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Home My WebLink About87-0020IN THE COURT OF COMMON PLEA~ CUMBERLAND COUNTY, PENNA NO. Civil, 1987 ETHEL R. WIRE, Plaintiff vs. RALPH WILLIAM WIRE, Defendant COMPLAINT IN DIVORCE LAW OFFICES GOLDBERG, KATZMAN ~ SHIPMAN, P.C. (717) ~S4-4161 I-I1 0 0 ~ I I I I I I I I I I I I I I I I OF THE PROT~ONOT~RY CUMBE~,LAN~ ~OUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ....... ET~I'F_,L.. R .... W_T~R.E, ............................................. ...................................... P-lai-nt--i f-f- ...................... Versus ....... ~.I!.. ~_::!;L~.!_._A~.....WI;._~._., ................................ ..................................... Defendant ..................... N() ............ ~ .......... Ck~%!..1987 DECREE IN DIVORCE AND NOW, ........ .~.,y~....~.o.~. .... 19. AT.., it is ordered and decreed that ,.~m. ~. ~,~ plaintiff, and .............. m~L~H. W~L~ZA~ .WZR~, .................... , defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claJms which have been raised of record in this action for which a final order has not yet been entered; None. ' ...... ETHEL R. WIRE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : v. : No. 20 Civil, 1987 : : : IN DIVORCE RALPH WILLIAM WIRE, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following nformation, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under C~Section (~ 201(c) ( ) 201(d) of the Divorce Code. ,~(Check applicable section). 2. Date and manner of service of the complaint: ~Served on January ~1987~ s~n~ C~r~f~ m~i!~ ~e~tricte~ De!i~ry, ~ 3. (Complete either paragraph (a) or (b). Return Receipt requeste¢ (a). Date of execution of the affidavit of consent required by Section 201(c) of the Divorce Code: by plaintiff November 18, 1987; by defendant November 13, 1987 ~ · (b) (1) Date of execution of plaintiff's affidavit required by Section 201(d) of the Divorce Code: ; (2) date of service of the Plaintiff's affidavit upon the Defendant: · 4. Related claims pending: None. Ronald M. Katzman~~~~._ Attorney for (X) Plaintiff ( ) Defendant OF tHE :':IcT;~ONJi'ARY C;UMB~'F,L :, N:J COUNTY PENNSTLVANIA ETHEL R. WIRE, Plaintiff Ve RALPH WILLIAM WIRE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. ~ ~) CIVIL, 1987 : CIVIL ACTION - LAW : IN DIVORCE 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 the 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 at the Cumberland County Courthouse. 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 Telephone: (717) 249-1133 GOLDBERG, KATZMAN & SHIPMAN, P.C. BY: Ronald M. Katzn(a~p, Esquire 319 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Plaintiff ETHEL R. WIRE, Plaintiff RALPH WILLIAM WIRE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil, 1987 CIVIL ACTION - LAW IN DIVORCE WAIVER OF COUNSELING Ethel R. Wire, 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 my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Office of the Prothonotary, 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 by the Court. I understand that false the penalites of 18 Pa. C.S. to authorities. statements herein are made subject to §4904, relating to unsworn falsification Ethel R. Wire Sworn to and subscribed before me this ~,~ ~ day of ~:~- ~ , , 1986. OAVID J. LEAClt, NOTARY PUBLIC My Commission Expires: My Commission Expires October 2, 1990 Camp Hill P~, CumbeHand County ETHEL R. WIRE, Plaintiff RALPH WILLIAM WIRE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil, 1987 CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I 1. Plaintiff is Ethel R. Wire who currently resides at 104 South First Street, Lemoyne, Cumberland County, Pennsylvania. 2. Defendant is Ralph William Wire who currently resides at 2417 Harvard Avenue, Camp Hill, Cumberland County, Pennsylvania. 3. The parties have been bona fide residents in the Commonwealth of Pennsylvania for at least six months prior to the time of the filing of this Complaint. 4. The parties were married on November 24, 1948 in Harrisburg, Pennsylvania. 5. There have been no prior actions in divorce or annulment filed by either of the parties hereto. 6. Plaintiff has been advised of the availability of counseling and that the Plaintiff has the right to request that the Court require the parties to participate in counseling. 7. The marriage is irretrievably broken. COUNT II 8. Paragraphs 1 through 7 of the within Complaint are incorporated herein by reference. 9. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties pursuant to Section 401 of the Divorce Code and Rule of Civil Procedure No. 1920.33. COUNT III 10. Paragraphs 1 through 9 of the within Complaint are incorporated herein by reference. 11. Plaintiff requests the Court to allow her alimony as it deems reasonable, pursuant to Section 501 of the Divorce Code and Rule of Civil Procedure No. 1920.31. -2- COUNT IV_ 12. Paragraphs I through incorporated herein by reference. 11 of the within Complaint are 13. Plaintiff requests the Court to allow her reasonable alimony pendente lite, counsel fees and expenses, pursuant to Section 502 of the Divorce Code and Rule of Civil Procedure No. 1920.31. WHEREFORE, Plaintiff prays Your Honorable Court to: (a) Enter a Decree in Divorce, divorcing the plaintiff from the bonds of matrimony heretofore existing between plaintiff and defendant; (b) property; Order equitable distribution of marital (c) Award alimony reasonable; as the Court deems just and fees (d) Order payment of alimony pendente lite, counsel and expenses, as the Court deems just and reasonable; -3- (e) Order such other relief as the Court deems just and reasonable. 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. ~, Dated: /~/~ ~./ ~ ~- ~ ~/~ /~? ~/X~'~ Ethel R. ~/ire PLAINTIFF GOLDBERG, KATZMAN & SHIPMAN, P.C. BY: lio~na~i M. Kat~maa~ Esquire 319 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Plaintiff -4- COMMONWEALTH OF PENNSYLVANIA : COUNTY OF C~ ~ ~,.~ I a~ - : SS: Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Ethel R. Wire who being duly sworn according to law, deposes and says that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of her knowledge, information and belief. Ethel R. Wire Sworn to and subscribed before me this ~ ~ _ day of ~ ~ _, 1986. }~ary Pub~!.~ D/x, VID J. LEA~ , NOTARY PUBLIC My Commission Expires: My Commission Expires October 2, 1990 Camp Hill, PA Cumberiand ¢ount~/ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA ETHEL R. WIRE, Plaintiff vs. NO. 20 CIVIL iRALPH WILLIAM WIRE, Defendant 1987 AFFIDAVIT OF SERVICE LAW OFFICES GOLDBERG, KATZMAN ~c SHIPMAN, P.C. (717) ~[34-4101 ETHEL R. WIRE, Plaintiff vs. RALPH WILLIAM WIRE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 20 CIVIL 1987 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) ss COUNTY OF DAUPHIN ) Personally appeared before me, a Notary Public in and for said Commonwealth and County, Ronald M. Katzman, Esquire, who being duly sworn according to law, deposes and says that on January 5, 1987, he sent the original of the attached letter by Certified United States Mail, Return Receipt Requested, Restricted Delivery, to Ralph William Wire, 2417 Harvard Avenue, Camp Hill, Pennsylvania, 17011, that enclosed with said letter was a copy of the Complaint In Divorce; and the return receipt card signed by R. W. Wire, marked as having been delivered January 6, 1987, is attached hereto and made a part hereof. UiaE RONA~-~'~MANk Q SUBSCRIBED AND SWORN TO before me this 7~ day of January, 1987. ~Public' ~ ~ My Commission Expires: LESA K. ~EtL¥, N~ I.l~rt~burg, Dauphin County, Pa. My Commission Expires April 2, 1990 ARTHUR L. GOLDBERG RONALD M, KATZMAN HARRY B. GOLDBI:'RG F. LEE SHIPMAN PAUL L. ZEtGLER PAUL d, ESPOSITO NElL HENDERSHOT d, dAY COOPER THOMAS E BRENNER DAVID C. NIILLER dAMES M. SHEEHAN dOHN A STATLER APRIL L. STRANG 1. AW OFFICES ~JOLDBEEO, [,(.ATZI~iAI',T ¢~3C SHIPmAn, ~,C. ~19 EAEKET STREET P. O, ~OX l~OO HARRISBURG, PENNSYLVANIA 17108-1~08 January 5, 1987 TELEPHONE (717) 234--4161 TELECOPtER (7t7) 23~-6808 Mr. Ralph W. Wire 2417 Harvard Ave. Camp Hill, PA 17011 CERTIFIED MAIL # P 737 862 158 Restricted Delivery; Return Receipt Requested In re: Ethel R. Wire vs. Ralph W. Wire Dear Mr. Wire: Enclosed herewith please find a copy of the Complaint In Divorce which was filed with (mailed to) the Cumberland County Prothonotary's office on this date, January 5, 1987. Very truly yours, ~Onald'M, Kat~manL~ RMK/lkk Enclosure cc: Samuel L. Andes (w/encl.) ETHEL R. WIRE, Plaintiff RALPH WILLIAM WIRE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil, 1986 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on January6:, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce. 4. 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. 5. 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. §4904, relating to unsworn falsification to authorities. DATE: /rfp ffz /P; /~ ETHEL R. WIRE · ETHEL R. WIRE Plaintiff vs. RALPH WILLIAM WIRE Defendant IN THE COURT OF CO~N PLEAS OF COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 20 CIVIL 19~7 IN DIVORCE AFFIDAVIT OF 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on or about 5 January 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broKen and ninety days have elapsed from the date of filing the Complaint. '=~. ~ I consent to the entry of a final Decree in Divorce. 4. 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 have been advised of the availability of marriage counseling, understand that~ne Court maintains a list of marriage counsellors and that I may request the COurt require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce beco~ting final. 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 1~ Pa. C.S. Section 4904 relating to unsworn falsification toauthorities. November 13, 1987 ~alp~Wi~'liam Wire · Date OF .FN.F ;,, ,- CUMBE~L ~,ND COUNTY PENN SYLV,~NIA I~ 19 2 ~7 PII '1/