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Home My WebLink About08-3255/' A ? Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 3,,265 CIVIL TERM William E. Peterson Defendant 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, Cumberland County Courthouse, 1 Courthouse Square, 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. Cumberland County Bar Association " 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 t - f Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF. Plaintiff CUMBERLAND COUNTY PENNSYLVANIA , v. NO. 08- -3 °? WSJ CIVIL TERM William E. Peterson Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is who currently resides at f5Q(-)0 yl r Q # i7 4l 14, 1 `7 , Cumberland County, Pennsylvania. 2. Defendant is f p a A 'C"n?1 who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ; (x(15 at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 4 -+ 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. y ------------ Date Plaintiff, Pro Se verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to autharitie?s` `'as provided in 18 Pa. C.S. §4904. Date: Plaintiff, Pro Se ?- Assisted by: Thomas J. Williams, Esq. Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-1383 ?_ D }? '? _ ?? _ .--,? ?:.,x.:. .?,[ r ("_ T? ?? [T.3 rs_ • • _.' ?... '^i: Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. N0.08- 3 Z CIVIL TERM William E. Peterson Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Whitiney N. Mosley, Plaintiff, to proceed in forma ap uperis. I, Thomas J. Williams, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. vy A Thomas J. Wi i s, Esquire Attorney for aintiff Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-3341 1.11 a ? t .3 --L7 I . r f . Fr FILFS'CIient0492 Mid Penn\5492.7T,Musley\5492.77.prereinstate Raised: 8 15'08 10'. I SAM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WHITINEY N. MOSLEY, Plaintiff V. WILLIAM E. PETERSON, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3255 CIVIL ACTION - LAW : IN DIVORCE PRAECIPE Please reinstate the Divorce Complaint. MARTSON LAW OFFICES By 1 Thomas J. Willis , Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: August 15, 2008 ?,, ? s?. ? f Y -- -rs ?? ,?.N. { ,? ?? rte' ?-° ...? Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08-3255 CIVIL TERM William E. Peterson Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, William E. Peterson (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written bel,4.w. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 2 9 apO ?' Date William E. Peterson, Def dant ?t 6ylrr C1.3 Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 3255 CIVIL TERM William E. Peterson : Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed onm paps r? 1 06? 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 divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject a penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to a orities Date: I' LA Signature: Whitiney N. M sley, Plaintiff C Whitiney N. Mosley Plaintiff V. William E. Peterson Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 3255 CIVIL TERM IN 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 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. i Date: Signature: I, Whitiney N. Mosley, Plaintiff G ? ' a S Am '>'EJ 1 Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 3255 CIVIL TERM William E. Peterson Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on A J L Q G?k 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 divorce. 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. ? v Date: Signature: William E. Peterson, Defen ??9 ?if+ rI" ,,, ?, .Ycs -:; ?+ ..? ?. ?.? Whitiney N. Mosley IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 3255 CIVIL TERM William E. Peterson Defendant IN 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 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. /-1) /I IL Date:1 7 Signature: William E. Peterson, Defendant r CC, ?n Whitiney N. Mosley Plaintiff V. William E. Peterson Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08 Z5S-' 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: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on !gbqkcci? 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of ) 1 y O by Defendant, 1 / S*' L the Divorce Code: by Plaintiff, 4. Related claims pending: There are no outstanding aims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: 1(9 IT20V (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: _ I - 1 mr] 0 4 Plaintiffs Social Security Number: Defendant's Social Security Number: (?- kncit A')Yl Qtr.. 4 '1. , 0 1 4Q I Whitiney N. Mosley :-? "r' -r?, .,_.- f'; ,,.?, ?r ?, : IN THE COURT OF COMMON PLEAS OF WHITINEY N. MOSLEY CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM E. PETERSON NO. 08-3255 DIVORCE DECREE AND NOW, (b ,•??,, Z 7_ oo S , it is ordered and decreed that WHITINEY N. MOSLEY , plaintiff, and WILLIAM E. PETERSON , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE. By the Court, ell,