HomeMy WebLinkAbout05-1529
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
KAREN E. WILSON,
v
: CIVIL ACTION LAW
Defendant
: NO. 2005 -
: DIVORCE
/5J5
RONALD E. WILSON, II,
NOTICE TO PLEAD
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that
if you fail to do so the case may proceed without you and a judgment may be entered against
you by the Court without further notice for any money claimed in the complaint or for any
other claim or relief requested by the Plaintiff. You may lose money or property or other
rights important to you.
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 Street
Carlisle, Pennsylvania
717-249-3166
KAREN E. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v
: CIVIL ACTION LAW
RONALD E. WILSON, II,
Defendant
: NO. 2005 -
: DIVORCE
COMPLAINT
Plaintiff, Karen E. Wilson, by her attorneys, Broujos & Gilroy, P.C., sets forth the following:
1
Plaintiff, Karen E. Wilson, is an adult individual residing at 487 Highland Street, Carlisle,
Cumberland County, Pennsylvania.
2
Defendant, Roanld E. Wilson, II, is an adult individual residing at 7 Watson Drive, Carlisle,
Cumberland County, Pennsylvania.
3
Plaintiff and Defendant were married in Cumberland County Pennsylvania on June 6, 1992.
4
Both Plaintiff and Defendant have resided continuously in the Commonwealth of
Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of
this action.
5
There have been no prior actions of divorce or for annulment between the parties.
6
The marriage is irretrievably broken.
7
The Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing her
from the Defendant.
BROUJOS & GILROY, P.c.
Hubert X. Gilroy, Esquil1
Attorney for Plaintiff
Broujos & Gilroy, P.
4 North Hanover Str
Carlisle, PA 17013
717-243-4574
By q;- (<J
I verify that the statements in the foregoing pleading are true and correct. I
understand that false statements herein are made subject to the penalties of 18 PaCS
4904 relating to unsworn falsification to authorities.
~/jb 105
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Karen E. Wilson, Plaintiff
Date
I verify that the statements in the foregoing pleading are true and correct. I
understand that false statements herein are made subject to the penalties of 18 PaCS
4904 relating to unsworn falsification to authorities.
3/10/05
Date
f(0Mt\ f. ~
Karen E. Wilson, Plaintiff -
I verify that the statements in the foregoing pleading are true and correct. I
understand that false statements herein are made subject to the penalties of 18 PaCS
4904 relating to unsworn falsification to authorities.
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Karen E. Wilson, Plaintiff
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KAREN E. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V A IA
V.
: CIVIL ACTION - LAW
RONALD E. WILSON, II,
Defendant
: NO. 2005 - 1529
: DIVORCE
ACCEPT ANCE OF SERVICE
,
I, Jane Adams, Esquire, represent Ronald E. Wilson, II, in t~e above- aptioned
matter, and I hereby accepted service of Plaintiff's Notice to Defend and Cdmplaint i Divorce
,
,
I
on behalf of Defendant on or about March 24,2005, and hereby affirm I ant authoriz d to do so.
!
Date:#S-
Adams, Esquire
. Pitt St.
lisle, Pa. 170 I3
(717) 245-8508
Attorney for Defendant
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KAREN E. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V A IA
V.
: CIVIL ACTION - LAW
RONALD E. WILSON, II,
Defendant
: NO. 2005 - 1529
: DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE I,
TO THE PROTHONOTARY:
i
Please enter the appearance of Jane Adams, Esquire as Attorney of rtcord for onald E.
Wilson, II, Defendant, in the above-captioned matter.
Date:'j /2f! ~1 ~--
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ane Adams, Esquire
I.D o. 79465
6 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508 I,
ATTORNEY FOR DEFE!tlDANT
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KAREN E. WILSON,
Plaintiff
IN THE COURT OF COMMON PL AS
CUMBERLAND COUNTY, PENN YL V ANJA
No.;) (;O.s -l ("~ 1 Civil Te
vs.
RONALD E. WILSON,
Defendant
ACTION IN DIVORCE
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this >>,.J. day of h Ath..-b-l
between, KAREN E. WILSON, of Carlisle, Pennsylvania, hereinafter referre
and RONALD E. WILSON, of Carlisle, Pennsylvania, hereinafter referred to
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on June 6, 199 , m
Mechanicsburg, Cumberland County, Pennsylvania, and;
WHEREAS, there were two children born of this marriage;
,2005, by and
to as "WIFE",
"HUSBAND".
WHEREAS, differences, disputes, and difficulties have arisen betwee the parties and it
is the intention of Husband and Wife to live separate and apart for the rest oft eir natural lives,
and the parties desire to settle their respective financial property rights and obI gations as
between each other, including the settling of all matters between them relating to ownership and
equitable distribution of real and personal property; the settling of all matters etween them
relating to the past, present, and future support, alimony, and/or maintenance f Husband or
Wife; and in general, the settling of any and all possible claims by one against he other or
against their respective estates;
NOW THEREFORE, Wife and Husband, each intending to be legally ound, hereby
covenant and agree as follows:
1. FULL DISCLOSURE OF ASSETS. Each party warrants that he she has made a
full and fair disclosure of income, assets, and their valuation prior to the execut" on of this
Agreement as well as any other fact relating in any way to the subject matter 0 this agreement.
.
.
These disclosures are part of the consideration made by each party for en ering into this
agreement.
2. ADVICE OF COUNSEL. The Husband has employed and h the benefit or counsel
of Jane Adams, Esquire, as his attorney. The Wife has employed and ha the benefit or counsel
of Hubert X. Gilroy, Esquire, as her attorney. Each party has carefully an completely read this
agreement and has been advised and is completely aware not only of its c ntents but of its legal
effect.
3. SEPARATION. The parties intend to maintain separate and ermanent domiciles
and to live apart from each other. It is the intention and purpose of this a reement to set forth
their respective rights and duties while they continue to live apart from ea h other. Neither party
shall harass, annoy, injure, threaten, or interfere with the other party in an manner whatsoever.
Each party may carry on and engage in any employment, profession, busi ess or other activity as
he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment,
or disposition of any property now owned and not specified herein or pro rty hereafter acquired
by the other.
4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Wife has tiled a
Complaint in Divorce in Cumberland County, Pennsylvania, claiming that the marriage is
irretrievably broken under the no-fault mutual consent provision of Sectio 330 I (c) ofthe
Pennsylvania Divorce Code. Husband hereby expresses his agreement tha the marriage is
irretrievably broken and expresses his intent to execute any and all affidav ts or other documents
necessary for the parties to obtain an absolute divorce pursuant to Section 301(c) of the Divorce
Code. The parties hereby waive all rights to request Court Ordered couns ing under the Divorce
Code. The provisions of this Agreement relating to equitable distribution fproperty of the
parties are accepted by each party as a final settlement for all purposes wh tsoever, as
contemplated by the Pennsylvania Divorce Code.
Should a decree, judgment, or order of separation or divorce be obt ined by either of the
parties in this or any other state, country or jurisdiction, each of the parties ereby consents and
agrees that this Agreement and all of its covenants shall not be affected in y way by any such
separation or divorce; and that nothing in any such decree, judgment, order or further
modification or revision thereof shall alter, amend, or vary any term of this greement, whether
or not either or both of the parties shall remarry. It is specifically agreed th t a copy ofthis
Agreement or the substance of the provisions thereof, may be incorporated y reference into any
divorce, judgment, or decree. This incorporation shall not be regarded as a erger, it being the
specific intent of the parties to permit this Agreement to survive any judgm nt and to be forever
binding and conclusive upon the parties.
5. DATE OF EXECUTION. The "date of execution" or "executi n date" of this
agreement shall be defined as the date upon which it is executed by the part" es if they have each
executed the Agreement on the same date. Otherwise, the "date of executio "or "execution
date" of this Agreement shall be defined as the date of execution by the part last executing this
Agreement. All provisions of this agreement shall be effectuated by the pies within thirty
.
.
(30) days of the execution date of this agreement unless otherwise speci
agreement.
6. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and IFE each do hereby
mutually remise; release, quit-claim and forever discharge the other and t e estate of the other, of
and from any and all rights; titles, and interests, or claims in or against th property (including
income and gain from property hereafter accruing) of the other or against he estate of such other,
or whatever nature and wheresoever situate, which she or he now has or a any time hereafter
may have against such other, the estate of such other or any part thereof, hether arising out of
any former acts, contracts, engagements, or liabilities of such other or by ay of dower or
curtesy, or claims in the nature of dower or curtesy of widow's or widowe 's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the other as tes amentary, or all other
rights of a surviving spouse to participate in the decease spouse's estate, ether arising under
the laws of Pennsylvania, any state, commonwealth, or territory of the Um ed States, or any other
country, or any rights which Wife may have or at any time hereafter have gainst the other for
past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees,
costs, expenses, or equitable distribution of marital property whether arisi g as a result of any
marital relation or otherwise, except, and only except, all rights and agree ents and obligations
of whatsoever nature arising or which may arise under this agreement or P r the breach of any
thereof.
7. WARRANTY OF DEBTS AND FUTURE OBLIGA nONS. Each party warrants
that they have not contracted any debt or liability for the other or which th estate of the other
party may be responsible or liable, and except only for the rights arising ou of this agreement,
neither party will hereafter incur any liability whatsoever for which the oth r party or the estate
of the other party, will be liable. Each party agrees to indemnifY or hold h mless from the other
and against all future obligations of every kind incurred by them, including those for necessities.
8. OUTSTANDING JOINT DEBTS.
(a) Wife agrees that the following debts are her own personal respo sibility and therefore
agrees to completely and finally pay on the following debts and obli ations.
Wife shall pay any and all amounts owed to her mother, Ann Sawyer,
And shall indemnifY Husband and hold him harmless from t is obligation.
(b) Husband agrees that the following debts are his own personal re ponsibility and
therefore agrees to completely and finally pay on the following debts and obligations.
Any and all debts relating to the home located at 7 Watson 've, Carlisle, Pa;
Any and all loans against his 401 (k).
Any and all debt related to the parties' Mastercard and Disco er card, which total
approximately $] 8,000.00; these accounts have been closed a d Husband took out
a personal loan with Members First to satisfY these obligation. Payment was
.
.
made directly from Members First to Mastercard and Disc ver. Husband has
provided current statements from these accounts and main ains that both balances
are $0 and both accounts have been closed. However, in t e event that any late
fees, penalties, or unpaid balances would remain on either fthese accounts,
Husband will pay off these balances and shall indemnifY ife and hold her
harmless from these obligations.
9. EQUITABLE DIVISION OF MARITAL PROPERTY. T e parties have
attempted to distribute their marital property in a manner which conforms 0 the criteria set forth
in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following cons'derations: the length of
the marriage, the age, health, station, amount, and sources of income, voc tional skills,
employability, estate, liabilities, and needs of each of the parties, the contr bution of each party to
the education, training, or increased earning power of the other party; the pportunity for each
party for future acquisitions of capital assets and income; the sources of in ome of both parties,
including but not limited to medical, retirement, insurance or other benefit; the contribution or
dissipation of each party in the acquisition, preservation, depreciation, or a preciation of the
marital property, including the contribution of each spouse as a homemake; the value of the
property set apart to each party; the standard of living the parties establishe during the marriage;
and the economic circumstances of each party at the time the division of pr perty is to become
effective.
The division of existing marital property is not intended by the parti s to constitute in any
way a sale or exchange of assets, and the division is being effected without he introduction of
outside funds or other property not constituting marital property. The divis on of property under
this Agreement shall be in full satisfaction of all the marital rights of the pies.
As such, the parties acknowledge that Husband or Wife's obligation 0 make the
payments defined in this agreement shall not be subject to termination, disc arge, or
discontinuance in bankruptcy or for any other reason or by any Court or trib nal. Should
Husband or Wife pursue and action in bankruptcy and be successful in extin uishing his
obligation to pay any debts for which he has assumed sole obligation as set rth herein, he or she
shall immediately be obligated to pay alimony to the other party in an amou t equal to the
monthly obligation on such debts that he or she otherwise had assumed and or which he had
taken sole obligation and responsibility, plus an additional fifteen percent (I %) in consideration
of the tax consequences associated with receipt of alimony. At the time of t e implementation of
this alimony award, which may be made through the appropriate Domestic lations of support
office with the Court of Common Pleas of appropriate jurisdiction as Husba d or Wife may
select, such party shall then be responsible for any such debts extinguished t rough the other
party's bankruptcy as described herein.
10. OTHER PERSONAL PROPERTY. Husband and Wife do her by acknowledge
that they have previously divided all their tangible personal property. Exce as may otherwise
be provided in this Agreement, Wife agrees that all of the property of Husban or in his
.
.
possession shall be the sole and separate property of Husband; and Husb nd agrees that all of the
property of Wife or in her possession shall be the sole and separate prope of Wife. The parties
do hereby specifically waive, release, renounce, and forever abandon wha ever claim, if any, he
or she may have with respect to the above items which shall become the s Ie and separate
property of the other.
11. MOTOR VEHICLES. With respect to the motor vehicles, wned by one or both
of the parties, they agree as follows:
(a) The 2004 Grand Am shall be and remain the sole and exclusiv property of Wife.
(b) The 1994 Toyota Pickup shall be and remain the sole and excl sive property of
Husband.
The titles to the said motor vehicles shall be executed by the partie , if appropriate for
effecting transfer as herein provided, within thirty days of the execution deaf this Agreement,
and said executed titles shall be delivered to the proper parties on the distr bution date. Each
party agrees to be solely responsible for the amounts presently due and ow ng against his or her
respective automobiles.
12. MARITAL HOME. HUSBAND and WIFE hold title as T ants by the Entireties
to the premises identified as 7 Watson Drive, Carlisle, Pennsylvania, 1701 . The parties agree as
follows with respect to the marital residence:
(a) Husband has arranged for refinancing of the marital residence a d will pay Wife the
amount of$20,6l2.00 upon refinancing in full satisfaction of her e uity in the marital
residence. The closing will occur on March 25, 2005. On or befor March 25, 2005,
Wife shall deliver a deed, conveying all right, title and interest in a d to the marital
residence in exchange for the payment to her. Wife shall also sign a waiver of marital
interest and any other documentation which will be necessary to fac"litate Husband's
refinance of the mortgage obligation on the marital home.
(b) In addition to the payment of $20,6] 2.00, Husband shall also pa to Wife the amount
of$4,388.00, which will be obtained through a loan against Husban 's 401(k). Husband
shall apply for this loan within thirty (30) days of this agreement an upon receipt of
funds shall promptly pay wife this amount.
(c) As of the date of separation, and without regard to when bills fo such items are
incurred, received or due, HUSBAND shall be solely responsible fo all past, present, and
future costs or liabilities associated with or attributable to maintaini g the marital
residence (except as provided herein), including but not limited to, I real estate taxes,
water and sewer rents, gas, electric, and telephone service, homeo er's insurance, and
gardening expenses and repairs, and HUSBAND shall keep WIFE a d her successors,
assigns, heirs, executors, and administrators indemnified and held h mless from any
liability, cost or expense, including attorney's fees, which are incurr d in connection with
.
.
such maintenance, costs, and expense. HUSBAND shall indemn' and hold WIFE
harmless from any liability, cost or expense, in connection with ny expense required to
be made by HUSBAND including but not necessarily limited to, t e first mortgage,
property taxes, and insurance with respect to aforesaid premises.
13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. xcept as otherwise
provided in this agreement, the parties agree to waive any and all rights th y have in and to each
other's employment benefits, including but not limited to both parties pen ions and retirement
plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits
of the other at any time in the future.
14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL F ES. Other than as
provided in this agreement, each party hereby waives any right to spousal upport, alimony, or
alimony pendente lite, and each party agrees to be responsible for his or h own legal fees and
expenses. The parties herein acknowledge that by this Agreement, they ve respectively
secured and maintained a substantial and adequate fund with which to pro ide for themselves
sufficient financial resources to provide for their comfort, maintenance, an support in the station
of life to which they are accustomed. Wife and Husband do hereby waive, release, and give up
any rights they may respectively have against the other for alimony, suppa , or maintenance. It
shall be from the execution of this Agreement the sole responsibility of eac of the respective
parties to sustain themselves without seeking any support from the other p y. All alimony to be
paid under this agreement shall terminate upon the recipient's remarriage 0 cohabitation with a
person of the opposite sex.
Wife's waiver of spousal support and alimony shall become effecti upon receipt of the
total of $25,000.00 in payments as described in section 12 of this agreemen .
15. INCOME TAX RETURNS. Husband and wife represent to e ch other that to the
best of their knowledge all federal, state, and local taxes required to paid wi h during the
marriage and during the periods covered by such tax returns have been paid. Husband and Wife
further represent that there are no tax deficiencies proposed or assessed agai st Husband and/or
Wife for such periods, and neither Husband nor Wife executed any waiver 0 the Statute of
limitations on the assessment or collection of any tax for such periods. If a y deficiency in
federal, state, or local income taxes is proposed, or any assessment of any su h tax is made
against the other party by reason of his or her having joined in the filing ofj int federal, state or
local income tax returns, Husband and Wife shall indemnify and hold harml ss the other against
and from any and all tax, interest, penalty, or expense relating from any such tax deficiency,
including reasonable counsel and accounting fees, and such tax, interest, and penalties or
expenses shall be paid solely and entirely by the responsible party as determi ed to be
attributable to that party on account of misrepresentation or failure to disclos relevant
information of income on the aforesaid joint returns.
.
.
16. WAIVER OR MODIFICATION TO BE IN WRITING. 0 modification or
wai ver of any of the terms hereof shall be valid unless in writing and sign d by both parties, and
no waiver of any breach hereof or default hereunder shall be deemed a wa ver of any subsequent
default of the same or similar nature.
17. MUTUAL COOPERATION. Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge, and deliver to he other party any and
all further instruments and/or documents that the other party may reasona y require for the
purpose of giving full force and effect to the provisions of this Agreement.
18. APPLICABLE LAW. The Agreement shall be construed in ccordance with the
laws of the Commonwealth of Pennsylvania which are in effect as of the d te of execution of this
Agreement.
19. INTEGRATION. This Agreement constitutes the entire unde standing ofthe
parties and supersedes any and all prior agreements or negotiations betwee them. There are no
representations or warranties other than those expressly set forth herein.
20. OTHER DOCUMENTATION. Wife and Husband covenan and agree that they
will forthwith execute any and all written instruments, assignments, release , satisfactions, deeds,
notes, or such other writings as may be necessary or desirable for the prope effectuation of this
Agreement.
21. NO WAIVER OF DEFAULT. This Agreement shall remain' full force and effect
unless and until terminated under and pursuant to the terms of this Agreem nt. The failure of
either party to insist upon strict performance of any of the provisions of this Agreement shall in
no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any
default or breach of any provision hereof by construed as a waiver of any su sequent default or
breach of the same or similar nature, not shall it be construed as a waiver or strict performance of
any other obligations herein.
22. SEVERABILITY. If any term, condition, clause, or provision fthis Agreement
shall be determined or declared to be void or invalid in law or otherwise, th only that term,
condition, clause, or provisions shall be stricken from this Agreement; and i all other respects,
this Agreement shall be valid and continue in full force, effect, and operatio . Likewise, the
failure of any party to meet his or her obligations under anyone or more oft e paragraphs herein,
with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter
the remaining obligations of the parties.
.
.
23. BREACH. If either party breaches any provisions of this agr ement, the other party
shall have the right, at his or her election, to sue for damages for such bre ch, or seek other
remedies or relief as may be available to him or her, and the party breachi g this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this agreement.
24. INFORMED AND VOLUNTARY EXECUTION. Each p y to this agreement
acknowledges that he or she is fully informed as to the facts relating to the subject matter of this
agreement, is entering into this agreement voluntarily, free from fraud, un ue influence, coercion
or duress of any kind, has given careful thought to the making of this agre ment, has carefully
read each provision of this agreement, and fully and completely understan s each provision of
this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hand and seals the day and
year first above written:
WITNESS:
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KAREN E. WILSON, Wife
Date: 3/?;;L( Os:-
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Hubert X. Gilroy, Esquire
'tN. Hanover St. (
Carlisle, Pa. 17013
(717) 243-4574
Attorney for Wife
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RONALD E. WILSON, II
Date: 1!IovvJ.. J J f ;}O{J)
-.
Adams, Esquire
6 S. Pitt St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Husband
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KAREN E. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 2005 - 1529 Civil Term
RONALD E. WILSON,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
l. A complaint in divorce under section 3301(c) of the Divorce Code was tiled on March 22, 200S.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the tiling 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. (also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date:
10(21105
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Karen E. Wilson, Plaintiff '--
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER &330I(c) AND &330I(d) OF THE DIVORCE CODE
I. I consent to entry of a final decree of divorce without notice.
2. t understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses
if ( 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 tiled 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. S4904 relating to unsworn falsification to authorities.
Date:
~ e 'W-\....J
Karen E. Wilson, Plaintiff
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KAREN E. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 2005 - 1529 Civil Term
RONALD E. WILSON,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 22, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the filing and service ofthe 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 corred. 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.
Date: (pICA 7 /o~-
~7)-1v~
Ron E. Wilson, Defendant
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE OECREE
UNDER 6330)(c) AND 6330)(d) OF THE DIVORCE CODE
I. 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
if! 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.e.S. ~4904 relating to unsworn falsification to authorities.
Date: G/)7/o~- R!~so~:~n1::
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KAREN E. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - LAW
RONALD E. WILSON, II,
Defendant
: NO. 2005 - 1529
: 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:
I. Ground for divorce: irretrievable breakdown under &3301(c) of the Divorce Code.
2. Date and manner of the service ofthe Complaint: Regular mail, Acceptance of Service
on March 29, 2005.
3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code:
By Plaintiff:
June 21,2005
By Defendant:
June 27,2005
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the
Prothonotary: June 29, 2005.
Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the
Prothonotary: June 23, 2005.
D," 1/7/0;
ectful:ZJ~
a Adams, Esquire
1. . No. 79465
M S. Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Defendant
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
PENNA.
STATE OF
Karen E. Wilson, Plaintiff
No.
No. 2005 - 1529 Civil Term
VERSUS
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Ronald E. Wilson, Defendant
DECREE IN
DIVORCE
fv~
Karen E. Wilson
/3
.:z~r, IT IS ORDERED AND
AND NOW,
DECREED THAT
, PLAINTIFF,
Ronald E. Wilson
AND
, 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; The property settlement agreement executed on March 22, 2005, and
Filed April 5, 2005 shall be incorporated but not mergt:d into this Decree.
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OURT: / .
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ROTHONOTARY .
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