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Home My WebLink About01-4278 . * 't- ~ ry:!.f, IOU 6 ~ P 7- ~ tewtl fP Jo-Ll-b ---- - PAMELA S.'WILSON, Plaintiff IN THE COURT OF COMM:ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. No. 01-4278 Civil Term ROBERT E. WILSON. JR.. CIVrr.. ACTION- IN DIVORCE Defendant 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 (X) 3301 D of the Divorce Code. (Check applicable code) 2. Date and manner of service of the complaint Certified-Restricted delivery-7/18/01 3. (Complete either paragraph (A) or (B) .) (A) Date of execution of the affidavit of consent required by Section 3301 (C) of the divorce code: By plaintiff ; by defendant (B) (1) Date of execution of the plaintiff's affidavit required by Section 3301 (D) of the Divorce Code: 7/11 /01 (2) Date of filing and service of the plaintiff's affidavit upon the respondent 7/18/01 NONE certified-restricte( 4. Related claims pending: 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: R/ln/nl-r.p~r;f;p~ m~;' . . (B) Date plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: Date defendant's Wavier of Notice in ~ 3301 (c) Divorce was filed with the Prothonotary: ) Plaintiff ) Defendant Prothon. -4 9 ------~--- ,.. D -n ; C/' -b +- ,. . " -~ '. Lh -<::. '-" J::, ~ ROBERT E. WILSON, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01- .If~7P Ci<.)~l~~ CIVIL ACTION-IN DIVORCE PAMELA S. WILSON, Plaintiff vs. NOTICE TO DEFEND AND CLAIM RIGIITS YOU HAVE BEEN against the claims set take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of 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 the divorce 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, Cumberland County Courthouse, Carlisle, PA. SUED IN COURT. If you wish to defend forth in the following pages, you must 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 IF YOU DO NOT HAVE TELEPHONE THE OFFICE GET LEGAL HELP. TAKE THIS PAPER TO YOUR LAWYER AT ONCE. A LAWYER OR CANNOT AFFORD ONE, GO TO OR SET FORTH BELOW TO FIND OUT WHERE YOU CAN Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PAMELA S. WILSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- ,-/-,)7f ~ /~ ROBERT E. WILSON, JR., Defendant CIVIL ACTION-LAW DIVORCE ACTION NO FAULT DIVORCE COMPLAINT 330 1 (D) AND NOW COMES the above-named Plaintiff, PAMELA S. WILSON, by Judith A. Calkin, Esquire and she seeks to obtain a Decree in Divorce from the above named Defendant upon the grounds hereinafter more fully set forth: 1. Plaintiff is PAMELA S. WILSON, who resides at 185 Sugar Maple Drive, Etters, York County, Pennsylvania. Her social number is 206-52-9161. 2. Defendant is ROBERT E. WILSON, JR., who resides at 476 Brook Circle, Mechanicsburg, Cumberland County, PA. His social security number is #187-44-9399. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing for this Complaint. 4. The Plaintiff and Defendant were married on May 23, 1987 in Cumberland County, Pennsylvania. 5. There has been no previous action filed to the above- captioned number and term. 6. The Defendant is not a member of the Armed Forces. 7. The marriage is irretrievably broken, and the parties have lived separate and apart for a period in excess of two (2) years. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handled down by the Court. WHEREFORE, Plaintiff requests the court to enter a decree of divorce under 3301(d) of the Pennsylvania Divorce Code. Respectfully submitted: ith A. Calkin, Esquire torney for Plaintiff 2201 North Second Street Harrisburg, PA 17110 (717) 238-2312 PAMELA S. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. ROBERT E. WILSON, JR., Defendant CIVIL ACTION-LAW DIVORCE ACTION NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this Affidavit, you must file a counterclaim within twenty (20) days after this affidavit has been served on you or the allegations will be admitted. AFFIDAVIT OF PLAINTIFF UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in 1997, and have continued to live separate and apart. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights, concerning alimony, division of marital property, attorney's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. 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: 7-11-o I Cfi1mJ11 D/ ~ Pamela S. Wllson AFFIDA VIT I verify that the statements made in this 3301 (D) Divorce Complaint 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: Lfa/lxdaJJ ~ Pamela S. Wilson Sworn and Subscribed tf.v before me thisl~ day of ~'vL 1'1 ' 2001. ~~~ Notary Public NOTARIAL SEAL ElLEN ROSENBLOOM, Notary Public City of Harrisburg, Dauphin County Mv Commission Ex ires Ma 8, 2003 CERTIFICATE OF SERVICE I, Judith A. Calkin, do hereby certify that a true and correct copy of the within 3301 (D) Divorce Complaint was mailed at Harrisburg, PA., certified-restricted delivery, postage pre-paid to the following person: Robert E. Wilson, Jr. 476 Brook Circle Mechancisburg, PA 17055 Date: 7 j;;fl ~tlul PAMELA S. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-4278 Civil Term ROBERT E. WILSON, JR. Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE TO ROBERT E. WILSON, JR., Defendant You have failed affidavit to after August enter a final have been sued in an action for divorce. You to answer the complaint or file a counter the plaintiff's affidavit. Therefore, on or 26, 2001, the plaintiff can request the court to decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. UNLESS YOU HAVE ALREADY FILED WITH THE COURT A WRITTEN CLAIM FOR ECONOMIC RELIEF, YOU MUST DO SO BY THE ABOVE DATE OR THE COURT MAY GRANT THE DIVORCE AND YOU WILL LOSE FOREVER THE RIGHT TO ASK FOR ECONOMIC RELIEF. THE FILING OF THE FORM COUNTER-AFFIDAVIT ALONE DOES NOT PROTECT YOUR ECONOMIC CLAIMS. YOU YOU' DO NOT TELEPHONE THE LEGAL HELP. SHOULD HAVE OFFICE TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF A LAWYER OR CANNOT AFFORD ONE, GO TO OR SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subj ect to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: Robert E. Wilson, Jr. NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter affidavit. o c ,...-. c-u C}\ ~ -T- -r~ V\ - , ~ V\ ):,. ~ ~,.., <.. ~ ~ PAMELA S. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA vs. NO. 01-4278 Civil Term ROBERT E. WILSON, JR. Defendant IN DIVORCE At'}'WA VIT OF SERVICE I, Judith A. Calkin, Esquire, deposes and says: 1. That she is an adult individual residing in Dauphin County, Pennsylvania. 2. That on July 17, 2001 she sent by certified- restricted mail, return receipt requesting from Harrisburg, Pennsylvania (No. 7099 3220 0009 4715 4619) of the 3301(d) Divorce Compaint in the above captioned case to: Robert Wilson 476 Brook Circle Mechanicsburg, PA 17055 3. That on July 18, 2001, Robert Wilson signed the receipt (No. 7099 3220 0009 4715 4619 ) which is attached to this affidavit. Calkin, Esquire for Plaintiff 2201 N. Second Street Harrisburg, PA 17101 (717) 238-2312 .' . - U.S. postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) It' It" Cl f'- ttECMAMICS8IJl6 pt\ 17055 postage $ to.57 IT" M' ..D .:r , U"} M f'- .:r Certified Fee IT" Return Receipt Fee 0' (Endorsement Required) o Restricted Delivery Fee o (Endorsement Required) Cl Total Postage & Fees ru ru lTl $ .1.31 Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: '. . X 1./.-:.L4.,-, D. Is elivery address different from item 1? If YES, enter delivery address below: o Agent o Addressee DYes o No Ii 0 h~r -f ')v / I fU-./ ,-/7 t {j,o;; (irK/' Ih t tit J:l ,,/t' t S IJ u t.-g I f fA... /70SS 3. Service Type )CiPertified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Transfer from service label) PS Form 3811, March 2001 70 II? 3;).-,J; 0 tJOtJ if '-/7 / f ~1,19 Domestic Return Receipt 'l p "'~ d) v,,.. U- 102595-01-M-1424 Q C/' ~ + -t:. i.J'\ .b.. ~ ~ ' ~ V\ (, r ~ ...~ 5; " "'"'I f .1 ... PAMELA S. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA vs. NO. 01-4278 Civil Term ROBERT E. WILSON, JR. Defendant IN DIVORCE At'}'IDA VIT OF SERVICE I, Judith A. Calkin, Esquire, deposes and says: 1. That she is an adult individual residing in Dauphin County, Pennsylvania. 2. That on August 7, 2001 she sent by certified- restricted mail, return receipt requesting from Harrisburg, Pennsylvania (No. 7099 3220 0009 4715 4640) of the Notice of Intention to Request Entry of a Divorce Compaint in the above captioned case to: Robert Wilson 476 Brook Circle Mechanicsburg, PA 17055 3. That on August 10, 2001, Robert Wilson signed the receipt (No. 7099 3220 0009 4715 4640 ) which is attached to this affidavit. /-~ Calkin, Esquire for Plaintiff 2201 N. Second Street Harrisburg, PA 17101 (717) 238-2312 ... ':'" U 5 postal Service CE'RTIF.IED ~A'L .RNE~E~~r:nce Covel age Provided) (Domestic Mall Only, 0 n Oi ::T ....J] ::T I1EctIIIIIlCSd6 " 17055 ".34 postage $ .2.18 Lf1 .-'I f'- ::T Certified Fee Return Receipt Fee ~ (Endorseme[\t Required) o Restricted Delivery Fee o (E[\dorsement ReqUIred) 11-:1 .... o Total postage & Fees $ _.7'" ru r; b completed by mailer) ~ Name (P17f~ i2~e~:r (_~,_.r;;.LLs..trL-....-.._.--._.._...._.__....- si;eei:;4pi.-NO';;O; pcrijoj,~. /) L L I. vi./.-- y c~._,.___..!.:;.l.P.m'&"'--' ,.1 --, ... '''y''''-''T1;J-' ciiy:si"i;:z;p+ 4 e ~h Il Wi'" J .h. _ t-- 4.-- [J'" [J'" o ...... :.. SENDER: COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: R 0 bt- 14- Lv i f g 0 vJ \{1(' Grook c".I/~Ie.- (nt-c,nll,v1 C/ f h v~ \ po..! 17 oS 5 2. Article Number." '..,.' .., b ~, 3 '"'\, 1"'1 (Tran~ service label) I I d' --v PS Form 3811, March 2001 "" . I delivery address different from item 1 . If YES, enter delivery address below' '.;.~ . .,;4 ,Ie,.,. ,.:.~~.tr 4. Restri.cted Delivery? (Extra Fee) DYes l../'f~ l~ Domestic Return Receipt 102595-01-M-1424 ------------ 0 - -n 1 -1 -1" V\ . , ...p::.. ,- ' V'> ~ ..,