wiles, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN/A KARA G. WILES, Plaintiff VS. DERON P. WILES, Defendant NO. 04-276 Civil Term ; CIVIL ACTION - LAW · IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 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 the foregoing 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. KARA G. XWILES, Plaintiff VS. DERON E WILES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-276 Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD Grounds for divorce: ,/ Section 3301(c) oftheDivorce Code Section 3301(d) of the Divorce Code (a) Date complaint filed: January 21. 2004 (b) Date of service of the complaint: January 29. 2004 (c) If service 30 days after date of filing, date complaint reinstated: (d) Manner of service of the complaint: ,/ Certified mail, restricted delivery to and return receipt signed by defendant First-class mail-not returned, certified mail refused, 15 days have elapsed Date of mailing: Date certified mail refused: Personal service by Sheriffand/or Deputy Sheriff Personal service by competent adult other than Sheriff (Affidavit attached) ____Acceptance of service (Copy attached) ___By publication pursuant to Order of Court (Copy of Order attached) Affidavit of consent required by Section 3301(c) of the Divorce Code: May 4. 2004 (a) Date of execution: plaintiff.' May 4. 2004 defendant: Date of filing: plaintiff: contemporaneously herewith defendant: contemporaneously herewith (b) Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: Date of execution: Date of filing: Date of service upon defendant: Manner of service: Related claims pending: None. All economic claims have been settled. (a) Date of service of the notice of intention to file praecipe to transmit, a copy of which is attached: Manner of service: (b) Date waiver of notice to file praecipe to transmit was filed with the Prothonotary: By plaintiff: contemporaneously herewith By defendant: contemporaneously herewith VERIFICATION I verify that the statements made in this praecipe are true and correct, I understand that false statements herein are made subject to the penalties of 18 PaC. SA §4904 relating to unsworn falsification to authorities. Date IN THE COURT OF COMMON PLEAS KARA G. WILES, OF CUMBERLAND COUNTY STATe OF PENNA. NO. 04-276 Plaintiff Civil VERSUS DERON P. WILES, Defendant AND NOW, DECREED THAT AND DECREE IN DIVORCE Kara G. Wiles Deron P. Wiles ,'~, IT IS ORDERED AND ,PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT I~ETAINS 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. All economic claims have been settled. BY*HE COURT: PROTHONOTARY