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HomeMy WebLinkAbout05-6213 . . SHARI WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE RODERICK WILLIAMS, SR. Defendant : NO, 05- b.J.L3 CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set orth in the following pages, you must take prompt action, You are warned that if you fail to 0 so, the case may proceed without you and a decree of divorce or annulment may be entered ag inst you by the court. A judgment may also be entered against you for any other claim or reli f requested in these papers by the plaintiff. You may lose mOl1ey or property or other rights im rtant to you, including custody or visitation of your children, j When the ground for the divorce is indignities or irretrievable breakdown if the marriage, you may request marriage counseling, A list of marriage counselors is available i~ the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. I I IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PRJPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT lIS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. ) I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORT BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIN ALA WYER. IF YOU CANNOT AFFORD TO HIRE A LA WYER, THIS OFFICE M Y BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO EE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law t comply with the Americans with Disabilities Act of 1990, For information about accessible cilities and reasonable accommodations available to disabled individuals having business b fore the court, please contact our office. All arrangements must be made at least 72 hours prio~ to any hearing or business before the court, You must attend the scheduled conference or hearipg. I SHARI WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE RODERICK WILLIAMS, SR. Defendant : NO. 05- (.,.;)./3 CIVIL iTERM DIVORCE COMPLAINT The plaintiff, Shari Williams, by her attorneys, the Family Law Clinic, setl forth the following cause of action in divorce: I I. Plaintiff is Shari Williams, who currently resides at 118 Yz North East Str et, Carlisle, Cumberland County, Pennsylvania 17013 since November 7, 2005. 2. Defendant is Roderick Williams, Sf., who currently resides at 317 North est Street, Carlisle, Cumberland County, Pennsylvania 17013, since May 2003. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least s x months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 14, 1988 at Carlisle, Cumb rland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since May 1,2001. 6. There have been no prior actions for divorce or for annulment between t e parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff ay have the right to request that the court require the parties to participate in counseli g. . . , WHEREFORE, Plaintiff requests the court to enter a decree of divorce. / ~~ ," /~~ Bur ess Bradshaw Certified Legal Intern Robert I . I Thoma . Place I Anne MacDonald-Fo Lucy Johnston-Walsh Supervising Attorney FAMILY LAW CL IC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 . : (;/"/ -'((i[~ C . . , VERIFICATION I verify that the statements made in the foregoing complaint are true and corre~t, to the best of my knowledge, information and belief. I understand making any false ~tatement would subject me to the penalties of 18 Pa.C.S. 94904, relating to unsworn fal$ification to authorities. . Date )~ ,]- L~.j , " . 1/ / PlaintifLM/fA~' .~. (cJ~ Shari Williams I I I i I I I ! I I I I I I , I I I I ~ u c! ~. - (. ) -,1 C-:" ':.1 :~j 1-,1 r,_ (..-' .~, .-, ,'. 1"" , ," I': ...-~, . (.... SHARI WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE RODERICK WILLIAMS, SR. Defendant : NO. 05- 1.,.;<J..3 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Shari Williams, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma paup~ris, certifies that we believe the party is unable to pay the costs and that we are providing free lie gal service to ~~. i i I I I ~~ C:A~~ Burgess Bradshaw Certified Legal Intern I I R~tif~~~ k: THOMAS M. PLACE I ANNE MACDONALD-FOk LUCY JOHNSTON-WAL~H Supervising Attorneys I Respectfully submitted, Date I~ lv, I oJ: . F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 ,_f '.:) 1 t'- "-. , I ~I .- SHARI WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE RODERICK WILLIAMS, SR. Defendant : NO. 05- [,'J(3 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on May I, 200 I, and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. 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. 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. 94904, relating to unsworn falsification to authorities. Date/..21-{'.5~ ~(- ~ /.1) / r,.-. ." . ru<- . U.ltczd>1()J Shari Williams Plaintiff ':..) Shari Williams, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION-LAW DIVORCE Roderick Williams, Sr., Defendant NO. 05 - 6213 CIVIL TERM CERTIFICATE OF SERVICE I, Rene M. Gornall, Certified Legal Intern, hereby certify that the Family Law Clinic served a true and correct copy of the Divorce Complaint on Mr. Roderick Williams, Sr., residing at 317 North West Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Roderick Williams, Sr., on the 14th day of December, 2005, as evidenced by the attached green card. ne Gorrt: Certified Legal Inte --I /1'" C/l ,~.L.{.' L~~d'i' (L'CY l..-. . Lucy J4st~-Walsh, Esq. Supervismg Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 , SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse $0 that we can return the card to you. . Attach this card to the back. of the mailpiece, or on the front if space permits. A. Signature (' (~\.. 0 Agent y'" 0 Addressee Q. Date i livery " / I D. Is delivery address differnnt from item 1? Yes If YES. enter delivery address below: 0 No x 1. Article Addressed to; ~o(Lt~j( UJ~t1-c{vYW 3 17 '17 My! ji/~ SZ;J.d' f!.~de ( /"-'9/7c/3 3. Service Type ;a Certified Mail 0 Express Mall o Registered ~ Heturn Receipt for Merchandise o Insured Mall 0 G.O.D. 4. Restricted Delivery? (Extra Fee) J(Yes 7005 0390 0003 2633 0137 2. Article Number (Transfer from service labelj PS Form 3811, February 2004 Domestic Return Receipt 102595-Q2-M,,'540 "'," " Ms. Shari Williams, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Mr. Roderick Williams, Sr., Defendant : NO. 05-6213 CIVIL TERM DEFENDANT'S COUNTE -AFFIDAVIT UNDER OF THE IVORCE CODE I. Check either (a) or (b): (~( (a) I do not oppose the entry of a divorce decree. () i (b) 1 oppose the entry ofa divorce decree because (Check (i), (ii) or both): (i) The parties to this action have ~t lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably ~roken. I () () 2. Check either (a) or (b): (~ (a) 1 do not wish to make any claims for economic relief. I understand that 1 may lose rights concerning alimony, division ~f property, lawyer's fees or expenses if I do not claim them before a divorce is grante~. () (b) 1 wish to claim economic reliefwh~ch may include alimony, division of property, lawyer's fees or expenses or other impfrtant rights. 1 understand that in addition to checking (b) above, 1 must also file all of my economic claims with the prothonotary in writing and I serve them on the other party. If I fail to do so before the date set forth on the Notice of Interltion to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made i this counter-affidavit are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities Date A/?-, '3 k,c I I c:- ;'~:' C} ;".'. ~_.) .,----- SHARI WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-6213 CIVIL TERM RODERICK WILLIAMS, SR., Defendant : CIVIL ACTION - LAW : 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 ~ 330l(d) of the Divorce Code. 2. Date and manner of service ofthe complaint: service bv U.S. mail registered, restricted delivery complete on December 14, 2005. 3. Date of execution ofthe affidavit required by 9 3301(d) ofthe Divorce Code: December 8, 2005: 4. Date of filing ofthe plaintiffs affidavit: December 13,2005: 5. Date of service of the plaintiffs affidavit upon the respondent: December 14, 2005. 6. Related claims pending: None. 7. Date and manner of service of the Notice ofIntention to Request Entry of Divorce Decree, a copy of which is attached: Service hv First Class mail on Februarv 24, 2006. Date 1-2--1-D ~ yYL/Yc-~ Robert . ains, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire William G. Martin, Esquire Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 ,\' '..' Ms. Shari Williams, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE Mr. Roderick Williams, Sr., Defendant : NO. 05 - 6213 CIVIL TERM CERTIFICATE OF SERVICE I, Jill Hammill, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet on Roderick Williams, Sr, residing at, 317 North West Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, first class, postage prepaid, on April 21, 2006. ('.~ ~ ~~. <, ," '-:. '.. "r" . \ V\../ '- ' ~iIl)Hammill - C'rufied I'gol '""m & ~~1':n~~~ . Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 ....,. Ms. Shari Williams, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v. Mr. Roderick Williams, Sr., Defendant : CIVIL ACTION - LAW : DIVORCE : NO: 05-6213 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 9 330 1 (d) affidavit. Therefore, on or after March 16, 2006, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer w*our signature notarized or verified or a counter-affidavit by the above date, the court 'ra\ lnter a final decree in divorce. A counter-affidavit which you may file with the prothonotary ofJllll'court is attached to this notice. -(" Unless you have already filed with the court a written claim for econolJlll'\elief, you must do so by the above date or the court may grant the divorce and you willl\;~ forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL 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 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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 Indrviduals 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. Yau rl1ust attend the scheduled conference or hearing. Ms. Shari Williams, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Mr. Roderick Williams, Sr., Defendant : NO. 05-6213 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER !l3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ( ) (a) 1 do not oppose the entry of a divorce decree. () (b) I oppose the entry ofa divorce decree because (Check (i), (ii) or both): ( ) (i) The parties to this action have not lived separate an1':lart for a period of at least two years. _ ( ) (ii) The marriage is not irretrievably broken. r- m 2. Check either (a) or (b): ( ) (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. 1 understand that in addition to checking (b) above, 1 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 counter-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. D~lt;: lVII', Roderick '\/V-ilJE1H1S, Sf, .') ~,,,,". l ~ ~ +'+':+.+++.+++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ',' 'f 4: +++++:f++ +++++'+'++'f.+~ . ++++:f++++++++:f +'+'++'f.+++'+'+++'+++'++++'++'++'++'++'~ . . . . . . . . . . . . . . . . . . . . . . . . . .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAiNS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE STATE OF ,SHART WTT.T,TAM's , Plaintiff VERSUS PODfPIC~ ~ILTTAM~ Defendant . . . . . . . . . . AND NOW, , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++. +. +. +. +. +. + + + + DECREED THAT AND PEN NA. No. 6213 2005 SR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + +. 'to; +. +. +. + +. +. +. +.+' DECREE IN DIVORCE 1",..,'1 .2c. , ;zoo '-, IT is ORDERED AND SHART WTLrTAMS , PLAINTIFF, RODERICK WILLIAMS, SR. , DEFENDANT, YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT NONE BY THE COURT: /l ++.++. +++++++.+++.++.++++++.+++++++++++++++++++.++++++ +:-1'++:-1' J. ;/_ -' ~7 ,#7'.'77""./ /07..7' / -)::;T77 ~J 17 . r (// ') ?' , .7 f!';rT -, /..li/i} - I-??J ? " . ~ ' ";'.7 !..:t )-' . , "),/'L.C"'?