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HomeMy WebLinkAbout06-0677 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Erie D. Willhide. ) Civil Action - Law Plaintiff: ) ) {77 VS. ) No. ~-- ) Staci L Grimes Willhide, ) Defendant, ) 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 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 of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT F1LE 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. THIS OFFICE CAN PROVIDE YOU WITH INFORM A TION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 Telephone: (717) 249-3166 AMERICANS WITH DISABlLlT1ES 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 belore the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Eric D. Willhide, ) Plaintiff, ) ) vs. ) ) Staci L. Willhide, ) Defendant, ) Civil Action - Law No. t.I~- ~ 77 G.vJ I~ In Divorce NOTICE OF A V AILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional maniage counselors is available at the Domestic Relations Office, ] 3 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. [fyou desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANJA Eric D. WiIlhide, ) Plaintiff, ) ) vs. ) ) Staci L Willhide, ) Defendant, ) Civil Action - Law No. () (" i-.77 Cu.J--r-'u,.-... In Divorce COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE I. Plaintiffis Eric D. Willhide, a sui juris adult who currently resides at 104 Barnhill Drive, Shippensburg, Cumberland County, Pennsylvania, 17257 since September, 2002. 2. Defendant is Staci L Grimes Willhide, a sui juris adult who currently resides at 228 West King Street, Shippensburg, Cumberland County, Pennsylvania 17257, since January 21,2006. 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 June 2, 200 I in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. The Plaintiffhas 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. 3 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. .~--- Eric D. Willhide, Plaintiff BARLEY SNYDER, LLC Date: II"D I D {, jAr ~Lvv{ 1- ~ Michael J. Connor, Esquire Attorney 1.0. #75927 247 Lincoln Way East Chambersburg PAl 720 I (7 \ 7)264-6494 Attorney for Plaintiff 1550934 4 ">-! ~ "f' ~ ("=0 0 "-' C) c:::) <;. c:J -n 0'.... ~ ..." -c:l -----. -C~ ~l_-n R n, ~l r'l-lp -J OJ u,C-J; .'Ol-n \)'1 I ~71V ~, N \~^'~ t.~) "" ,;;::., \..N -0 .. ,_..- ~ ~ ---... ::r..: t~~fi'~ ~ C'..J '-.. Cl ~iJ -< :< ,-!,\ c:! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA E.kr C P. WrL-L!-frbl Plaintiff Vs FileNo. 6 (; '-0-;?- IN DIVORCE S'TA C r L. CJ It.u-f-t D-E Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] L prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to reswne the prior sumJlllle of 612/ Me S' , and gives this written notice avowing his I her intention pursuant t Date:20C0- 62-03 COMMDNWEALTH OF PENNSYLVANIA) COUNTY OF ('u"", /", f__,JJ On the ~ day of J..Jr.... .. '7 ' 200~, before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and acImowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seaL C).U1P (}1u'O&~/ I ~ Prothonotary or l\Totary Public IIOTARIM. Q MmlOhOTAR'( NOTAIlY'" CAIlUIlE CUMBERLAND COUN1Y_ MY COMMISSION EXPIlIES JMU/IIt't 4,IOtO -,~ .;) 7t. '7 /." 'f';;] c.! 0< ~"''' c::> Ci ,".::.::> 4 0' '--.1 0 -., ~ r> ~ D CO ~- I '& w ~ -'0 --- :;~ ~, 0" \ '0~) (\::, 0) "" t'-~ <<> .~ ~ " I.> \" ;-;,-,~;~- ,p""'! .JIIlI''' ; ."___"",,,;n.'l"-" l~f~;""-j ~i,.-'i.--" t~':;~ ,. '(t,".~UV ,. -~,,......~.._,,..--_."."'-,... ------, ~ \ "'-r't~~ -, '; "~~ '-r.l,-'- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Eric D. Willhide, Civil Action - Law Plaintiff, ) ) ) ) ) ) ) No. 06-677 Civil vs. Staci L Grimes Willhide, Defendant, In Divorce ACCEPTANCE OF SERVICE I, Staci L Grimes Willhide, Defendant, in the above-captioned matter, accept service and acknowledge that I have received a true copy of the Notice to Defend and Claim Rights, and Complaint Under Section 3301(c) and 3301(d) of the Divorce Code filed in the above-captioned matter on February 2,2006. , Date: ...(..../i.._~:.) _ Ce : '- '\t)'--- , {~--.., "''"'. .I ~ i \ t:' ( j I r i~~vl ~~~v ~~( I .\\,(l: ~ } 1, .\.. Staci L~(Gri'mes 'llhide, Defend'ant {. 1550946 " r..) f."":' C;'::;:;;l ,::" -"n 0.:: G.') '-11 (~.i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Eric D. Willhide, Plaintiff I CIVIL ACTION - LAW V. I Staci L. Grimes Willhid~, Defendan~ No. 06-677 Civil In Divorce AFFIDAVIT OF CONSENT 1. A Complaint, in Divorce Under Section 3301(c) and 330l(d) of the Divorce Code was filed on February 2, 200~. i 2. The marriag~ of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date o~both the filing and service of the Complaint. I 3. I consent to t~e entry of a final Decree of Divorce after service of notice of intention to request entry of the Dectee. 1. I consent to he entry of a final Decree of Divorce without notice. 2. I understand ~hat I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not faim them before a divorce is granted. , 3. I understand ~hat I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decref will be sent to me immediately after it is filed with the Prothonotary. , I verify that th statements made above are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorif . Date: 1623725 o ~; ,or, lJ)l ' .-.:l = = (..-r" c__ c: ..~~.,.. 4,'- , .......~ I c::i' C') -n ~ -r -n r11p -.-,D': - -~] "'",-'~ '>'j ",-,~ \':~ :r1. '~}\P\ .:~ .~~ ""D r:? f',:.. Eric D. Willhide, Plaintiff L IN THE COURT OF COMMON PLEAS OF ~UMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW (") -o~. 12; rt r-..) = = 0' <- c:: (~ r'( -<"~'-. -.. .;..,.... . ...~, .~~..7" -0 :r: o -n -i fF,:n r- -rJfJJ ':Ci~i i';'1Q, ~.'.... -"1'" '...,.,} ~..... /' \., ,j ~?\\n ,"" ~ I Ci' No. 06-677 Civil t;? f',:l v. Staci L. Grimes Willhid , Defend In Divorce AFFIDAVIT OF CONSENT 1. A Complain in Divorce Under Section 3301(c) and 3301(d) of the Divorce Code was filed on February 2, 200 . 2. The marriag of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date 0 both the filing and service ofthe Complaint. 3. I consent to e entry of a final Decree of Divorce after service of notice of intention to request entry of the De ee. 1. I consent to e 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! do not laim them before a divorce is granted. 3. I understan~ that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decr,e will be sent to me immediately after it is filed with the Prothonotary. I verify that statements made above are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorit es. 1623725 Date: ~OCtJ - 0 - 02. () ,...., = (,) c = :::-":.:0.- c;:;r. -1'1 <- :::i c.: ~ .." """"'- 'Dr I 7~ iT: 01 ., <-'0; .. " _... "'1:'J .- -" -~,- ):l:.J ('5 r-' N i.":::> " ~i.::! .:J:J IV --<: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Eric D. WiIlhide, Civil Action - Law Plaintiff, ) ) ) ) ) ) ) No. 06-677 Civil vs. Staci L. Grimes WiIlhide, Defendant, 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: I. Ground for divorce: irretrievable breakdown under Section 330 I ( c) and 330 I (d) of the Divorce Code. 2. Date and manner of service of the Complaint: February 4, 2006 - Acceptance of Service signed by Defendant, Staci L. Grimes Willbide; 3. Date of execution of the Affidavit of Consent required by Section 3301(c) and 3301(d) of the Divorce Code: by Plaintiff, June 5, 2006; by Defendant, June 2, 2006; 4. Related claims pending: Resolved through private Agreement; 5. (a) Date Plaintiff s Waiver of Notice in Section 330 I ( c) and 330 I (d) Divorce was filed with the Prothonotary: June 6, 2006; (b) Date Defendant's Waiver of Notice in Section 330 I ( c) 330 I (d) Divorce was filed with the Prothonotary: June 6, 2006. Respectfully submitted, BARLEY SNYDER, LLC ft'w L By: t - Michael J. Connor, sqUIre Attorney for Plaintiff 247 Lincoln Way East Chambersburg, PA 17201 (7 I 7) 264-6494 J.D. No. 75927 1644375 o c ,..., "" c~ <y. ~ ~~: - U) () 11 1.-n \1'f: -\]\"'"1< ~',~!Y '^,/'(-', " ~;.' :'7" ~ 9 }~.r(~; ""J, :::;-.; r-:h :::<: ,-0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Eric D. Willhide No. 06-677 Civil Plaintiff VERSUS Staci L. Grimes Willhide Defendant . DECREE IN DIVORCE AND NOW, JU "\~ 10 , lOO~, IT IS ORDERED AND . DECREED THAT Eric D. Willhide , PLAINTIFF, . AND Staci L. Grimes Willhide ; 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 J. PROTHONOTARY .~.t ~~ w.Lf-? -"'.l fp? ~ u.r.v.P'J ~. Le ? "' " .,' t' .., ~. . 't "L * ~ ,)...~.,