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Home My WebLink About08-5262 ROBERT C. WILSON, Plaintiff VS. RHONDA WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. : CIVIL ACTION - AT 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 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 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, 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 4 ROBERT C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. Q 51- 5-,2 L CTo; ( ?unn RHONDA WILSON, CIVIL ACTION - AT LAW - IN DIVORCE Defendant DIVORCE COMPLAINT The Plaintiff, Robert C. Wilson, by and through his attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L.C., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE - §§ 3301(c) or 3301(d) 1. The Plaintiff, Robert C. Wilson, is an adult individual who currently resides at 119 North Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, Rhonda Wilson is an adult individual who currently resides at 378 Thistlewood Drive, Cadillac, Michigan 49601. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on June 20, 1998, in Harrison, Michigan. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this matter. tted, Date: 9-3-2001 Marli arkley, Esquire La ffi s of Patrick F. Lauer, Jr., L.L.C. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 ROBERT C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. RHONDA WILSON, CIVIL ACTION - AT LAW - IN DIVORCE Defendant 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 Pa.C.S. § 4904, relating to unworn falsification to authorities. f. Date: Signature: '`F Robert C. Wilson CS . _,". f Imo,) _ ul )IJ i? "'f7 him Cn ..ti ROBERT C. WILSON, Plaintiff vs. RHONDA WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-5262 CIVIL ACTION - AT LAW - IN DIVORCE AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Marlin L. Markley, Esquire, verify the Complaint in Divorce has been served upon the Defendant indicated above by first class, certified mail # 7008-0150-0003-6464-2545, restricted delivery, return receipt requested, prepaid postage, pursuant to the requirements of Pa. R.C.P. 1930.4. ¦ Complete items 1, 2, and 3. Also complete ftm 4 if Restricted Delivery is desired. X e3 ¦ P *d your name and address on the reverse so that we can rotum the card to you. - of Ddvwy ¦ A ach this card to the back of the mailpieoe, s C• Date orAn the front if space permits. So>^ q_l?. 1. le Addressed to: D. Is delivery address different from Item 1? ? we K a If YES, enter delivery address below: ? No hada I SON_) ? 3-7 9 3*,'? Type Mail L l? ((,? 0 R?rtd ? insured Mail ? C.O.D. 2. llrtlol? frr)Nr101r - 7008 0150 0003 6464 2545 form NJ T, Faxwy 2004 Donne PAWUM Ia?aNpt ?, f fb10 -Mar arkley, Esquire La Off. es of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Z ?O p Camp Hill, Pennsylvania 17011-4706 Date: t 0 ID# 84745 Tel. (717) 763-1800 ?I, - vs ?? ? .?.. t75 ? ?i ,J ?? --1 ? _ ' _9 r .?' +v a rr ?? ??l+! tJ ? [\Y / - y a? ? ?. David D. Bueff Prothonotary Kirks. Sohonage, ESQ, Solicitor Tsnee X Simpson 1" Deputy Prothonotary Irene E. Morrow 2"d Deputy Prothonotary Office of the Prothonotary Cumberfand County, Pennsylvania nA- SZja LCIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 9 Suite 100 9 Carlisle, PA 17013 • (717) 240-6195 9 Eax (717) 240-6573