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HomeMy WebLinkAbout05-2158 ~ : In The Court of Common Pleas v. : Cumberland County, Pennsylvania &J : No. 2005 -. d-I:;g-- .. Shari Lynn Wolfgang-Wright, Plaintiff : Civil Action - Law Michael Troy Wright, Defendant : In Divorce NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the ca e may proceed without you and a decree of annulment may be entered against you by the court. judgment may also be entered against you for any other claim or relief requested in these pape s by the plaintiff. You may lose money or property or other rights important to you, including cust dy or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marri ge, you may request marriage counseling. A list of marriage counselors is available in the Office f the Prothonotary at 1 Court House Square, Carlisle, PA 17013 (717) 240-6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANT D, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THI OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABL TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGA SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 ]) c{.4~ T f:.~ David F. Rice, Esq. Attorney I. D. No. 29106 Attorney for Plaintiff RD # 1 Box 872, Blain, P A 170 6 (717) 536-3685 - : In The Court of Common Pleas Shari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 - CV DV : Civil Action- Law Michael Troy Wright, Defendant : In Divorce COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE I. Plaintiff is Shari Lynn Wolfgang-Wright, who currently resides at 58 Regency Woo s North, Carlisle, Pennsylvania, 17013, County of Cumberland, since mid-year of 2002. 2. Defendant is Michael Troy Wright, who currently resides at SOt Burgners Road, C lisle, Pennsylvania, 17013, County of Cumberland, since January IS, 2005. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at last six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 11, 1998, in Hummelsto Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have e right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. I verifY that the statements made in this Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relatin unsworn falsification to authorities. Date: P-e.bi"VtitfL77 2DO!J I ) David F. Rice, Esq., Attorney for Plaint ~ ~ , ~ IAj 'vJ ~ '.... ~ CA ~ '\ ~ ~ " t 1J\.~ \ \ (p. \ ~ iA ~ \, b\j " ~ ~ t o ~ ~. -'f)i,S:' fT:{T, -;7'-""- "c__' -,;,- [ 0~;'-' ~ y~<' 7:':\...:' -,,:Cj :>"'C:. -;.-'" ~1 -< ....' ~ ::0 7J f'..:l 0" - ~ :r;<" ~ - - ~ ~....... rt'l~ -:srm Q.~ ,,,,,._ -"I /':::'}::D ':'7("") Or~ :~,~l (" :5!. <J\ -' : In The Court of Common Pleas S ari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 - 02158 CIVIL : Civil Action - Law ichael Troy Wright, Defendant : In Divorce ACCEPTANCE OF SERVICE OF ORIGINAL PROCESS PURSUANT TO CIVIL PROCEDURE RULE 1930.4(d) I, MICHAEL TROY WRIGHT, Defendant in the above-captioned divorce action, do hereby CEPT SERVICE of the I) NOTICE TO DEFEND AND CLAIM RIGHTS, and 2) COMPLAINT - " r Os: ?/L-/v:;.~ l- Oa e ? MI DER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE, in the above-captioned rce action. Mailing Address: 7738 Avondale Terrace (updated) Harrisburg, PA 17112 o r_' = = c..n o -" ---l ..,- -,--"'" trlr-_-: -n rT'. <'le. ., J '-/(,) :l:;~J I'i-. :.:.:: :::;:e, -< , 0) -0 -',' -"." (-;? Cr (.,) - : In The Court of Common Pleas Shari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 - 02158 CIVIL : Civil Action-Law Michael Troy Wright, Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 26, 2005. 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. 1 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. Section 4904 relating to unsworn falsification to authorities. Date: 10//1/05,- , , f2. ~V'? /~ -;.J;d SHARI L YNN WOLFOO -WRIGHT ,..1"LAINTIFF o s:;. ..., ,= = <.r' o ('..~ --i -0 -."" -"- is; o -n --l :J: -n n1--- .~tD ~.~j 'l.y' ('-1 C) ""'''''T', !:5~~ ~r" ["C' g' ~;:1 :< N o - : In The Court of Common Pleas Shari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 - 02158 CIVIL : Civil Action---Law Michael Troy Wright, Defendant : In Divorce AFFIDA VIr OF CONSENT I. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 26, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date offijing 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. Section 4904 relating to unsworn falsification to authorities. Date: III /(1. 05 . ~ MICHAEL TROY WRIGHT, DEFE ------ ,--- C'> ,= ....' = = CJ1 Cl :"-') :..., ~ ", ". -0 :3: o -n ~"n nl~. "'T'\"_, ~-,";y ,-) ,-., '~;J ~< <-~Gl -.-)fl L, ~ '< N o- N C> : In The Court of Common Pleas Shari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 - 02158 CIVIL : Civil Action - Law o c ,..., = = c.n o \.-) -I Michael Troy Wright, Defendant : In Divorce WANER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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 i[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. Section 4904 relating to unsworn falsification to authorities. Date: if) / /1)- oS ~-...-:~ ----- MICHAEL TROY WRIGHT, -() o -n ....; :1:-r\ P1e ~'qe; ;.:~.; (J..) ,J~: ::] ~~8 5; :< ...:... t'-> N Cl : In The Court of Common Pleas Shari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 -02158 CIVIL : Civil Action - Law Michael Troy Wright, Defendant : In Divorce 0 ...., <:''::::J 0 C L:;..""") ... c...fl 0 ..... C) .. nl 2) -j \.- rn c-;- -.;; , <:~ -'1 C) f'--' ::::) r-il --i .,.> N :'.:.:J a -< WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 ifI 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 veriJy 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. Section 4904 relating to unsworn falsification to authorities. Date: /.0/ /1 /0';- ( f a- ~ ~ -tr~~ SHARI LYNN OLFGA - HT , PL~TIFF : In The Court of Common Pleas Shari Lynn Wolfgang-Wright, Plaintiff : Cumberland County, Pennsylvania v. : No. 2005 - 02158 CIVIL : Civil Action-Law Michael Troy Wright, Defendant : In Divorce PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry ofa divorce decree: 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint pursuant to Civil Procedure Rule 1930.4( d) on May 2, 2005, and filed with the Prothonotary an executed Acceptance of Service document evidencing such service on said date. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: October 11, 2005 By Defendant: October 10.2005 4. Related claims pending: NONE 5. Date Plaintiff's Waiver of Notice of Intention To Request Entry of a Divorce Decree was filed with the Prothonotary: October 11, 2005. Date Defendant's Waiver of Notice ofIntention To Request Entry of a Divorce Decree was filed with the Prothonotary: October 11,2005. ~~F~ David F. Rice, Attorney for Plaintiff 'l'+ it::+.:+.:+.:+.:+.:+.:+.:+. Of:+.:+. :+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . :f.:f.:+.:+.:+. :+. :+.:+:+.:f.:+:+. :+.:+. :+:+. :+.:+.:+. :+':+':+':+':+':+':+':+:+':+':+':+:+':+':+':+:+':+':+':+'+Of:+':+.:+.:+. :+.:+.:+.++:+.++ . . . + . . . + IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Shari Lynn Wolfgang-Wright . . . . . . . . . . . . . . + . + . . . . + . + . + . . . . + . + . . + . . . . . + . . . . + . + . + . + . + . . + . . . . + . . + . + + + + . . . . + + + . . + + . . . . + . + . + + . . . :+. :+. :+. :+. :+. + + + :+. :+. :+. + + + :+. + + + + :+. + + :+. :+. + ++ STATE OF PENNA. Plaintiff NO.2005-2158 Civil VERSUS Michael Troy Wright Defendant DECREE IN DIVORCE 1J~( at>{ ..::r ).."5 0 I' IY1 ;; , IT IS ORDERED AND + + + + + . + . + + + . + . . + . AND NOW, DECREED THAT Shari Lynn Wolfgang-Wright , PLAINTIFF, Michael Troy Wright 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 ATTEST: PROTHONOTARY +++'+':+.:+.:+.:+. '" Of "':+. + '+' :+. Of':+':+':+. 'f.:+ Of' Of :+:+.+++:+.:+. :+'+:+''1''1''1''1':+':+''1':+':+':+'+ :+. J. (~ 5/; Y' ~~7 ,;t?? % ~1 ~u.. .-Sr;? r 11 Jfci ~ ~ 4th:; P?J;;O' (' '/1 , .