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Home My WebLink About08-3350Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 Attorneys for Plaintiff 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, V. Plaintiff WILLIAM F. HUDSON, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS CIVIL ACTION - LAW IN DIVORCE 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 pages 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 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 Courthouse, 1 Courthouse Square, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OE- 3 3.5'0 Wit ,, Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 Attorneys for Plaintiff 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. C 3 3 To (Jt o WILLIAM F. HUDSON, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, LAURA L. HUDSON, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, WILLIAM F. HUDSON: 1. The Plaintiff is LAURA L. HUDSON, an adult individual, residing at 6143 Haymarket Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is WILLIAM F. HUDSON, an adult individual, residing at 62 Tory Circle, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff and Defendant were married on May 20, 1995, in Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties separated no later than April 11, 2008. 8. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a Decree of Divorce under Section 3301(c) or 3301(d) of the Divorce Code. COUNT H -EQUITABLE DISTRIBUTION 9. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs 1 through 8 inclusive, of the Complaint as if the same were set forth herein at length. 10. Plaintiff and Defendant have legally and beneficially acquired certain personal property during their marriage. 11. The parties have not yet reached an agreement regarding equitable distribution. Should they successfully reach a private agreement in the future, Plaintiff requests that the agreement be incorporated into any Decree later entered by this Honorable Court. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court equitably divide all marital property. COUNT IM- CUSTODY 12. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs 1 through 11 inclusive, of the Complaint as if the same were set forth herein at length. 13. The Plaintiff and Defendant are married and are the parents of one (1) minor child: Anne Emilia Hudson, born October 15, 2002. 14. The child was born in wedlock. 15. Plaintiff seeks custody of the parties' daughter, who has been in her primary custody since April 11, 2008. 16. For the last five years the child's residence has been as follows: A. October 2006 to April 11, 2008, with both parents at 6143 Haymarket Way, Mechanicsburg, Pennsylvania. B. September 2005-October 2006, with both parents at 9569 City Limit Road, Neosho, Missouri. C. Birth - September 2005, with both parents at 40 Longstreet Drive, East Berlin, Pennsylvania. 17. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 18. The Plaintiff has no information of a custody proceeding concerning the child pending in any court of this Commonwealth or any other state. 19. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 20. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as a party to this action. 21. Mother has been and continues to be willing to negotiate a parenting plan that focuses the parents making decisions together and serving the child's best interests. In the absence of an agreement, Mother invokes the jurisdiction of the Court to assume control of the decisions to be made regarding custody. 22. The best interest of permanent welfare of the child will be served by granting the relief requested because: A. The child needs frequent and continuing contact with both of her parents. B. Mother is able to provide a stable and loving home and will support child's relationship with her Father, as his schedule permits. C. Mother has been primary caregiver and a stay home parent as the result of a joint decision by the parties. WHEREFORE, the Plaintiff, LAURA L. HUDSON, respectfully requests this Honorable Court to set a schedule of to ensure frequent and continuing contact with Anne Emilia and both of her parents and award the parties shared legal custody-eghe minor child. JOHNSON, DUFVIE, STEWART & WEIDNER Melissa Peel Greevy :333625 VERIFICATION I, LAURA L. HUDSON, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: S"2g 09 V4u,"s- LAURA L. HUDSON .333625 ? • ~- , rte,, r Iva f lk? O 1 1 ?C A Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff LAURA L. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 3 3-5D V. NO. 08*969oCIVIL TERM WILLIAM F. HUDSON, CIVIL ACTION - LAW Defendant RETURN OF SERVICE AND NOW, this day of June, 2008, the undersigned does hereby certify that on June 5, 2008, the Complai t filed May 30, 2008 in the above captioned action was served upon on Defendant, William F. Hudson, via certified mail return receipt requested, restricted delivery, addressed to 62 Tory Circle, Enola, PA 17025. The Return Receipt evidencing service upon Defendant is attached hereto as Exhibit A. JOHNSO , FIE, STEWART & WEIDNER y: )VIelissa Peel Greevy I.D. No. 77950 Johnson, Duffle, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne. PA 17043-0109 Attorneys for Plaintiff f • CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing Return of Service upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the(4b? 4ay of June, 2008, addressed to the following: William F. Hudson 62 Tory Circle Enola, PA 17025 JOHNSOIyfWFFIE, STEWART & WEIDNER Peel Greevy :335133 M -.r r CO a Kr .A c Postage C- MPCs Certified Fee ru ° C3 Return Receipt Fee (Endorsement Required) ° Restricted Delivery Fee - (Endorsement Required) r=I N Total Postage & Fees ° t1 - Sent To ° Street, Apt. No.; ........................ or PO Box N----------------- 1 n -- -- / j I p SSSLLLCCC s [ LJS ------'----"--- Ciry, Stare, ZlP+ PS Form 3800. August rr. See Reverse for ln?tructiong-- ¦ Complete Items 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 Addr%asm to: With, F, kdsor, GL ? 1 A. Sig nal re X 13 ILA ressee B. Rece by( prf )E N Date of Delivery G.L{c,1F. big D. Is delivery add Yes If YES, enter dt7j- StiService Type 3. ?-' No XCerdfied Mail ? Express Mall ? Registered ? Retum Receipt for L4wd ndtse ? Insured mail ? C.O.D. f 4. Restricted Delivery? (Extra r--i g 2. Article Number - (i-ranswftmswwoeh 7007 0710 0,002 9649 1843 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-WIS40 IX ?S ,,, ?, ?, ? s:- ;.... ?+. ? .. _ ?? {? _ ,?" ,J'' .--_ Johnson, Duffle, Stewart & Weidner. By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, Plaintiff V. WILLIAM F. HUDSON, Defendant NO: 08-3350 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter hereby elects to resume and hereafter use the previous name of LAURA L. GILLIGAN, and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309 No. 295, §702; 54 Pa.C.S.A. 704, as amended. LAURA L. HUDSON TO BE KNOWN AS: Attorneys for Plaintiff Laura L. Hudson IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LAURA L. GILLIGAN COMMONWEALTH OF PENNSYLVANIA . ss: COUNTY OF CUMBERLAND On this, the 1(&day of September, 2008, before me, a notary public, personally appeared LAURA L. HUDSON known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Cassandra T. Rosenbaum, Notary Public .334056 Lemoyne Boro., Cumberland County My Commission Expires Dec. 4, 20b8 Member. Pennsylvania Association of Notaries 4 O 93 0 I'D Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, Plaintiff V. WILLIAM F. HUDSON, Defendant Attorneys for Plaintiff Laura L. Hudson IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-3350 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MOTION FOR ENTRY OF ORDER UPON STIPULATION AND NOW, comes Plaintiff, Laura L. Gilligan, f/k/a Laura L. Hudson, by and through her attorneys, Johnson, Duffle, Stewart & Weidner, and moves your Honorable Court to enter an Order upon Stipulation for Custody. The undersigned represents that Defendant concurs with this Motion. Respectfully_su. miffed, , DUFFJIE, STEWART & WEIDNER Date: December L d, 2008 MBt tda Peel Greevy Attorney I.D. No. 77950 301 Market Street Post Office Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorney for Plaintiff CERTIFICATE OF SERVICE Ajj AND NOW this " day of December, the undersigned does hereby certify that she did this date serve a copy of the foregoing Motion for Entry of Order upon Stipulation upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: William F. Hudson 62 Tory Circle Enola, PA 17025 STEWART & WEIDNER Peel Greevy CD 7 f t. ` i c 7 - r Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, Plaintiff V. WILLIAM F. HUDSON, Attorneys for Plaintiff Laura L. Hudson IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-3350 CIVIL TERM CIVIL ACTION - LAW Defendant IN DIVORCE PARENTING PLAN AND CUSTODY STIPULATION AND NOW, come the parties, Laura L. Gilligan, f/k/a Laura L. Hudson, (Hereinafter referred to as "Mother") and William F. Hudson, (Hereinafter referred to as "Father") to enter the following Parenting Plan and Custody Stipulation: WHEREAS, the parties are the parents of one child, Anne Emilia Hudson, aged six, having been born October 15, 2002; and WHEREAS, the parties separated on April 11, 2008; and WHEREAS, Anne Emilia has been in the primary custody of Mother since the parties' separation; and WHEREAS, the parties have reached an agreement with regard to a Parenting plan that each believes in is their daughter's best interests, without the necessity of Court intervention or a Custody Conciliation; and WHEREAS, the parties desire to have their Parenting Plan and Custody Stipulation entered as an Order of Court NOW THEREFORE, the parties, intending to be legally bound stipulate and agree as follows: 1. Mother and Father shall have shared legal custody of their minor daughter, Anne Emilia Hudson, born October 15, 2002. Major decisions, including but not necessarily limited to her health, welfare, education, religious training and upbringing, shall be made by the parties jointly after discussion and consultation with each other with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning the child that reasonably can be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions that must be made the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby; however, that party shall inform the other of the emergency and consult with him/her as soon as possible. 2. Each Parent shall be entitled to all report cards, progress reports evaluations calendars and any other information pertinent to the children's progress and standing at their school. 3. The parties shall keep each other informed in advance of all of the child's doctor, dental, vision, counseling or other health related appointments and shall thereafter provide each other with the results of any such appointments not attended by both parents. 4. Physical Custody: Mother shall have primary physical custody subject to Father's rights of partial custody, which shall be arranged as follows: A. School year: 1. One weekday, from the time of school dismissal until 8:00 p.m. In the absence of an agreement to the contrary, the week day custody shall occur on Wednesdays. 2. On alternating weeks to commence November 12, 2008, one (1) over night period of custody which is presently exercised on alternating Wednesdays after school until Thursday when Father takes Anne to school. The parties agree that the scheduled days may be switched to be arranged around Father's work and school schedule. 3. Other such times as the parties agree. B. Summer: 1. One week day selected around Father's work/school schedule. 2. On alternating weeks , one (1) over night visit arranged around Father's work and school schedule. 3. Other such times as the parties agree. 5. Father shall provide Mother with a copy of his class schedule within ten (10) days of his receipt thereof. Father shall provide Mother a copy of his work schedule not less than one week in advance, and promptly after it becomes available to him. 6. Holidays: The following Holiday schedule shall supercede the regular schedule. The parties recognize that Father's work schedule may require them to adjust this schedule this year or in subsequent years. A. Memorial Day weekend and July 4. Father shall have custody for these holidays, to include one overnight period of custody for each holiday, if his work schedule permits. If Father must work part of these holiday weekends, the parties shall cooperate with each other in arranging periods of custody for Anne to be with Father around his work schedule. B. Labor Day weekend. Mother shall have custody C. Father's Day. Mother's Day: Father will have custody on Father's Day, Mother will have custody on Mother's Day. D. Easter: Father will have custody on Easter in Odd numbered years, as his work schedule permits. Mother will have custody on Easter in Even numbered years. E. Thanksgiving 2008: Father will have custody for this holiday, from 9:00 a.m. the day before Thanksgiving until 8:00 p.m. Thanksgiving Day. F. Christmas 2008 and 2009: Mother shall have custody from Christmas Eve at 5:00 p.m. until 8:00 a.m. on December 26, 2008. Father will have custody from 8:00 a.m. December 26, 2008 until 8:00 p.m. December 28, 2008. G. Christmas and Thanksgiving 2010 and subsequent Years: Commencing 2010, provided the parties agree that it is in Anne's best interests, the parties will begin to alternate Thanksgiving and Christmas. In even numbered years, Father shall have custody for Thanksgiving from 5:00 p.m. the day before Thanksgiving until 8:00 p.m. Thanksgiving Day, and Mother shall have custody for Christmas from Christmas eve at 5:00 p.m. until Christmas Day at 8:00 p.m. In Odd numbered years, Mother shall have custody for Thanksgiving from 5:00 p.m. the day before Thanksgiving until 8:00 p.m. Thanksgiving Day, and Father shall have custody for Christmas from Christmas eve at 5:00 p.m. until Christmas Day at 8:00 p.m. 7. Vacation: Each party shall be entitled to two (2) non consecutive weeks of uninterrupted custody for purposes of Summer vacation. The holiday schedule shall supercede the regular schedule and the vacation schedule. The parties shall provide each other with at least thirty (30) days notice of their intended vacation schedule. In the event of a scheduling conflict, the party first providing written notice to the other shall have choice of vacation weeks. 8. The parties may vary from the terms of their mutual agreement. In the absence of an agreement, the parties intend that the terms of their Stipulation an Order shall control. 9. The parties agree that this Parenting Plan and Custody Stipulation shall be entered into an Order of Court which they intend to be as binding as if entered after notice and hearing. 10. The parties agree that Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. WITNESS: 4L URA L. GILLIGAN, A LAURA HUDSON WILLIAM F. HUDSON :348217 L COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND Ott, On the day o , 2008, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared LAURA L. GILLIGAN, F/K/A LAURA L. HUDSON, known to me (or satisfactorily proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand an notarial seal the day and year first above written. • W Notary Public 000Nwi:ALTt+ OF PENNSnvarlP? wl * I Saab Dana L. rilaa0 1, Notary Public LWnoyna 80x0, Cwnbirland CounlY QOmmOp Nov.15,11)1? d COMMONWEALTH OF PENNSYLVANIA COUNTY OF ss. On the. day of , 2008, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared WILLIAM F. HUDSON, known to me (or satisfactorily proven) to be one of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand an notarial seal the day and year first above written. Notary Publi COMMONWEALTH OF PE14NSYLVANIA NOTARIAL SEAL Janet M. Fisher-Notary Public Lower Paxton Up., Dauphin County MY COMMISSION EXPIRES OCT. 19, 2012 -13- C> ? -? -T, ;-== ? - -`' _ ? ?}. ?? ?•? v S ? ,r •-°s; ~-j ?? DEC 19 'N'06 6 LAURA L. HUDSON, Plaintiff V. WILLIAM F. HUDSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-3350 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this day of December, 2008, upon consideration of the within Parenting Plan and Custody Stipulation, IT IS HEREBY ORDERED AND DECREED that said Stipulation is made an Order of this Court in its entirety, and the parties are directed to comply with all of the provisions of said Stipulation. BY THE COURT: J. Di tribution: elissa Peel Greevy, Esquire, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043 William F. Hudson, 62 Tory Circle, Enola, PA 17025 nn l?t?? t F's rn 991 LL .., ... r ?.:. '" ti - _.. r Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, v. WILLIAM F. HUDSON, Plaintiff, Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-CV-3350 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. 1 consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 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 if I do not claim them before a divorce is granted. !1'' low 3. 1 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 above 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. Date: I A io`? 1,4);k., -?,, duL, WILLIAM F. HUDSON 351271 u l Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, Plaintiff, V. WILLIAM F. HUDSON, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-CV-3350 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 May 30, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. 1 consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DE_ CREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. I' 2. 1 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. 1 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 above 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. Date: t l0 q t LAURA L. GILD ANF/N/A LAURA L. HUDSON 351271 t? w ?? . _ ?. '`'? • v ,?.Z? ?T. 'y+? sir rU (? fTj f Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy, Esquire I.D. No. 77950] Attorneys for Plaintiff 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 LAURA L. HUDSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 08-CV-3350 WILLIAM F. HUDSON, CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff January 8, 2009, by Defendant January 8, 2009. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: /' Filed herewith. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Filed herewith. JOHNSON, DUFFIE, STEWART & WEIDNER Date: I /q/0 By: Melissa Peel Greevy :351274 ev IF L -f C.3 -7- LAURA L. HUDSON, V. WILLIAM F. HUDSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3350 DIVORCE DECREE AND NOW, it is ordered and decreed that LAURA L. HUDSON plaintiff, and WILLIAM F. HUDSON , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendent elite 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: