Loading...
HomeMy WebLinkAbout05-6217SUZANNE K. WOODALL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005- ? ) t 7 ?f Lc ROBERT L. WOODALL, JR., : CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims et forth in the following pages, you must take action within (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You re warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. i 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 717-249-3166 SUZANNE K. WOODALL, Plaintiff VS. ROBERT L. WOODALL, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005 - r?Z?7 e"-_p -r..., : CIVIL ACTION LAW IN DIVORCE COMPLAINT Plaintiff, Suzanne K. Woodall, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, Suzanne K. Woodall, is an adult individual residing at 327 West Ridge Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Robert L. Woodall, Jr., is an adult individual residing at 21 Wet Mulberry Hill Road, Carlisle, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married in Cumberland County Pennsylvania on February 25, 1994. 4 Both Plaintiff and Defendant have resided continuously in the Commonwealth of Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of this action. 5 There have been no prior actions of divorce or for annulment between the parties. 6 The marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing her from the Defendant. BROUJOS & GILROY, P.C. By Hubert X. Gilro , squi Attorney for aintiff Broujos & ilroy, P.C. 4 North anover Street Carlisle, PA 17013 717-243-4574 VERIFICATION I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. .S ZANNE K. WO DAL i ?. ?' `??,--? r--?? ?... r_, _, ?3 ? -____ y ? - r? ? ? c", ra _. ? ?; ?, -. `? Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE K. WOODALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005- 6217 ROBERT L. WOODALL, JR., CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) 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 NovemberVI , 2005 and have continued to live separate and apart for a period of at least two 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 subj ect to the penalties of 18 Pa. C. S.A. Section 4904 relating to unsworn falsification to authorities. Date: April? D , 2008 Plaintif F . :: Oni I C F:\FILES\C1ients\12839 Woodall, S\12839.1.Aflidav.scr divorcr.wpd Created: 9/20/04 0:06PM Revised: 6/9/08 10:50AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNEK. WOODALL, Plaintiff V. ROBERT L. WOODALL, JR., Defendant IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA NO. 2005-6217 : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Robert L. Woodall, Jr., by certified mail at the Defendant's address at 21 West Mulberry Hill Road, Carlisle, Pennsylvania on December 3, 2005. A copy of the Certified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. DA E Hubert X. Gilroy Esquire Attorney for P ntiff Martson De dorff Williams Otto Gilroy & Faller 10 East High Street Carlisle, PA 17013 (717) 243-3341 Sworn and subscribed before me this 16 day of3,, 2008 COAMUONWEALTH OF PENNSYLVANIA Notarial Seal Sh* Brooke, Notary Public otary ublic Ca1We Bm, Ctx?'lberlend county i My Con'xni?ion Expires Aug. 5, 2009 1 Member. Pennsylvania Association of Notaries C' 0 tj n" f ' Z-; F -lip rY (_ ' °r ? LdS G - F:TaXS\Ch=b\12839 WoodaA S\12839.1ws Revised: 7/16/08 9:26AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE K. WOODALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-6217 CIVIL ACTION - LAW ROBERT L. WOODALL, JR., Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce and Notice to Plead was received by Defendant Robert L. Woodall, Jr., via certified mail, restricted delivery, return receipt requested on December 3, 2005, and attached hereto. Sworn to and subscribed before me this 16' day of July, 2008. ?"f M-0, Ac Notary Public COMMONWEALTH Of PENNSYLVANIA Notarial Seal Mdna A. Shc*, Notary Public Cat" Bolo, Cumberland Cotmty My Corrxniaaion Expires Jan. 19, 2010 Member, Pennsylvania Assoolation of Notarles J t ai GWIpiMtttife1.2, and 3. Abotaair 10him ftm4 if FkmO *cNd DN vwY I*dmWW.: ¦ PdN your name and addroee on the w,* n so that we can ftm the cwd to you. ¦ Attaoh V* owd to the book of the rraWk*w, or on the ftnt K epwo penMts. 1. Mole MdrpNd to: Mr. Robert L. Woodall, Jr. 21 W. Mulberry Hill Road Carlisle, PA 17013 A. B. ReoelMgd try (P~ PIMW I q Qw? ter L 3 0 e? D. k1 d*my adds d% m from Rem 17 D ym if YEB. wow da vwy addnN below. D No a Swam Ty" =Qwtlllad Mal D app Mal OR gi iet D PAM Reo lot for Mwdwan D k*gsd and D C.O.D. 4. Reehicled Detitiwyr OBft FW IFIVO 2' Ardde dertifdAd No. 1004 1350 0003 7143 6730 PL4 yewi w 1. F ? wid t`lOM+e1?o llMian Rur*t 109695a2-WIMO -r.?.-. c ?.?? ?? °r .y t: cv ; ?;. ? -,- _ -? c'> - ` -: ? .y -% F:\FMMChCM\12839 Woodall, 5\12839.laos2 Revived: D16108 9:39AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE K. WOODALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-6217 CIVIL ACTION - LAW ROBERT L. WOODALL, JR., Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Plaintiff's Affidavit under Section 3301(d) of the Divorce Code, a Notice of Intention to Request Entry under Section 3301(d) of the Divorce Code and a Counter-Affidavit was served on the Defendant by certified mail, restricted delivery, return receipt requested on June 12, 2008, a copy of the certified mail receipt is attached hereto, as well as a copy of the June 9, 2008, letter to the Defendant referencing the above mentioned documents. Sworn to and subscribed before me this 16' day of July, 2008. 4'?WL?yx 0), Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mellsea A. SdX*, Notary Public Carlisle Boro, Cumberland County My Commissi n Expires Jan.19, 2010 Member, Pennsylvania Association of Notaries a 1% ¦ Compieta Items 1, Z, and & Also corn de 4Wn a If Pa*lc%d 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 mallpieos, or on the front M apace permits. 1. Article Addressed to. Mrloberg b-wboAo Tf- (613 N. EU? ;We? 3 3. 3Meios IWO 0 rIOL A. At-dd&r X ? Addressee B& Raoelued by (Rifled Mona) C. cede cf rr D. Is dellmy address drmw t from item 1? E3 Yes If YES, ago delhrery address below: © No XQM d Mar O t3rptew Mar 0 Repls7Jelo ] Reoelpt for M.rdrm,dlse 0 Irrered Mar C.O.D. 4. Rsetriaioed DeNrery? fSftFS* O Yes 2. ArtoisNUMW 7003 3110 0004 5772 8543 (flarbr ftib service Ndw Ps Fomm 381 t. fabnwy am f#enratrs t tasaaweaFU?o L . qb June 9, 2008 Mr. Robert L. Woodall, Jr. 620 N. East Street Carlisle, PA 17013 RE: Woodall v. Woodall Our File No. 12839 Dear Mr. Woodall: As you know, I am representing your wife Suzanne K. Woodall with respect to a divorce action. In connection with this divorce action, I enclose the following: 1. A copy of the Plaintiffs Affidavit under Section 3301(D) of the Divorce Code whereby she certified that the two of you have been separated for at least two years and that the marriage is irretrievably broken. 2. A Notice of Intention to Request Entry of A Section 3301(D) Divorce Decree. 3. A Counter-Affidavit which you may file with theProthonotary. Your attention to these matters is merited. Very truly yours, MARTSON LAW OFFICES Hubert X. Gilroy HXG:srb cc: Ms. Suzanne Woodall Enclosures r rii_c.? t uerK I.\ i4 %%"-h'11 _S I'7 V>.I.n,' hJ C'- ?' ?/'} ? ^++{,x1 e :i3 ?7. ?`?.1 ?.?, ?J 1" 47 ?..._ ,a° ?. :L}? i, ` C _. j r _y Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE K. WOODALL, Plaintiff V. ROBERT L. WOODALL, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-6217 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD (3301d) 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery, on December 3, 2005. See Affidavit of Service, as filed. 3. Date of filing and service of the plaintiffs affidavit upon the respondent: Filed on June 11, 2008, and served via certified mail on June 12, 2008. See Affidavit of Service, filed. 4. Related claims pending: No claims were raised. 5. Date and manner of service of the notice of intention to file praecipe, a copy of which is attached hereto: Served on June 12, 2008, via certified mail. See Affidavit of Service, filed. MARTSON LAW OFFICES By Date: July 16, 2008 Hubert). Gilroy, Esquire 10 E ,seHigh Street Carl' le, PA 17013 (717) 243-3341 Attorneys for Plaintiff F. I-LI S Ciients,12SY Woc UII. S' 12S' I). !,Notice of mention to Request Entry of M, rce Decree.tepd Cte-atedi 9 70 04 0.06PM Re, ised. 6 9 „3 11, I: ANI Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE K. WOODALL, Plaintiff IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA V. ROBERT L. WOODALL, JR., NO. 2005-6217 CIVIL ACTION - LAW NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: ROBERT L. WOODALL, JR. 620 N. EAST STREET CARLISLE, PA 17013 DEFENDANT You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the § 3301(d) Affidavit. Therefore, on or after September 5, 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 with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. 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. f -; YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS i OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU ?,, CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE :ABLE TO PROVIDE )I'OU r f , ? 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, PENNSYLVANIA 717-249-3166 Date: I u-1;;it X. Gilroy, Esquire Attorney for Plaintiff Q ? 42 ? F a ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SUZANNE K. WOODALL, Plaintiff VERSUS ROBERT L. WOODALL. JR. N 0. 2005-6217 DECREE IN DIVORCE AND NOW, -SJ 13 30 , 'Xwe' IT IS ORDERED AND DECREED THAT SUZANNE K. WOODALL , PLAINTIFF, AND ROBERT L. WOODALL, JR. 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. BY THE COURT: IN\ -? ATTEST: -1 PROTHONOTARY 30 os ? ? P. a