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HomeMy WebLinkAbout04-2380LISA M. WOOLUMS, Plaintiff VS. MICHAEL P. WOOLUMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. O t/_ ~2 3 ~o Civil Term : : ACTION 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. Where the ground for the divome is indignities or irretrievable breakdoum of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 LISA M. WOOLUMS, Plaintiff VS. MICHAEL P. WOOLUMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 0 ¥- .2 .~ £o Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Pla'mtiffis Lisa M. Woolums, a competent adult individual, who has resided at 161 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania, since 2002. 2. Defendant is Michael P. Woolums, a competent adult individual, who has resided at 161 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania, since 2002. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 19, 2003 in New Cumberland, Pennsylvania. 5. There have been no prior actions of divoree or for annulment between the parties. 6. Plaintiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. Plaintiffand Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to emer a decree in divorce. I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Lisa M. Woolums, Plaintiff J J~ffe Adams, Esquire / /El) No. 79465 /J 3~6 S,.o.uth~Pitt. S~eet Carlisle, Pa. 17013 ' (717) 245-8508 ATTORNEY FOR PLAINTIFF LISA M. WOOLUMS, Plaintiff VS. MICHAEL p. WOOLUMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 2380 Civil Term : : ACTION IN DIVORCE : AFFIDAVIT OF SERVICE AND NOW, this June 8, 2004, I, Jane Adams, Esquire, hereby certify that on or about June 4,2004, a certified true copy of the NOTICE TO DEFEND and COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: Michael p. Woolums 161 Texaco Road Mechanicsburg, Pa. 17050 DEFENDANT 1.1~. No. 79465 3.36 South Pitt Street ~ Carlisle, Pa. 17013 (717) 245-85;08 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 reveme 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. A~icle Addressed to: I-1 Agent i~ A~dressee B. Received by (Pdnted N~lme) Date of Delive~J D. Isdelive~yaddressdiffemntfrom[teml? r'l ye~ [f YES, enter de[ive~ ac dress below: [] NO 2. Ar[Icle Number (Transfer from service label) PS Form 3811, August 2001 [] Regis{ered [] Return Receipt for Merchandise [] Insured Ma~[ [] C O D , 7003 1010 0004 ~818 6640 · Sender: Please print yot~_~a~?~er ~//ddress, and ZIp+4 i11~th~ ~:° ~; LISA M. WOOLUMS, Plaintiff vs. MICHAEL P. WOOLUMS, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 04 - 2380 Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 26, 2004. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entxy 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 tree and correct. I also m~derstand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to m~swom falsificatinn to authorities. ate: (4. .... Michael P. Woolums, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER $3301(c) AND ~3301(d) OF THE DIVORCE CODE 1. [ consent to 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 undemtand that I will not be divomed 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 unswom falsification to authorities. Michael M. WoolumS, Defendant LISA M. WOOLUMS, Plaintiff vs. MICHAEL P. WOOLUMS, Defendmat IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 2380 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 330l(c) of the Divorce Code was filed on May 26, 2004. 2. The marriage of Pinintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry ora 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 tree and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. %L-'fga IV[. Woolums, Plaintiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301¢c) AND §3301(d) OF THE DIVORCE CODE 1. I consent to 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 ifI 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 inm~ediately 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 unswom falsification to authorities. '~25sa IVL Woolum~, Plaintiff LISA M. WOOLUMS, Plaintiff VS. MICHAEL P. WOOLUMS, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 04- 2380 Civil Term : : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry ora divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail restricted delivery, return receipt requested on: June 4, 2004. 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff.' September 22, 2004. By Defendant: September 22, 2004. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 23, 2004. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 23, 2004. Respectfully Submitted: ~dams, Esquire · . io. 79465 t/ 36 8 Pitt Street sle, Pa. 17013 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS Lisa M. Woolums? Plaintiff OF CUMBERLAND COUNTY STATE OF PENNA. No. 04 - 2380 'NO. VERSUS Michael P. Woolums, Defendant Civil Term AND NOW, DECREED THAT AI~D DECREE IN Lisa M. Woolums , PLAINTIFF, Michael P. Woolums , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None.