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Home My WebLink About01-2094 PATRICIA A. WILDE, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNS¥'LVANIA · · v. : CIVIL ACTION - DIVORCE · · MICHAEL M. WILDE, : NO. 01- Defendant : . NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against th~'claims set forth in thc following pages, you must take prompt action. You arc warned tha~fyou fail to do so, the case may proceed without you and a decree of divorce or annulment ay bc entered against you bY thc court. A judgment may also be entered against you fbr andy other claim or relief requested in these papers by thc plaintiff. You may lose money o/r~lS~opcrty 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 Cumberland County Court of Common Pleas, One 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 1-800-990-9108 PATRICIA A. WILDE, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA · · v. : CIVIL ACTION - DIVORCE · · MICHAEL M. WILDE, :NO 01 - ~.~¥' ~ ~ Defendant . ' · 1. Plaintiff, Patricia A. Wilde, Social Security # 191-46-2166, is an adult individual who currently resides at 207 Old York Road, Apt. 2 New Cumberland, York County, Pennsylvania 17070. 2. Defendant, Michael M. Wilde, Social Security # 375-56-8909, is an adult individual who currently resides at 315 Fifth Ave., First Floor, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The parties were married on December 4, 1977 in Camp Hill, Cumberland County, Pennsylvania. 5. The parties have lived separate and apart since on or about October 1, 1997. 6. Neither party has instituted any prior action of divorce or annulment with regard to this marriage in this or any other jurisdiction. 7. Plaintiff avers that there are three children of the marriage, namely: lan Wilde, born January 16, 1980, Daniel Wilde, born September 25, 1984, and Mark Wilde, born October 24, 1988. 8. Neither the Plaintiff nor the Defendant are members of the Armed Forces of the United States of America or any of its allies. 9. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter pursuant to 3301(c) or 3301(d) of the Divorce Code. RESPECTFULLY SUBMITTED, Date ' ' - Cindy L. Kos~~ - Attorney ID/~o~/751~99 4810 Derry treet Harrisburg, PA 17111 Telephone (717) 564-1084 FAX (717) 564-5158 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dat~ / Patric~a A. Wilde, Plaintiff PATRIClA A. WILDE, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA · · v. : CIVIL ACTION - DIVORCE · · MICHAEL M. WILDE, : NO. 01- z~~~ ~ ~'".~~~ Defendant . · ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint in the above- captioned action. Michael Mason Wilde, Defendant Print mailing address- PATRICIA A. WILDE, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA · · v. : CIVIL ACTION - DIVORCE · · MICHAEL M. WILDE, : NO. 01 - 2094 CIVIL TERM Defendant . · AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 9, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 made herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: /,/~~/~~-'3- -~_ ' ~' Patricia A. Wilde, Plaintiff PATRIClA A. WILDE, 'IN THE COURT OF COMMON PLEAS Plaintiff · :CUMBERLAND COUNTY, PENNSYLVANIA · V. ' : CIVIL ACTION - DIVORCE · · MICHAEL M. WILDE, · NO. 01 2094 CIVIL TERM Defendant : - · w_.4_A ORCQ 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 ill 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 sub' Pa C S §4904 relatin to ..... · ...... ~ect to the penal" s of 18 · · · g unsworn fals~ficabon tO authorities. ,,~ /" / ,.." C_ ,'~ . ,/i /....."' Date: _ ~ /~'~_d? ~-. / '- -- M",cfiaei ~' ~lde, Defendant · IN THE COURT OF COMMON PLEAS PATRICIA A. WILDE, · · CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff · · · · CIVIL ACTION - DIVORCE V. · NO. 01 -2094 CIVIL TERM MICHAEL M. WILDE, · · Defendant · PRAFCIPI:: 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. ~. Date and manner of service of the complaint: Defendant si,qned Acceptance.. of Service on April 16, 2001. 3. Date of execution of affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on January 16, 2002; by Defendant on January 18~ 200____[2. 4. Related claims pending' Resolved by informal agreement of the parties. 5. Date of execution of waiver of Notice of Intent: by Plaintiff on January 16_ 200~2; by Defendant on January 18, 2002; and date of filing of waivers: February 5, 2002. -- - ~ .indy L. ~er, Esquire Date / ~ ~~ 75899 Attorney 4810 Derry Street Harrisburg, PA 17111 Telephone (717) 564-1084 Fax (717) 564-5158 v' ~I INTHE COURT OF COMMON PLEAS ~ PENNA ~f STATE OF , · · ,t I ¢ ~.__A_ ,4 ,_..~/. _..~_!~.,.'._.n..~...;.~~ ..................... ~,, .~!..:.~~,./ ~,v,:/?~,-,~ ~.. /.~~.~.~_~ ...... ~_., ..... _~/.~~.~,.. ~ ..................... bo.f..e.~..d...o~__± ............................ ~~ DECREE IN ~t DIVORCE ~ AND NOW ~ I'~ ~...~,~ it is ordered and ~,,; /' . . . . . . . .~1.. · . . · · · · · · · · · · · ' ' i~ .... , ~ decreed that ....... '~~/~. ~'~'/"'~' ~*'' ~C~, Y~..~, ...... plaintiff, .... . . · . . · · · · . . · . · . · · . · · . . . · ~ ~ ,~~~./ ~~ ~]/~~ defendant, ~ and ........... ~. · ....................... are divorced from the bonds of matrimony. The court retains jurisdiction of the tollowing claims which have been raised of record in this action for which a tinal order has not yet ~" been entered' . · .... · · . · . ....... · · . · . . · . · · . .... · .... · · . . · . · . . · . · . · · . . . · . . · . · · . · · . · ~ , .. . . , · .