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HomeMy WebLinkAbout09-6333Shawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Facsimile: (717) 657-2060 (fax) Attorney for Plaintiff GRETTA WILLIAMS, Plaintiff V. STEWART WILLIAMS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . NO. 09 - to333 l:ivil 1." : CIVIL ACTION -LAW : 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 One Courthouse Square Carlisle, PA 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 St. Carlisle, Pennsylvania 17013 (717) 249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Court Administrator at (717) 240-6600. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. Shawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Facsimile: (717) 657-2060 (fax) Attorney for Plaintiff GRETTA WILLIAMS, Plaintiff V. STEWART WILLIAMS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Cwt ??,?, NO. 0'?- 6 33Y : CIVIL ACTION-LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OR (d) OF THE DIVORCE CODE COMES NOW the Plaintiff, Gretta Williams, by and through her undersigned attorneys, Shane M. Dorward and The McShane Firm, LLC and avers in support of her Divorce Complaint as follows: 1. Plaintiff, Gretta L. Williams, is an adult individual currently residing at 3435 Westheimer Rd, # 109, Houston, TX, 77027. 2. Defendant, Stewart R. Williams, is an adult individual currently residing at 47 Drexel Place, New Cumberland, PA 17070. 3. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to filing of this Complaint. Mrs. Williams recently moved to Texas to reside with her parents. 4. Plaintiff and Defendant were married on December 20, 2002, in Gadsden, Alabama, and separated on February 20, 2009. 5. There have been no prior actions of divorce or annulment between the parties. 6. The ground on which the divorce action is based is that the marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that the Defendant may have the right to request that the court require the parties to participate in counseling 8. Plaintiff requests the court to enter a decree of divorce. 9. No children have been bom of this marriage. WHEREFORE, Plaintiff, Gretta Williams, respectfully requests this Court grant a Decree of Divorce, divorcing the parties from the bonds of matrimony. COUNT I - EQUITABLE DISTRIBUTION 10. The averments of paragraphs 1 through 9 hereof are incorporated by reference as if the same were more fully set forth herein. 11. Throughout the course of the parties' marriage, they have accumulated real and personal property, which is subject to distribution under the provisions of Section 3502 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff respectfully requests that all marital property be equitably distributed. Respectfully Submitted, The McShane Firm, LLC S?iawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Facsimile: (717) 657-2060 (fax) Attorney for Plaintiff VERIFICATION I, Gretta L. Williams, 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 unsworn falsification to authorities. J'r__ ?' A Z ':'? ? ate 7- 1 Gretta L. Williams 'T THE TARY 2099 SEP 23 Psi 1: 30 43(A . 50 90 A-rry el+ etc* Isb1 0(;,wg4 4 Shawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Facsimile: (717) 657-2060 (fax) Attorney for Plaintiff GRETTA WILLIAMS, Plaintiff V. STEWART WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6333 CIVIL ACTION -LAW DIVORCE AFFIDAVIT OF SERVICE I, Shawn M. Dorward, Esquire, hereby verify that on September 22, 2009, Defendant was served with a true and correct copy of the Custody Complaint by one the following methods: (X ) Service was made by United States Postal Service, first class mail, postage prepaid, certified, restricted delivery, return receipt requested to the Defendant, on the 2nd day of October, 2009. The return receipt (postal green card) signed by the Defendant is attached hereto. ( ) The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant. Personal service was made at the following location and time: on the day of , 20 . At o'clock. verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. Date )(A V - 9 -?" / Respectfully Submitted, The McShane Firm, LLC Shawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Facsimile: (717) 657-2060 (fax) Attorney for Plaintiff ¦ 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 Addressed to: 117 /70 ?O -. ? gent A. S `?y?jGc 7.-?? JOLAddressee B. Received by (Printed Name) C. Dat of Delivery Zi .+4?T j LCI rtsys? I D t ?' 91 . D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Se ice Type Certified Mail ? Express Mail ? Registered eturn Receipt ? Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7006 3450 0001 6399 0144 (Transfer ffvm service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 EXHIBIT A 1 2Lj911' i 1 v f,: Y 1 E 0TFI0N0 Vi 2011 S P- I PIS I: 4 C GRETTA WILLIAMS, `;UMBERLAND COUNTI?I THE COURT OF COMMON PLEAS OF P Plainti t?NSYI.VANIA : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-6333 CIVIL TERM STEWART WILLIAMS, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw the appearance of McNees Wallace & Nurick LLC on behalf of Defendant Stewart Williams in the above-captioned action. McNEES WALLACE & NURICK LLC By J. ul Helvy, I'D. No. 53 100 Pine reet P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5343 (717) 260-1701 (facsimile) Dated: phelvy -mwn.com PRAECIPE TO ENTER APPEARANCE Please enter the appearance of Lynnore K. Seaton on behalf of Defendant Stewart Williams in the above-captioned action. bl4a'dt/k, Lynnore K. Seaton Attorney I.D. No. 210241 PO Box 387 Lewisberry, PA 17339 (717) 586-7933 Dated: '?/ , `3t , I CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class mail upon the following: Lynnore K. Seaton P.O. Box 387 Lewisberry, PA 17339 Shawn M. Dorward, Esquire The McShane Firm LLC 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Amand Felty, Legal Secretary Dated: ? - ? t I + `- GRETTA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA V, NO. 09-6333 ?-, c STEWART WILLIAMS, CIVIL ACTION -LAW =m 6 Defendant DIVORCE z? x © AFFIDAVIT OF CONSENT ?o ?,, z° ?o 1. A complaint in divorce under § 3301(c) or (d) of the Divorce Code was filed on Sep* bZ23,:;o 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the compiaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unsworn falsification to authorities. DATE: / l(?z, VVG?l?tar Gretta Williams, Plaintiff GRETTA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-6333 STEWART WILLIAMS, : CIVIL ACTION -LAW Defendant : DIVORCE : w WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE .{A to ca UNDER § 3301() AND 3301(d) OF THE D° a 6- DIVORCE CODE ??o 57>1= Mc 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. 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 in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Fa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 6Aa(A- " Gretta Williams, Plaintiff GRETTA WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, o q PENNSYLVANIA c -o7 N ?„ V. wrn a ?r?- NO.2009-FC-6333 r ? ?is© STEWART WILLIAMS, D ad ° ' --? ca Defendant A°? = o?n CIVIL ACTION -LAW z_o QC) DIVORCE z"= -' AFFIDAVIT OF CONSENT A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 23, 2009. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the complaint. I consent to the entry of a final decree of Divorce after service of Notice of Intention to request entry of the decree. 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: wart Williams GRETTA WILLIAMS, IN THE COURT OF COMMON PLS C Plaintiff : OF CUMBERLAND COUNTY, -a3 .,. : PENNSYLVANIA =rQ7n : ?r=• v . NO.2009-FC-6333 ?z aD 4a STEWART WILLIAMS, C3 c-? o-s? Za Defendant =o 5:c- 0a CIVIL ACTION -LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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, lawyers 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. Section 4904 relating to unsworn falsification to authorities. Date: _ 11-131 2D/Z C?? - st art Williams Shawn M. Dorward, Esquire Attorney ID No. 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Facsimile: (717) 657-2060 (fax) Attorney for Plaintiff 2012 ,tAt? 20 gM t: ?3 CUM??.RU YLdAN?pT`f PENNS GRETTA WILLIAMS, Plaintiff V. STEWART WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-6333 CIVIL ACTION -LAW DIVORCE PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION COUNT TO THE PROTHONOTARY OF SAID COUNTY: Please withdraw the Equitable Distribution Count in Plaintiff's Complaint for Divorce. Respectfully submitted, THE MCSHANE FIRM, LLC c Shawn M. Dorward, Esquire Attorney ID No.: 209595 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Fax: (717) 657-2060 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Denise M. Kendall, an employee of The McShane Law Firm, LLC, hereby certify that service of the foregoing Praecipe to Withdraw Equitable Distribution Count was made via first class, postage prepaid mail on January 18, 2012, to the following; Lynnore Seaton, Esquire P.O. Box 387 Lewisberry, PA 17339 ?r Date D nise AKendall, Legal Assistant GRETTA WILLIAMS, Plaintiff V. STEWART WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA r -A rn 5.7.. NO. 2009-FC-6333 -1 cr> CIVIL ACTION -LAW DIVORCE 4 = _ PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I . Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: September 24 2009_?Certified, Return Receipt Restricted and First Class Mail. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on January 12, 2012, by Defendant on January 13, 2012. 4. Related claims pending: None 5. Date Plaintiff s Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: January 13, 2012. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Januar? 1. 8, 2012. Respectfully Submitted, Date: I -- c:? I - I a Lynnoo K. Seaton Attorney ID 210241 Ream, Carr, Markey & Woloshin LLP 119 East Market Street York, PA 17401 (717) 843-8968 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GRETTA WILLIAMS V. STEWART WILLIAMS NO. 2009- 6333 DIVORCE DECREE ?'Gi it is ordered and decreed that AND NOW, -e '?- GRETTA WILLIAMS , plaintiff, and STEWART WILLIAMS , 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, Attest: J. -I1•M/d?? \/I MAIn NhV1 - Pl 9 61VJ.b Q;'3u?ELL, 'Prothonota c'et? corx ,rya,GPd lDorw(91LI ?Vb. e j r7D 5P? /)