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Home My WebLink About01-1706AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO. 2001-1 ?Or,., CIVIL TERM 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 tail 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, Cumberland County Courthouse, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. AUDRA S. SLONE Plaintiff V. WILLIE DAVID SLONE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : NO 2001- JTOa CIVIL TERM COMPLAINT UNDER THE DIVORCE CODE 23 Pa.C.S. §§ 3301(c), 3301(d), 3301(a)(5) and 3301(a)(0D The plaintiff, Audra S. Slone, by and through her attorneys, the Family Law Clinic, avers the following: 1. Plaintiff is Audra S. Slone, who currently resides at 144 Church Avenue, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Willie David Slone, Jr., who is currently incarcerated at the Oak Glenn Correctional Facility - CC #35, California State Prison, 41100 Pine Bench Rd., Yucaipa, CA 92399. 3. Plaintiffhas been a bona fide resident of Cumberland County and the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on October 19, 1991, in Santa Barbara, Santa Barbara County, California. 5. Plaintiff and defendant have lived separate and apart since April 9, 1999. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Defendant pled nolo contendere to the crime of possession for sale of cocaine base and was sentenced to imprisonment for a period of three years on April 6, 2000. A true and correct copy of the Felony Sentencing Docket and Abstract of Judgment are attached hereto as Exhibit A, and incorporated herein by reference. 9. Defendant has offered such indignities to plaintiff, an injured and innocent spouse, as to render her condition intolerable and life burdensome. 10. Plaintiff has been advised that counseling is available and that plaintiff or defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Date Katherine E. 'Bavoso Certified Legal Intern ROBERT E. RAINS Supervising Attorneys TERI HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 Fax 717-243-3639 00/~/~ · uo.~e s!ql u! epe~ ~e~Spn[ eqt ~o ~lsqe ~ e eq ot 5u!o§e~o~ aqt ~!~ ~q I .L~JNO0 ~H.L :lO suo~lo~oo ~o ),u~wIJed~o m,,'oJqeo ~cl~ ~o Jo13eJ~p ~q~ Aq p~eu§mep j~ueo um),deoeJ ~ql ~j~ o~ peJa~!l~p ~q ol *sAep!loq pue ,sXepunS ,s~epunleS 5u!pnpxe sJnoq gt, Jeue [--"] qt~qtJoJ ~ Up. eqs eqt jo Apo~sno eql ol pepuecue~ s~ iuepue~ep eq.L 't, ~ · uo~qo]d ~o uo.qeoo~e~ ~eue ~ 'o · leedde uo uo!spep'~ed 5upueluesm le ~ 'q · §u~eq §upuetues le.~.u! ),e ~ 'e pesoduJ! eoueiues ~o uo.~noex-d *~ :(Xj~oeds) sJepJo JeCllO '1, ~, :(XJ~. eO';) J®qlo [----1 i---i ro6c Od F-I vzozr Od ~ oi luenwnd YNO [-~ 'q ol luenmnd SQIV ~ 'e 0NIIS31 'Ol. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA Dated &Entd: C)~ -CO(,~-cOq3 Time: Honorable: L_ cD D c~ ~ Dept: Deputy Clerk: ~"F/2r ~ The People o~ Defendant(s): ~ t I I,~ ~ ~'~ $ ~O ~, Present: DeR's Counsel~ I · ~ ' ~ x ' ~ Interpreter: Defendant present: [2~ in Custody [ ] OR [ ] Bail Bond/Cash [ ] Released Defendant convicted by [ ] plea [q~ conditional plea of: Violation ofsection(s)_ / / 'Z' ~-'~ section(s)_ section(s) Count(s)~ - Count(s)__ ~ Court indicated having read and considered the Probation Repor(on file herein~--~ [ ] Court heard oral argument. [c~ Defendant waived ar~:aignment for judgment; there being no legal cause why judgment should not now be pronounced. Grant of Probation [ ] Defendant sentenced to state prison for the U M L term of years on count of the Complaint; execution of sentence suspended and the defendant is granted .years probation on the terms and conditions as stated in the Order on ~obation, including__ d. ays in the County jail. Additional count(s): [ ] Additional count(s): [ ] Count to run concurrent / consecutive to count(s) [ ] Other.7 [ ] Total term: Imposition/Pronouncement of Judgment is suspended and the defendan including_ears probation on the terms and conditions as stated in the Ordetr is granted _days in the County jail. on Probation, Restitution as indicated in the Order on Probation. [ ] Defendant accepted terms and conditions of Order on Probation and was served with the same in open Court. [ } Defendant sign,ed Order on Probation. la. Page 1 of 2 Felony Sentencing Docket · pass!ms!p ( ~ s-.~c~,t~ ,~) - Oo.-LL,'(;);unoD 'aldOOd aq:~jo uo!tom uod~l{~] \ s.~apJ0 .~oq;0 :aaq;o [ I (s)~uamoau~qu3 [ ] '(s),unoa lgUO!:l.!ppg .~oj oaualuaS [ ] Z :aaqmnu as~D 'SA ~l~ldO~d VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. §4904, I verify that the statements made in the foregoing Complaint are tree and correct, to the best of my knowledge, information and belief. Audra S. Slone, Plaintiff "'- AUDRA S. SLONE, Plaintiff VCILLIE DAVID SLONE, JR., Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW 1N DIVORCE NO. 2001- l'/O1'' PRAECIPE TO PROCEED IN FORMA PAUPERIS CIVIL TERM To the Prothonotary: Kindly allow Audra Slone, Plaintiff, to proceed in forma pauperis. I, Katherine E. Bavoso, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing fi:ee legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Katherine E. Bavoso Certified Legal Intern Date: THOMAS M. PLACE Supervising Attorney TERI L. HENNING Staff Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 AUDRA S. SLONE, Plaintiff WILLIE DAVID SLONE, JR., Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 2001- /7o(, CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. i am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Audra Slone Address: 144 Church Avenue, Carlisle, PA 17013 Social Security No.: 160-70-9503 (b) Employment If you are presently employed, state Employer: John W. Gleim Inc. Exacavating Address: 90 Stover Drive Salary or wages per month: $320 week (gross) Type of work: Data entry clerk (c) Other income within the past twelve months: None Interest: Dividends: Pension and annuities: Support payments: (d) Other contributions to household support (Wife)(Husband) Name: Husband is in jail and provides no support. Contributions from children: Contributions from parents: (e) (f) Other contributions: Property owned Cash: Checking account: Savings account: $25.00 minimum to keep it open Certificates of deposit: Real estate (including home): Motor vehicle: Stocks; bonds: Debts and obligations: Outstand'mg: $230.00 Emergency Room Bill for daughter Teawna. $230.00 Emergency Room Bill for herself. Rent: $500 per month Loans: Other: Plaintiff must pay all medical expenses/no medical insurance Electric: $135.00/month Telephone: $50.00/month Cable: $41.00/month Water/Sewer: $45.00/month Transportation: $100/month Child Care Expenses: $200/month Food: $400.00/month Oil: $350.00/whenever needed Persons dependent upon you for support: Three Children Names: Alexandra Charisse Slone Mikia Renee Slone Teawna Justine Slone Ages: 8 6 5 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are hue and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. §4904, relating to unswom falsification to authorities. t I Audra S. Slone, Plaintiff AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE, NO. 2001-t 3 ')(w CIVIL TERM ACCEPTANCE OF SERVICE D ate cc: Audra Slone AUDRA S. SLONE, Plaintiff V. WILLIE DAVID SLONE, Jr., Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNT Y, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : NO. 2000-1706 CWIL TERM RETURN OF SERVICE I, ~ Byrtus, a competent adult, hereby certify that I se~wed a true and correct copy of the Divorce Complaint on Wi~lLe D,a,v~d~.S~.: J~f,~,~' ~!~ h,~an~)ng~7~°cuments to him at the(~t/c ~{'~'~c~ ~/'~2t4f"~'? a~r,: '5 ~-5' ~/'~ -Servi,;~ was complete upon ~eceipt by Willie David Slone on the ~__day of ~?r//, 2001 at Date RECEIVED APR 1 2 2001 AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION -. LAW : IN DIVORCE : NO. 2001-1706 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on March 22, 2001. 2. The marriage of Plaintiff and Defendant is irretriewibly broken and ninety (90) days have elapsed from the date of 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 herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date Audra S. Slone, Plaintiff RECEIVED AU$ 3 1 AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION -. LAW : IN DIVORCE : NO. 2001-1706 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce witthout 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 ~s granted. 3. I understand that I will not be divorced until a divo2:ce 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 unsworn falsification to authorities. Date AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW IN DIVORCE NO. 2001-1706 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on March 22, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities, i ~ Date ~7- [-~r ~ 'ant ~iili~q)a~id Slone. Jr.. De~ena AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -. LAW : IN DIVORCE : NO. 2001-1706 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF ri'liE 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 statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date - I Willi~ David Slolie, Defen AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -- LAW : IN DIVORCE : NO. 2000-1706 CIVIL TERM CERTIFICATE OF SERVICE I, Michelle L. Anderson, hereby certify that on this 4th day of September 2001, I am serving a tree and correct copy of Plaintiff's Affidavit of Consent and Plaintiff's Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301 (c) of the Divorce Code on Willie D. Slone, Jr., at the following address: 2514 Cliff Dr/ye, Santa Barbara, CA 93109, by first class U.S. mail. ichelle L. An3~fson Certified Legal-rntem FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243 -2968 AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant : IN THE COURT ,OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION -. LAW : IN DIVORCE : NO. 20015etq06 CIVIL TERM CERTIFICATE OF SERVICE I, Elisabeth L. Rowley, hereby certify that on this 13th day of September 2001, I am serving a true and correct copy of Defendant's Affidavit of Consent and Defendants's Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code on Willie D. Slone, Jr., at the following address: 2514 Cliff Drive, Santa Barbara, CA 93109, by first class U.S. mail. Date/ Certified Legal In~rn ~ FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 AUDRA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : : NO. 2001-1706 CIVIL TERM 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 5, 2001- Hand delivered by Kathleen Byrms; Defendant also signed an Acceptance of Service. 3. Date of execution of the Affidavit of Consent requh:ed by Section 3301(c) of the Divorce Code: by the plaintiff, August 30, 2001; by the defendant, September 1, 2001. 4. Related claims pending: none. 5. Date plaintiff's Waiver of Notice in §3301(c) Divo:me was filed with the pronthonotary: September 4, 2001. Date defendants Wmver of Notice in §3301 (c) Dlvorc ~ was filed with the pronthonotary: September 13, 2001. Certified Legal Inte~ ]~I~ERT IE. RAINS THOMAS M. PLACE TERI L. HENN1NG Supervising Attorneys Date: September 21, 2001 FAMILY ]LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 AUDKA S. SLONE Plaintiff WILLIE DAVID SLONE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 1N DIVORCE : : NO. 2001-1706 CIVIL TERM CERTIFICATE OF SERVICE I, Elisabeth L. Rowley, hereby certify that on this 21st Clay of September 2001, I am serving a tree and correct copy of the Praecipe To Transmit Record and Vital Statistics form on Willie D. Slone, Jr., at the following address: 2514 Cliff Drive, Santa Barbara, CA 93109, by first class U.S. mail, postage prepaid. (l~lisab~th L'~,. le, Y Certified Legal h~tem FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 PLEAS 1N THE COURT OF COMMON OF CUMBERLAND COUNTY PENNA. STATE OF AUDRA S. SLONEt plaintiff VERSUS WILLIE DAVID SLONE, JR., NO. 1706 3~FP DECREE IN DIVORCE Defendant 2001 AND NOW,~ DECREED THAT __ ATI~ .., PLAINTIFF, AND ~i'T,}',TE DAVTD ,qT,CN'Er ,tr. ,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; By ~T~h~~/ t{ J. ATTEST: ~/~~ PROTHONOTARY