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Home My WebLink About05-4298 () IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA William G. Sims, ) Civil Action - Law Plaintiff, ) ) CD -~ L(d-t(o ~ vs. ) No. ) Kristen A. Sims, ) Defendant, ) In Divorce a v.m. NOTICE TO DEFEND 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 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 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 Court House, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249--3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. , 278362-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA William G. Sims, ) Civil Action - Law Plaintiff, ) ) C,1r:( - ) No. oS ~ '1).'11 (e-r- vs. ) Kristen A. Sims, ) Defendant, ) In Divorce a v.m. COMPLAINT UNDER SECTION 3301(A) OR 3301(C) OR 3301(D) OF THE DIVORCE CODE COUNT 1 -- DIVORCE 1. Plaintiff is WILLIAM G. SIMS, a sui juris adult, who currently resides at 203 Wayne Street, Summerdale, Cumberland County, Pennsylvania. 2. Defendant is KRISTEN A. SIMS, a sui juris adult, who currently resides at 5440 Westbury Drive, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 18, 2001, in Marysvile, Perry County, Pennsylvania. 5. There have been no prior actions of divorce or annulment of marriage between the parties except the action represented by this Complaint. 6. The marriage is irretrievably broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. Plaintiff has been advised that counseling is available 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. 1467284 2 COUNT II -- EQUITABLE DISTRIBUTION -- SECTION 3502 10. The allegations of paragraphs 1 through 9 hereof are incorporated herein as fully as though set out at large. 11. The parties have been unable to determine and equitably dispose of their respective rights and interests in the marital property. 12. Plaintiff will, within 60 days after service of this Complaint upon the Defendant, cause to be filed an inventory and appraisement of all property owned or possessed at the time this Complaint is filed. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide, distribute and assign the marital property pursuant to the provisions of Section 3502 of the Divorce Code. Date: August 19, 2005 BARLEY SNYDER /~ / ------ " James . .. ams, Esquire 126 E. King Street Lancaster, PA 17602 (717) 299--5201 Attorney for Plaintiff 1467284 3 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. Section 4904, relating to unsworn falsification to authorities. ~;:S:~ 1467284 4 ~~?D ~rl '" ~ ~ ~ ~ t: '8 ~ G \"~ .-->. q. ~ ;:r .-1 ~ ~. ~~ 0.) :?J:-? r'"" 7.'J,t;~1 ~ -,,-,'\ 6("") ..-"\:J :---C\:"f"\ ~ '0 ~, cf! ~ r;- :;.::. ,~", '-" :2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA William G. Sims, ) Plaintiff, ) ) vs. ) ) Kristen A. Sims, ) Defendant, ) No. 05-4298 Civil In Divorce a v.m. ACCEPTANCE OF SERVICE I, Hubert X. Gilory, Esquire, hereby accept service of the Divorce Complaint. I certify that I am authorized to accept service on behalf of the Defendant, Kristen A. Sims. Date: C( -( 5- {j r BaYG;VO~ Hubert X. Gilroy 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 0 ....., !fl = c = s: c.n '""OtX.1 (I) :tl:n fnfr ...... ZT -0 ~Fii Zi.-" i@~~'.':' c.n ~6 <_. -0 =t=tj :PC Lei :JI: 9-0 >c:: ~ am :z: 'j;! =< 0 :n ..- -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM G. SIMS Plaintiff, CIVIL ACTION - LAW No. 05-4298 v. KRISTEN A. SIMS Defendant, IN DIVORCE a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code was filed on August 22, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both 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. WAIVER OF NOTICE OF INTENTION TO REODEST ENTRY OF A DIVORCE DECREE UNDER ~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 if I do not claim them before a divorce is granted. 3. 1 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904, relating to unsworn falsification to authorities. Date: 7-/'/--oCo wez~ 1638508 :_:-, .'n (~-:::-~. 'p:: <.:J ,..,', " . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM G. SIMS Plaintiff, CIVIL ACTION - LAW No. 05-4298 v. KRISTEN A. SIMS Defendant, IN DIVORCE a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code was filed on August 22, 2005. 4. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the filing and service of the Complaint. 5. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904, relating to unsworn falsification to authorities. Date:/-~O -(){p Lth-v,4. ~ Kristen A. Sims, Defendant 1663314-1 , '''-.) 0-': -',-'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM G. SIMS Plaintiff, CIVIL ACTION -- LAW No. 05-4298 v. KRISTEN A. SIMS Defendant, IN DIVORCE a v.m. PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw the Equitable Distribution count from the Complaint in Divorce filed in this matter on August 22, 2005. Respectfully submitted, BARLEY SNYDER BY:~ . Adams Court J.D. No. 02501 126 East King Street Lancaster, P A 17602 (717) 299-5201 Attorneys for Plaintiff 1638508 g ?; -04., nlfl' '-.1'."7: ?- (~ ~::~: ~C ~+~.:C~ :'P~ -;.;;- ~ ~ ~ ~ c;") ~ ~:!l ~ 8,~ =2::ft ~ %P. - "'-I ~ ~ C1' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM G. SIMS Plaintiff, CIVIL ACTION - LAW No. 05-4298 v. KRISTEN A. SIMS Defendant, IN DIVORCE a v.m. PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) or 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service as of September 13, 2005. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: July 14,2006; by Defendant: July 20,2006. 4. Related claims pending: There are no related claims pending in this matter. 5. Waiver signed by Plaintiff was filed on July 19,2006. Waiver signed by Defendant was filed on July 23, 2006. Dated: August 23, 2006 z:rOER By: .~ James R. Adams 126 E. King Street Lancaster, PA 17602 (717) 299--5201 1663314-1 () ,...., ~ = c: "'" ~ "" -oc6 ",.. ~::!l mr"l"' c:: z:~: G""> .-: --;7'1 N ::ge3 (1; U1 ()b r:: :::t -.:' ~(~; :l>'" t'):!J :::r. "'70 5:i~- - om - -\ z 55 :2 N N -< ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . :t +. OIe:+ *.:+:+::+ + '" + . . . . . . . . . . . . . . . . . . . . . . .. ",;to:f.:+:"; . ... . ... .. ... ... . . . .. .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. William G. Sims No. 4298 05 VERSUS Kristen A. Sims DECREE IN DIVORCE AND NOW, ~ , IT IS ORDERED AND 2,\ , 2006 DECREED THAT William G Sims , PLAINTIFF, AND Kristen A. Sims , 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 . ++++++,.,+:+:+++ ... + '+' + 't,,!, ~:+ ... ++:i:+ .. ,. Of '+' + .. +'f:+:f++++++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + Cf. +. i;+ f)(J ")0 krF: fp ;: rfi'- ~ U- .,4'frr't '7- I'f" 4,bJ . f"J "' . . ' n c'- F'b S ):/ "'" c::::> c;~_, () c.;'-, -n --I T li1 :T:! ,- :fL' , . l~; C0 o (~~: c,.) -'