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Home My WebLink About09-6349Debra L. Washington N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- CIVIL TERM Isaiah S. Washington, IV 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 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, 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 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Debra L. Washington IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 6 3Y q CIVIL TERM Isaiah S. Washington, IV Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is D o nckD , who currently resides at Cumberland County, Pennsylvania. 2. Defendant is ?? , who currently resides at P-vq--?Al- C-0 e4? rt ?- tQd,7 6 x-1 30gU 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ! V u 3 zoo ( at ?a 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plaintif ro e I-A '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 made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: Plaintiff, PrerSe Assisted by: Jacqueline M. Verney, Esq. Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 9s 21, All 4W Debra L. Washington Plaintiff V. Isaiah S. Washington, IV Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 3 CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Debra L. Washin tg on, Plaintiff, to proceed in forma pa uperis. I, Jacqueline M. Verney, attorney for the party proceeding in forma 12gMMris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. M. Jacqline M. Verney, Esquire Attorney for Plaintiff Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 nmgfApy T-HE P" 2009 S 1' 24 i 10: 22 ?' w ) Debra L. Washington IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 6--54 CIVIL TERM Isaiah S. Washington, IV Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, DehrsW&3V%'rn?m , being duly sworn according to law, depose and say that on ? "a "O (Date of signing of the green card by spouse), I served a true and correct copy of the Divorce Complaint upon the Defendant, by Certified Mail, Restricted Deliver, addressed as follows: S G i t? Y? S. ?Gr S It v?? ?n t I` ??? i? ------------ The Certified Mail Return Receipt Mailing Card ("Gree and"), for t e foregoin isk attached hereto and made a part hereof. 1*t" Signature Ctrs- bah%mgj!sn Printed Name Sworn to and subscribed before me a Notary Public in and for Cumberland COMMONWEALTH OF PENNSYLVANIA County, Pennsylvania this day of 20 0 9 . NOTARY PUBLIC NOTARIAL SEAL VALERIE F. GSELL, Notary Public Carlisle Boro., Cumberland County My Commission Expires October 9, 2010 My commission expires: ATTACH GREEN RETURN RECEIPT CARD HERE ¦ 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: 5aI ail h 1 n9f (1r, &DX Z4 ? G-?a}e?xd P4 ?q 4 2-to A. Signature X /j ? Agent C ? Addressee B. Received by (Printed Name) C. Date of Delivery ti-34o5 D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Type -- tHCertifled Mail ? Express Mail ? Registered ? Return Receipt for,ise ? Insured Mail_? C80. 4. Restricted Delivery? ice) ? Yes' 2. Article Number (71ansfer from servi 7009 0080 0001 8044 9749 Ps Form 3811, February 2004 Domestic Return Receipt 102555-02-M-1540 ?ft36ov ? ED-0"rICE OF THE PpovONoTARY 2009 OCT -2 AM 11: 19 PENNSYLVANIA Debra L. Washington IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- CIVIL TERM Isaiah S. Washington, IV Defendant IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that Plaintiff in the above matter filed a Complaint in Divorce filed on Debra Lynn Washington hereby intends to resume and hereafter use her previous name of Debra Lynn Williamson and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. Debra L ashington ebra L illiamson COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS On this, the day of 2009, before me, the undersigned officer personally appeared a nil uS also known as jgba ?d6 a- 21 - known tome (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set hand and official seal. -- (SEAL) Title of Officer COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL VALERIE F. GSELL, Notary Public Carlisle Boro., Cumberland County M Commission Expires October 9, 2010 i-'THE PPO ! i_: ""'ITARY 2009 OCT 19 Ail 9: 4 4 CUB ?: , iE ? ly il. ~".- ,~ ~ Debra L. Washington Plaintiff v. Isaiah S. Washington, IV Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 09- ~ ~ ~ `~ Crvit, TERM n IN DIVORCE ~ ~`~ cn {~, _, . ~' COUNTER-AFFIDAVIT UNDER SECTION 3301(d) `:c^: .,~_ ~ OF THE DIVORCE CODE ?a 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. 0 3 ~. w -~, rv .~- ~~ ~~ ^ (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ^ (i) The parties to this action have not lived separate and apart for a period of at least two years. ^ (ii) The marriage is not irretrievably broken. 2. Chec iher (a) or (b): a I do not wish to make any claims for economic relief. 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. d/(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. ~~ .. , o. I verify that the statements made in this counter-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: Z3 Isaiah S. ashington, IV NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.