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HomeMy WebLinkAbout05-3922 HAROLD S. IRWIN, III, I!SQUIRE ATTORNey' ID NO. 29920 84 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-8090 ATTORNI!Y FOR PLAINTIFF HUTHeR M. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLUS OF = CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION. LAW : NO. 2005 - -?9:1)..CIVIL TeRM . KIRK A. WILLIAMS, Defendant . . : IN DIVORCE NOTICE 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 fail to do so, the case may proceed without you and a decree in 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 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 17013, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 HEATHER M. WILLIAMS, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBULAND COUNTY, PI!NNSYLVANIA v. = CIVIL ACTION. LAW = NO. 2005 .]9 X)."CIVIL TI!RM , KIRK A. WILLIAMS, Defendant = IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301~ OF THE DIVORCE CODE NOW, comes the plaintiff, by his attomey, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is HEATHER M, WILLIAMS, an adult individual residing at 4404 Carlisle Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The defendant is KIRK A, WILLIAMS, an adult individual residing at 523 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce, 4, The parties were married on November 5,1994 in Gardners, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c}, the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties, I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S, Section 4904 relating to unsworn falsification to authorities, August1,2005 ~l ~~lWl U )~LUC\MvV HEATHER M. WILLIAMS, Plaintiff HARO S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 10 No. 29920 HEATHER M. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. I CIVIL ACTION. LAW I NO. 2005 . ~;)';;l." CIVIL TERM KIRK A. WILLIAMS, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand thatthe court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. August 1, 2005 ~ \ 0 ~lwl ");\)iAhwvD&J HEATHER M. WILLIAMS, Plaintiff (J ~ - ~ ~ ..0 \J - -c ~ G'- ~ ... 0- ~ ..0 6..J ~ ~ ~'::-~?, () !J ~;;;;.) -r1 E J1e'r:- '; \~~ < l';" ~',\ ('n .....,.~ 0 HDTHI!R M. WILLIAMS, PI.lntlff I IN THI! COURT OF COMMON PLDS OF = CUM.I!RLAND COUNTY, PI!NNSYLVANIA v. = CIVIL ACTION. LAW = NO. 2005. 39ZZ.CIVIL TI!RM KIRK A. WILLIAMS, Defend.nt = IN DIVORCI! ACCEPTANCE OF SERVICE I, Kirk A. WIlliams, defendant in this divorce action, hereby certify that I received a copy of the complaint in divorce on or about August 1, 2005 by personal service, I verify that the statements made in this acceptance of service 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. August 1, 2005 /Z Ul)~ KIRK A. WILLIAMS __, ',," ,e . ,. o co" N = = '''' () -n '..... ,~ rtl~ -'...- - ;)\:::;- ::"" C-:~. G-} , r'-" I..D ....) c - HEATHER M. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2005 - 3922 CIVIL TERM KIRK A. WILLIAMS, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about August 1, 2005. Service of the complaint was made by certified mail on August 2, 2005 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce, I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C. S. Section 4904 relating to unsworn falsification to authorities. November .3., 2005 III HEATHER M. WILLIAMS ~ "'0 i~;" l:i.":l', ';" (J) ....> = ~ -;e C::l L 1~:2.i.-- ,< ,:"c. yc:.'. '/ ~ -" \ -' Q, ~::l ::-L""-' P"\r-~ -(1~< ,:.;., ,.( '...f.() ~_~~~.~S ~~;-n lij :"" Y' :;:,J: - C? ;(:" 0' HEATHER M. WILLIAMS, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION - LAW : NO. 2005 - 3922 CIVIL TERM KIRK A. WILLIAMS, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about August 1, 2005. Service of the complaint was made by certified mail on August 2, 2005 (see acceptance of service previously filed). 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S, Section 4904 relating to unsworn falsification to authorities. November I ,2005 ~l, ).QJo IRK A. W L1AMS r-> "'" ~ - ...\,,- S?: , -' \,;:-,':;. '::" :.< ~ .-\ -c....,..-\ \~nE -:9,"C' ;-:'?\'~> .,;'- -1.~ :~:_r?\ ~ ::w: 9 ':,'~t ,:..-.. ::.< .r=- <1" HEATHER M. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2005 - 3922 CIVIL TERM KIRK A. WILLIAMS, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ~ 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 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. Section 4904 relating to unsworn falsification to authorities. November J, 2005 l/ilflNW/ fJZ i{4t~ HEATHER A. WILLIAMS o>:11Y rn\~ -7 -, ~> ~ (J~ 2'~l ~.\~ "2 o c: "~~.. <-' """ CJ cy\ ...,. cS ...:: I -l -r:~ ~i~ "9 ;<:' CY' 9" ~-n rne. -rJ\~, ~9>'\\ ".::\l,' --C:"\< '~~.;~.Y:\ " , ~..:::\ :y ;J :..r..:: HEATHER M. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2005 - 3922 CIVIL TERM KIRK A. WILLIAMS, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTIO!l 3301~ OF THE DIVOR~E 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. Section 4904 relating to unsworn falsification to authorities. November 2, 2005 f ~'A~ KfRK A. WILLIAMS >--, 0 = "", ." C~ Z :;:J ~ c) f-ii -< p' -.~.r Q~ ~::.:J ~, -, , (d :l:'.-.. -.',-', .....<.-. """ c"') 1T1 (:.:~J 5f~ -') "' =< -, en HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR DEFENDANT HEATHER M. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2005 - 3922 CIVIL TERM KIRK A. WILLIAMS, Defendant : IN 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: 1, Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2, Date and manner of service of the complaint: On or about July 1, 2005, defendant was served with a copy of the divorce complaint by certified mail. 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: November 2, 2005 By the defendant: November 2, 2005 (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 5, Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301 (c) divorce was filed with the Prothonotary: On or about November ., , 2005 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: On or about November 2, 2005 HAROLD S. IRWIN, III Attorney for Plaintiff November 2. 2005 (') ...., 0 = f: ,:;:"~ -n "'" <) u Z :j1 F'-: c' 0 rl1ffl " , ~ "0 (\I (0 .. I c: -' ,.-' , ~ ~? '.---:-..::: . j.;'" , ~ (,::~ (' "? ~ OJ; e, 9 ?2 ri'< c: ;;:' :~ r :n -l '< ++ ;to :'::f. +:.: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~:.: Of Of Of +:+:+ :+:+:+:+:+:+:+:+:+:+:+:+:+++++:++:+++:+++:f.+~ . . . . . :++++:f.:f.:++ :+:++:+:+:+:+ +:+:+:+: . +:f.:+:f.:+:+:+:+:+++:+::+: IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. HEATHER M. WILLIAMS, No. SId;;" 2005 - ,~ CIVIL TERM Plaintiff VERSUS KIRK A. WILLIAMS. Defendant DECREE IN DIVORCE AND NOW, 'to ..Loo"'- , IT IS ORDERED AND Novc.-4- DECREED THAT Heather M. Williams AND Kirk A. Williams ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, . J, . . . . . , . . . . . . . . , . , . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . , . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; NONE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT By TH E eouAl - . ++++++:+:++++++:+;to;tO+~+ ~:++++++++ +++++ +:++++++ .. PROTHONOTARY +++ +:++ ++:+:~+.+++ + +:+:+++ . ~ ~ /fJ: 1'1/ ~fI; 50 AI -J/ ~ ~ ~ ~4~./Yl sv' /In! .;