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HomeMy WebLinkAbout08-58120 1 William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Judy E. Woodside, NO. ?" Y/; ??` 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania 17013 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Judy E. Woodside, NO. 0&- 5 t 1 Z Defendant IN DIVORCE COMPLAINT AND NOW COMES the above-named Plaintiff, by his attorney, William A. Duncan, Esquire, and makes the following Complaint in Divorce: 1. Plaintiff, William L. Woodside, Jr., is an adult individual currently residing at 219 W. Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065.. 2. Defendant, Judy E. Woodside, is an adult individual currently residing at 31 N. 17`h Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 14, 2003 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Defendant herein is not a member of the Armed Forces of the United States of America. WHEREFORE, Plaintiff prays this Honorable Court enter a decree dissolving the marriage between the parties. Respectfully Submitte WillAdh A. Duncan, Esquire Attorney for Plaintiff Duncan & Hartman, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 VERIFICATION 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. sec. 4904, relating to unsworn falsification to authorities. Date: ( " ( Z _ O? William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Judy E. Woodside, : NO. Defendant : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with section 3301C) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relation Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost off counseling sessions are to be born by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Judy E. Woodside, NO. Defendant IN DIVORCE AFFIDAVIT William L. Woodside, Jr., Plaintiff, 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 my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (BWDO 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. 4. I realize that if the divorce is brought under section 3301C) of the Divorce Code, then counseling must be completed within ninety days after the filing of the complaint. If the divorce is brought under section 3301(d) of the Divorce Code, then counseling must be completed within one hundred and twenty days after the filing of the complaint. I understand that false statements herein are made subject to the penalties off 18 Pa.C.S.4904 relating to unswom falsification to authorities. mss} --•. s N -Ti c.,a -ra < i tom.:, --< William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Judy E. Woodside, NO. Defendant IN DIVORCE RECEIPT OF SERVICE I, July E. Woodside, being duly sworn according to law, do swear that I was served a Complaint in Divorce which was handed to me by William A. Duncan, Esquire, at the offices of Duncan & Hartman, P.C., 1 pI,r?viinne Row, Carlisle, PA on October 1, 2008 at approximately t/ ? .M. Judy E. Woodside Sworn to and subscribed before me this 1 s` day of October, 2008 N#ary Public OWMLTH OF PENNSYLVANIA NOTARIAL SEAL JOAN D. ADAMS, Notary Public [My Cafte Boro., Cumberland County Commission Expires March 7, 2011 ca Q -T? _ ass ?- -c+t ? __ 1 .: ? A ?,? t ? J'? .:. William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Judy E. Woodside, NO. ©' " S 0 Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, William A. Duncan, Esquire, being duly sworn according to law, do swear that I served a Complaint in Divorce on the Defendant, Judy E. Woodside, by handing her a true copy at the offices of Duncan & Hartman, P.C., I Irvine Row, Carlisle, PA on '0 ?4,8. William A. Duncan, Esquire Sworn to and subscribed before me this J W day of st, 2008 16,Wh0 ?Jbtary Public oNWEALTW of PENNSYLVANIA NOTARIAL SEAL JOAN D. ADAMS, Notary Public Cadisle Boro., Cumberland County Commission Expires March 7, 2011 t- a 4 William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Judy E. Woodside, NO. 2008-05812 Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301c) of the Divorce Code was filed on September 30, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. sec. 49904 relating to unsworn falsification to authorities. Date: /- ,?y -rt G c? ..v ? r CN William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Judy E. Woodside, NO. 2008-05812 Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301c) of the Divorce Code was filed on September 30, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. sec. 49904 relating to unsworn falsification to authorities. Date: vv V ?- b Judy E. Woodside William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Judy E. Woodside, NO. 2008-05812 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 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. sec. 49904 relating to unsworn falsification to authorities. Date: Judy E. W odside ? N ? `j N a ?'-' ? ' F ' - ?+ ? "' :? .- _ ? . i. -S' `?? -,. t'.± .. --- "? '? =< Gs? William L. Woodside, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Judy E. Woodside, NO. 2008-05812 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 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. sec. 49904 relating to unsworn falsification to authorities. Date: r / /-)o_??j? William L. Woodside, Jr. N C? r3 FJ --l William L. Woodside, Jr., Plaintiff V. Judy E. Woodside, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008-05812 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. Grounds for divorce: irretrievable breakdown under Section 3301( c ) of the Divorce Code. 2. Date and manner of the service of the complaint: Personal Service on October 1, 2008. 3. (1) Date of execution of the affidavit of consent required by Section 3301 ( c ) of the Divorce Code: by plaintiff: January 19, 2009 by defendant : January 19, 2009 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice in 3301 ( c ) Divorce was filed with the Prothonotary: January 2V, 2009. 6. Date Defendants Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: January 21, 2009 William A. Duncan, Attorney for Plaintiff ? ?I . ? C S _ LL -I t3- C :.2i 0 0 N IN THE COURT OF COMMON PLEAS OF WILLIAM L. WOODSIDE, JR. CUMBERLAND COUNTY, PENNSYLVANIA V. JUDY E. WOODSIDE NO. 2008-05812 DIVORCE DECREE AND NOW,?C-, A rM , W , it is ordered and decreed that WILLIAM L. WOODSIDE, JR. , plaintiff, and JUDY E. WOODSIDE , 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 hee Attest: rt, J. I ?e-Lw. 7 Prothonotary /,W JVIP l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA William L. Woodside, Jr. Judy E. Woodside Plaintiff Vs : File No. 2008-05812 IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking "x" prior to the entry of a Final Decree in Divorce, or ? after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of, and gives this written notice avowing his / her intention pursuant to the provisions of 514 P.S. 704. Date: 2-0 Signature Signatur of name being resumed COMMONWEALTH OF PENNSYLVANIA } COUNTY OF Cumberland ) On the ")4L day of 2W0 . before me, the Prothonotary or the 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 hereunto set my hand and official seal. Notary Pu is NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 e'? '?? ? ? ? '? ' ?e?` rrN--- W o° ?- °_ ? tf ? _? .7 T '1 P'ti,3