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Home My WebLink About08-7277JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff NETTIE M. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ERIC W. WILLIAMS, Defendant . NO. D$ - %R7'7 Civil le wA : CIVIL ACTION -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, Room 101, 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 I 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 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff NETTIE M. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ERIC W. WILLIAMS, Defendant . NO. : CIVIL ACTION -LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar acci6n con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decisi6n puede tambien ser emitida en su contra por caulquier otra queja o compensaction reclamados por el d'emandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTEDNO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PgRDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA 1NDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 NETTIE M. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO.O f- 7-177 ERIC W. WILLIAMS, : CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Nettie M. Williams, an adult individual who currently resides at 1107 Apple Drive, Mechanicsburg, Cumberland County, PA, 17055. 2. Defendant is Eric W. Williams, an adult individual who currently resides at 1915 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 27, 1992 in Lemoyne, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies !within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there are no children of this marriage. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code. Respectfully submitted, PC Date: /--7 . ?g Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff VERIFICATION I, Nellie M. Williams, 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 herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: I _ 3 _eO Nellie A Williams ?"j ' ? rrl - A N C: 1 g w w NETTTIE M. WILLIAMS, Plaintiff V. ERIC W. WILLIAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7277 Civil Term CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Eric W. Williams, acknowledge that I received and have accepted a true and correct copy of a time stamped Complaint in Divorce filed on December 12, 2008 in the above captioned action by first class mail on the 23rd day of December, 2008. Date: c! t o y I Eric W. Williams FILEO- OF 'ME F, f h i Ird:7 2049 SEP 17 PM 2: 0 b "? M if'- 4, 6lY val. NETTTIE M. WILLIAMS_ : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNT'S, PENNSYLVANIA V. : NO. 08-7277 Civil Term ERIC W. WILLIAMS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 17 A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 12, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the 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 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 counsermg 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. Section 4904 relating to unsworn falsification to authorities. Date: ?/?/Of vt/ '1"" "-P? Eric W. Williams OF THE R^"i.`!"NIOTARY 2009 SEP 17 PEA 2: 05 CUP>?? t f ;; NETTTIE M. WILLIAMS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7277 Civil Term ERIC W. WILLIAMS, Defendant I. 2. CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(cLOF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 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. § 4904 relating to unworn falsification to authorities. DATE: 4', 1.4.- Gv g Z! V y Eric W. Williams FILE ti-4 k-F uE OF THE 2099 SEP 17 PH 2: 6 c,? y NETTTIE M. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-7277 Civil Term ERIC W. WILLIAMS, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 12, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the 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 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. Section 4904 relating to unworn falsification to authorities. Date: Nettie M. Williams 2009 OC i 14 PH 12: 28 NETTTIE M. WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-7277 Civil Term ERIC W. WILLIAMS, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD UNDER § 3301 (c) OF THE DIVORCE CODE 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 § 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: (a) Date of service: December 23, 2008 (b) Manner of service: United States Mail. Affidavit of Service filed: September 17, 2009. 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: (a) By the Plaintiff. signed on September 28, 2009 and filed simultaneously with this document. (b) By the Defendant: signed on September 2, 2009 and filed on September 17, 2009 4. Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (a) By the Plaintiff: signed on September 28, 2009 and filed simultaneously with this document. (b) By the Defendant: signed on September 2, 2009 and filed on September 17, 2009 DATED: Related claims pending: NONE Joanne Harrison Clough, Es ui Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Nettie M. Williams .I- FILED - `,;rCZ TARY 2009 QC i 14 PM 12: 29 c,? ,1-rv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NETTIE M WILLIAMS V. ERIC W WILLIAMS NO 08-7277 DIVORCE DECREE AND NOW, 0 J00 t f 16 , 2009 , it is ordered and decreed that NETTIE M W1111-AM-2 , plaintiff, and FRTC eW WTT TAWg , 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.") By the Court, ?k. ? QA3? Attest: J. Prot notary r J /J f /1,?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW W tl c,nn s Plaintiff . FILE NO. op VS. IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the _o O day of Oc-mBey2-- hereby elects to resume the prior surname of yoyi CCk' C n and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: S"ry.XJfl! _ Zoo COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Signature Signature of name being se ur ed SS. On the day of 24 ?9, 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 official seal. a-? ? ?Iv"kd otaryublic NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 a4 6L1'56 O? C"'l 2 c u. S? 23q Ito