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HomeMy WebLinkAbout10-0303C Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHAUN R. WILLIAMS, Plaintiff V. TAMARA L. WILLIAMS, Defendant IN THE COURT OF G@DPEEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. lo-303 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 and visitation of your children. When the grounds for a 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 the County Courthouse. 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, PA 17013 (717) 249-3166 3S '-) Z6 &6:* ?? y9 FILED-O rICE Jr L. ? 2010 jAN I I PM T 32 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHAUN R. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ?U ' ?U 3 c :v TAMARA L. WILLIAMS, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Shaun R. Williams, an adult individual residing at 111 S. 3rd Street, Apt. #7, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant is Tamara L. Williams, an adult individual residing at 111 S. 3rd Street, Apt. #7, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on November 23, 2006 in Carlisle, Pennsylvania. 5. There are no children born of this marriage. 6. The parties separated on December 24, 2009. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9 of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. ADULTERY 12. The averments in paragraphs 1 through 11, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 2 13. Defendant has committed adulterous acts in violation of the marriage vows and the laws of the Commonwealth of Pennsylvania. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Shaun R. Williams, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; and B. Awarding other relief as the Court deems just and Dated: January 11, 2010 BarYara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 3 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHAUN R. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. TAMARA L. WILLIAMS, Defendant NO. CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that 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 do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: January 11, 2010 S UN R. WILLIAMS Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHAUN R. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. TAMARA L. WILLIAMS, Defendant NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, Shaun R. Williams, hereby certify that the facts set forth in the foregoing Pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: January 11, 2010 , SHAUN R. WILLIAMS I Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Pill- V 1010 JAN 11 PH 4: 03 SHAUN R. WILLIAMS, Plaintiff v. TAMARA L. WILLIAMS, Defendant IN THE COUft CUMBERLAND NO. JJ 3 CIVIL ACTION -LAW IN DIVORCE ION PLEAS , PENNSYLVANIA ORDER ADOPTING STIPULATION OF PARTIES AND NOW, to wit, this IIth day of January, 2010, upon consideration of the attached Stipulation and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, Shaun R. Williams, and on motion of Defendant, Tamara L. Williams, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation are adopted as an Order of Court as if set forth herein at length. Z a4 BY THE COURT, a Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHAUN R. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. TAMARA L. WILLIAMS, Defendant :NO. ?d 3 d 3 cN CIVIL ACTION - LAW IN DIVORCE STIPULATION THIS AGREEMENT is made this I It' day of January, 2010, by and between Shaun R. Williams, (hereinafter referred to as "Husband") an adult individual residing at 34 Newport Road, Duncannon, Pennsylvania, and Tamara L. Williams, (hereinafter referred to as "Wife") an adult individual residing at 397 Samplebridge Road, Enola, Pennsylvania. WHEREAS, the parties are Husband and Wife having married on November 23, 2006; WHEREAS, the parties separated on December 24, 2009; WHEREAS, in light of the heightened tensions between Husband and Wife, the parties desire to confirm their agreement relating to no personal contact during this -ft divorce action. NOW THEREFORE, the parties intending to be legally bound, do agree as follows: 1. The recitals contained in the whereas clauses are incorporated herein by reference. 2. During the course of this divorce action, Husband and Wife shall have no contact with one another. Contact shall be defined as personal, telephone, text, e-mail or any other electronic contact. 3. Husband and Wife agree that any and all necessary communications between them during this divorce action shall be made only through his or her respective counsel. 4. This agreement shall be entered as an Order of Court. IN WITNESS WHEREOF, the parties hereto, set forth theirs hands and seals. SIG A AND DELIVERED I HE A EN E OF: / L r/ C<?? Z??Jl -11 l WITNESS Shan R. William WI SS mara L. Williams FiLEU--t~;'~-!CE t~F ?~-'~ c~~~;.~n~y~TA~Y Barbara Sumple-Sullivan, Esquire Supreme Court #32317 ZQ10 JAPE 13 PIS 3: 3 5 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CUi~I~~L.-::_:` ~ ~~_~'.:~~_ii~fiY SHAUN R. WILLIAMS, IN THE COURT OF COMMON P~ ~ ~ ' ~ 'f ~~ `~~~`' Plaintiff v. TAMARA L. WILLIAMS, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. O O ~' ~V CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Tamara L. Williams, hereby accept service and acknowledge receipt of the above-captioned Divorce Complaint having received said Complaint on the 11~' day of January, 2010. -! Dated: January 11, 2010 '`~~ amara L. Williams Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 F?L?D=?F FPC? Vii= THF FROTFiouQT Pj 2011 FEB -2 PM 12: c ;S C SHAUN R. WILLIAMS, Plaintiff v. TAMARA L. WILLIAMS, Defendant IN THE COURT OF COM ,MP, CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-303 CIVIL ACTION .-LAW 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. Ground for divorce: Irretrievable breakdown under §3301(c) or §3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service on January 11, 2010. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff- January 29, 2011; and by Defendant: January 29, 2011. 4. Related claims pending: None. 5. Date of filing of Plaintiffs and Defendant's Wa February 02, 2011. Dated: l/ of Consent: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Defendant Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 L717)774-1445 SHAUN R. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10-303 TAMARA L. WILLIAMS, CIVIL ACTION .-LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Ms. Tamara L. Williams 397 Samplebridge Road Enola, PA 17025 DATED: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court 432317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 FILED-OFFICE OF THE PROTF'CNCTAR I` 2011 FEB -2 Ply 12: 54 CUMBERLAND CGUN -r V PENNSYLVANIA SHAUN R. WILLIAMS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-303 TAMARA L. 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 January 11, 2010. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: SHAUN R. WILLIAMS Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 FILED-OFFICE OF THE PROTHONOTARY 2011 FEB -2 FM 12: 55 CUMBERLAND COUNT`' PENNSYLVANIA SHAUN R. WILLIAMS Plaintiff V. TAMARA L. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-303 : CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. DATE: C - 19 - ( ( off' `'? SHAUN R. WILLIAMS l 'FILED-OFFICE Barbara Sumple-Sullivan, Esquire (gip' THE P R 0 T H 000 TA. IR Supreme Court #32317 549 Bridge Street 2011 FEB _2 Phi 12: SS New Cumberland, PA 17070 (717) 774-1445 CUMBERLAND COUNTY PENNSYLVANIA SHAUN R. WILLIAMS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-303 TAMARA L. 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 January 11, 2010. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: - `7 TAMARA L. WIL IAMS COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF A ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared TAMARA L. WILLIAMS, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing and Affidavit of Consent is true and correct to the best of her knowledge, information and belief. Affirmed and subscribed to before me this o2 T day of 14,oV , 2011. %ool gO 9RU?B My commission expires: IZ1131112- ?TMar ?rra. PW* eOro. JRCui ?iNlw O OIr 1 1Q12 IF Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 .FILED-OFFICE O THt PROTHONOTARY 2011 FEB -2 PM 12: 55 CUMBERLAND COUNTY PENNSYLVANIA SHAUN R. WILLIAMS Plaintiff V. TAMARA L. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-303 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unswom falsification to authorities. DATE: TAMARA L. WIL IAMS COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF u / ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared TAMARA L. WILLIAMS, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing and Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code is true and correct to the best of her knowledge, information and belief. Affirmed and subscribed to before me this 7 ?? day of , 2011. O Y PUB My commission expires: COMIMONAVALT OPP , riv/WU ROLMq L?a?Y??`?., Np4?ry q?bNC ? ? Oro?r 31,'Oi3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHANN'4R. WILLIAMS V. TAMARA L. WILLIAMS : NO 2010-303 DIVORCE DECREE AND NOW, FaL - 4- -2_, it is ordered and decreed that Shaun R. Williams plaintiff, and Tamara L. 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, ?P/u J. rothonotary a?q?a- cert. Copy( nnaalex! fo any sumple- 1j ulliurn Nvhee + UY rnai led -to DeR