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HomeMy WebLinkAbout04-0694JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. be?' CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court for divorce. 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. Ajudgment 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 the CUMBERLAND County Courthouse, in 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. Office of the Prothonotary Cumberland County Courthouse Carlisle, PA (717) 240-6195 JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. : : IN DIVORCE COMPLAINT IN DIVORCE COUNTI DIVORCE AND NOW comes the above Plaintiff, Jennifer Ross-Williamson, by her attorney, Richard P. Mislitsky, Esquire, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Jennifer Ross-Williamson, is an adult individual who resides at 204 North 32~d Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Jon Williamson, is an adult individual who resides at 1295 Lowther Road, Camp Hill, Cumberland County, Pennsylvania 17011. The Plaintiff and Defendant are sui juris, mad both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were ma~ied on October 9, 1999, in Camp Hill, Cumberland County, Pennsylvania. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 6. Plaintiff and Defendant agree that the marriage is irretrievably broken. 7. There have been no prior actions in divorce between the parties. 8. Plaintiff has been advised of the availability of counseling and the Plaintiff may have the right to request the parties to participate in counseling. The parties have entered into a written agreement with regard to support, alimony and property division. The Agreement has been prepared and signed by the parties and request that the Agreement be adopted by the Court and made part of the Decree in Divorce. Same is attached as Exhibit "A". WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT II EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 12. Plaintiff and Defendant have agreed upon to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to divide ail marital property as per Exhibit "A" attached. 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 a.C.S.A. §4904 relating to unswom falsification to authorities. / )~nnif~f Ross-Williamson Richard P Mislitsky Supreme Court Id. # 28123 One West High Street Carlisle, PA 17013 (717) 241-6363 Attorney for Plaintiff 2 RECEIVED DE(: 0 2 200, November24,2003 Mr. Richard P. Mislitsky One West High Street P.O. Box 1290 Carlisle, PA 17013 Dear Rich: Per your recommendation, we have agreed on the division of our assets, and we will not use attorneys for this process. However, we will use your services to file for divome. We have split our assets, and neither one will seek for future support. The divorce should be filed on Jennifer's behalf and all costs associated with the filing should be billed to Jennifer. Furniture All furniture and other household goods have been divided. All items in Jennifer's possession will remain with Jennifer. All items in Jon's possession will remain with Jon. Aocounts There are no longer any joint accounts. The $9,430.99 in Jon's money market account will be divided 50/50. Upon signing this letter, Jori will provide Jennifer a personal check in the amount of $5,090.50. This amount includes 50% of the money from his market account as well as half of September's rent - $375. Dogs The dogs - Cajun and Sedona - will remain in Jon's custody. Jennifer has forfeited her right to care for or visit the dogs. Retirement, life insurance All retirement accounts are separate. Jennifer will not seek funds from Jon's accounts, and Jon will not seek funds from Jennifer's accounts. Cars The 97 Dodge Dakota is in Jon's name. Jennifer will continue to pay for the 99 Volkswagen Passat. Jon is not responsible for any future payments. School loans Jon is responsible for paying for his school loans from Drexel and York College. Jennifer's name is not on these accounts, and she is not responsible for these payments. Jennifer is responsible for paying her school loans to for her education. Jon's name is not on these accounts, and he is not responsible for these payments. If there are ally questions regarding the divorce or split of the assets, please do not hesitate to contact us. illiamron Jon C. llVilliamson JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW No. oq-&qq lvlc-- IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301 (c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and Defendant ils irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint on the Defendant. 3. I consent to the entry of a Final Decree of Divorce either after service of Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. §4909 relating to unswom falsification to authorities. )SS-~VILLIAMSON JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE ON INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF TItE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divorce without notice. 2. 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. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and 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. §4909 relating to unswom falsification to authorities. Date: JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT Date: I. A complaint in divorce trader §3301 (c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint on the Defendant. 3. I consent to the entry of a Final Decree of Divorce either after service of Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and i participate in counseling prior to the divorce becoming final. 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. §4909 relating to unswom falsification to authorities. JO~ ~VILLIAMSON JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE ON 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 in Divorce without notice. 2. 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. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and 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. §4909 relating to unswom falsification to authorities. Date: JON'~ILLIAMSON JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 04-694 : : 1N DIVORCE AFFIDAVIT OF SERVICE BY ]MAIL PURSUANT TO PA. R.C.P. 403 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS Richard P. Mislitsky, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Jennifer Ross-Williamson, and he did mail a tree and correct copy of the Complaint in Divorce Under Section 3301 (c) or (d) filed in the above matter by certified, restricted delivery, to the addressee of Jon Williamson, on February 19, 2004, at 1295 Lowther Road, Camp Hill, PA 17011. The signed acc~eptance of service is attached hereto as "Exhibit A". Richard P. Mislitsky Sworn to and subsc,.rjbed Before me this ?a'klay of ~ ,2004. L U · Complete'~tems 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: II address different fror¢ If YES, enter delivery address below: [] Agent [ddressee [] No 3. Serv' Type 1 ~ified Mai, [] Express Mai, se [] Registered [] Return Receipt for Merchand L[] Insure~d Mail [] C.O.D_:_ -- -- ~4. Restricted Delivery? (E,,dra Fee) [] Yes 2. Article Number '~rlrl~3 O6bO DODO "l,£1b? Olds (Transfer from service label} 102595-02-M-1540 PS Form 3811, August 2001 Domestic Return Receipt /Postage &.Fees Paii:~ /USPS ~ ( 4Permit No. G-lO ~ · Sender: Please print your name, address, and ZIP+4 in this box · Richard P. Mislitsky One West High Street, Suite 208 P.O. Box 1290 Carlisle, PA 17013 :~ I Ill III II If II iiii ii I} I1 Itl ~, ~, IiI Ill Illlll II II IIII I J II III I II IIIII JENNIFER ROSS-WILLIAMSON, Plaimiff JON WILLIAMSON, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE ACCEPTANCE OF SERVICE I, Jon Williamson, Defendant, hereby accept service of this Complaint in Divorce served via United States Certified Mail. JENNIFER ROSS-WILLIAMSON, Plaintiff JON WILLIAMSON, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 04-694 : 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: 1. Grotmd for Divorce: Irretrievable Breakdc,wn under Section 3301 (c) or (d) of the Divorce Code. 2. Date and manner of service of the complaint: February 19, 2004 by first class mail, certified, restricted delivery to the Defendant, Joh Williamson. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by Plaintiff, July 8, 2004; by Defendant, July 8, 2004. 4. Related claims pending: None. 5. (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) was filed with the Prothonotary: July 9, 2004 Date Defendant's Waiver of Notice in Section 3301 (c) was filed with the Prothonotary: July 9, 2004 November 24, 2003 Mr. Richard P. Mislitsky One West I-Iiffh Sl~-t P.O. Box 1290 Carlisle, PA 17013 Dear Rich: Per your recommendation, we have agreed on the division of our assets, and we will not use attorneys t'or this process. However, we will use your services t~ file for divots. We have split our assets, and neither one will seek fi:x f~ure ~ppot~. l'he divorce should be filed on Jennifer's behalf and all costs as~mcinl~d with the h'llng should be billed to Jennifer. Furniture All furnituxe and other household goods have been divided. AH items in Jemaifer's possession will remain with Jennifer. AH il-'ns in Jcm's pomession will remain with jon. AcCoullt~ There are no longer my joint accomm. Tbe $9,430.99 in Jun's mo~y ~ ~xmnt will be divided 50/50. Ulxm ~671,~ thi~ letter, Jon ,a~ll l~ovide Jenffife~ a personnl check in the amount of $5,090.50. This amount includes .5(P,4 of the money fix~n his market account as well as half of September's rent - $;375. Dogs The dogs - Cajun and Sedona - will remain in Jon's custody. Jennifer has forfeited her fight to care for or visit the dogs. Retirement. lite insurance .-k~l retiremen.t accounts are separate. Jennifer will not seek t~ands t¥om Jon's accounts. and Jori ~51[ not seek funds from Jennifer's accounts. The 97 Dodge Dakota is in Jon's name. Jennifer wSll continue to pa.,,' for the 90 . ot.,,~u, agen ?assat. Jon is not responsible for an.,,' futn.u-e payrnents School loans Jon is responsible tbr paying tbr his school loans from Drexel and York College. Jermifer's name is not on these accounts, and she is no~: responsible for these payments. Jennit~-2r is responsible tbr paying her school loans to R)r her education. Jon's name is not on these accounts, and he is not responsible for these payments. IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE Of Jennifer Ross-Williamson Versus Jon Williamson PENNA. NO. 04-694 PLEAS DECREEIN DIVORCE AND NOW, DECREED THAT AN D Jon Williamson Jennifer Ross-Williamson : ~(3~L/, IT IS ORDERED AND ARE DIVOBCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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; BY THE COURT: ATTESF - ~ ' - //' j. /~} ROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jennifer Ross-Williamson Plaintiff CIVIL ACTION - LAW FILE NO. 04, 694 2004 VS. IN DIVORCE Jon Coble Williamson Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree &A in Divorce on the I e day of July, 2004, hereby elects to resume the prior surname of Jennifer I . Ross, a gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: /0 Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On the - I day of SS f OSS ')? - - - -, 20Lv , before me, a 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 purpose therein contained. In Witness Whereof, I have hereunto set my hand and ffi 'al s pMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Nota blic LWDA ELIZA8ETt+LCNDON, Notary Public city of Harrisburg, Dauphin County My CQmntisraF )n Expires March 28, 2013 OF TN??PROTNONOTARY 2014 DEC -2 AM 10: 15 CU!l?R.S LVANIANTY Penn p?. #ilad S-M