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Home My WebLink About01-2323 ,.W~E ~ ~O1~, · TN THE COURT OF COI~ON P~ PLAINTIFF ' C~ COUNTY, PENNSYLVAN~ v. ' NO. 2001 -~J~ CIVIL TERM WILLIAM MICHAEL V]tLORA, ' IN DIVORCE DEFENDANT · NOTICE TO DEFE~ 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 ta action. You are warned that if ..... =-= .... ke prompt ~u ~u~± ~o ~o so the Proceed without you and a decree o~ ~ ........ ' ~ case may ~ ~~u~= 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator,s Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. I[sYOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 JULIE ANNE %rALORA, ' IN THE COURT OF COMMON PLEAS PLAXNTIFF ' ~ COUNTY, PENNSXLVANIA v. ' NO. 2001 - ~~ CIVIL TERM WILLIAM MICltI~L ~~.,01~, ' IN DIVORCE DEFENDANT · COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE Di-~ORCE CODE IN Di-~ORCE 1. The Plaintiff is Julie Anne Valora who resides at 229 W. Main Street, Apartment #3, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is William Michael Valora who resides at 2001 Red Bank Road, Lot 313, Dover, York County, Pennsylvania 17315. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 4, 1994 in York County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff reqUests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint 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. --~lie Anne Valora JULIE ANNE VALORA, : IN THE COURT OF COMMON PLEAS PLAINTIFF : ~ COUNTY, PENNSYLVANIA v. : NO. 2001 - 2323 CIVIL TERM WILLIAM MICHAEL VALORA, : IN DIVORCE DEFENDANT : AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce and Plaintiff's Affidavit under section 3301(d) was served upon the Defendant by depositing the same in the United States mail on April 20, 2001 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the signed Acceptance of Service attached hereto, the Complaint was received by the Defendant on April 23, 2001. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 JULIE ANNE VALORA, ' IN THE COURT OF COMMON PLEAS PLAINTIFF ' C~ COUNTY, PENNSYLVANIA v. ' NO. 2001 - 2323 CIVIL TERM WILLIAM MICHAEL VALORA, ' IN DIVORCE DEFENDANT · ~AFFIDAVIT OF CONStaNT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 20, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 acknowledge that pursuant to Rule 1920 42(e) I have waived the · requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /Julie Anne Valora JUL~E ~ ~O1~, ' ~N THE COURT OF COLSON P~ PLAINTIFF ' ~ COUNTY, PENNSXLVANIA .. v. ' NO. 2001 - 2323 CIVIL TERM WILLIAM MICHAEL VALORA, ' IN DIVORCE DEFENDANT · ENTRY OF A D IVORC~ DFC_~.~_ UND_~._~ 1. I consent to the entry of a final decree 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 s~atements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. lie Anne Valora - JULIE ANNE VALORA, ' IN THE COURT OF COMMON PLEAS PLAINTIFF ' C~ COUNTY, PENNSYLVANIA v. ' NO. 2001 - 2323 CIVIL TERM WILLIAM MICHAEL VALORA, ' IN DIVORCE DEFENDANT AFFIDAVIT OF C ,N ENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 20, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. · . DATED- /___~~_~X~/- WilliamMichael Valora - JUL~E ~ ~O1~, ' ~N THE COURT OF COITION p~ PLAINTIFF ' C~ COUNTY, PENNSYLVANIA V. · NO. 2001 - 2323 CIVIL TERM WILLIAM MICHAEL VALORA, ' IN DIVORCE DEFENDANT . _ENTRY OF A DIVORCE DEC~REE ER 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED- William Michael Valora v · f ~ JULIE ANNE VALORA, ' IN THE COURT OF COMMON PLEAS PI.~INTIFF ' ~ COUI~Y, V. ' NO. 2001-2323 CIVIL TERM W'J:~I~ MICltI~L V]~OI~, ' IN DIVORCE DEFENDANT · PRAECIPE TO TRANSMIT RECORD To the Prothonotary- Transmit the record, together with the following information, to the Court for the 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- On April 23, 2001 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code- By Plaintiff, July 25, 2001; By Defendant, July 30, 2001. 4. Related claims pending- None . 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on August 3, 2001. Date Defendant's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on August 3, 2001. Thomas D. Gould, Esquire Attorney For Defendant IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF PENNA. JULIE ANNE VALORA, Plaintiff NO. 2001-2323 CIVIL VERSUS WILLIAM MICHAEL VALORA, Defendant DEC tee IN .. DIVORCE AND NOW, ~ ~ 0 ~ SN ~ , 2001 , it iS ORDERED AND JULIE ANNE VALOP. A DECREED ThAT , PLAintiff, AND WILLIAM MICHAEL VALORA , 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 The COUrt: PROTHON