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HomeMy WebLinkAbout06-1451 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. OL:, - /L.j~1 CiU'lL~ ffi-~ v. CIVIL ACTION - LAW RUAN C. WILSON, DIVORCE Defendant 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 at the Adams County Courthouse, Gettysburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IFYOU CANNOT AFFORD TO HIREA LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator Adams County Courthouse Gettysburg, PA 17325 (717) 334-6781 ext. 213 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. Ol, - /451 Ciu~CT0Ll v. CIVIL ACTION - LAW RUAN C. WILSON, DIVORCE Defendant COMPLAINT Plaintiff, Amanda L. Wilson, by her attorney, Diane G. Radcliff, Esquire, and files this Complaint in Divorce of which the following is a statement: COUNT I DIVORCE 1. The Plaintiff is Amanda L. Wilson, an adult individual who currently resides at 703 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055 2. The Defendant is Ruan C. Wilson, an adult individual residing at 2963 North 6th Street, Harrisburg, PA 17109. 3. Plaintiff and/or Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 17, 2003 at Abbottstown, Adams County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. 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. 7. Defendant is not a member of the Armed Services of the United States or any of its Allies. -2- 8. Plaintiff avers that the grounds on which the action is based are: A. Section 3301 (cl Mutual Consent No-Fault: The marriage is irretrievably broken; B. Section 3301 Cd) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, DCLlFF, ESQ 48 Trin e Road Camp Hill, PA 1701 1 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff -3- . VERIFICATION Amanda L. Wilson verifies that the statements made in this Complaint are true and correct. Amanda L. Wilson understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. CL1 V'.. . r nf\c{Ii!)i.h~ ~~ (A) )//}f/J/C Amanda L. Wilson Date: 0/0/00 -4- ?CJ 12 .co... ~ ~ ...() \\- \) ("") ....> 0 c:::::"' s; c~.:;> -0 vJ V( cr- ..... "'O\j~ , f\;~ --- C> 'J:'",... --.l -G l"-~ t' ~ -J -';;>' ::0 .-n ....:x :'-',- :gO If'! ;;~, - ......c r ::? U1 C)(~) V) c:~ \, ..." \~,;) :21 \"' -ra'~=^; :;: ,,:;"I..J [-J ~ <i? 2'5 rn __I :?'. .J:'>' ..L A, N :.0 -J .-<.( --- c ,l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WilSON, Plaintiff NO. 2006-01451 v. CIVil ACTION - LAW RUAN C. WilSON, DIVORCE Defendant AFFIDAVIT OF SERVICE I, Diane G. Radcliff, Esquire, being duly sworn according to law, depose and say that on March 25, 2006, I served a true and correct copy of the Complaint in Divorce upon Ruan C. Wilson, the Defendant, by Certified Mail, Restricted Delivery, addressed as follows: Ruan C. Wilson 2963 N. 6th Street Harrisburg, PA 17110 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. D L1FF, ESQUIRE 3448 Trindl oad Camp Hill, PA 17011 Supreme Court I. D. No. 32112 Attorney for Plaintiff (\ I I \ Sworn to and subscribed before me a Notary Public in and for Cumberland County, Pennsylvania this~day of rnoA.ch , 20~. ~fLVI flA .If 4)~%- NOTARY PUBLIC U COMMONI";:OALTH OF PENNSYLVA,jIA r-,Jotlr181 Seal Deboran L [}':1n:.-.y, Notary Public Camp Hill Bon Cumbertc:nd County My Commission Expires Sept 23, 2007 Member. Pennsylvania As~ociation Of Notaries My commission expires: .. -,1 . Complete Items 1 , 2, and 3, Also complete item 4 if Restricted 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 mailpiece, or on the front If space permits. 1. Article Addressed to: B. Received by (Printed Name) D Agent D Addressee C. Date of Delivery D. Is delivery address different from Item 1? 0 Yes If YES. enter delivery address below: 0 No YiitMi (! {J--<-.~ fl.tfiR'} 7). u'i-ll fl- ~~. jJIL ,~'-r l1/1() 3,~e Type rt~led Mail D RegiStered D ReI o Insured Mail 0 C.O.D. 4. 'Restrlcted Delivery? (Extra Fee) 2, Article Number ~",,",_Is~ PS Form 3811 , February 2004 7005 0390 0003 2641 5933 Domestic Return Receipt 102595-02-M-154Q EXHIBIT" A" RETURN RECEIPT CARD ( ~ -ot' rr"t~ ~f, (/) c_: ~c };c:.. S;~~ :? ..-< C .\ '''1 ...... ~, \..f..) -'c , ...\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. 2006-01451 CIVIL TERM V. CIVIL ACTION - LAW RUAN C. WILSON, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 15,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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. Section 4904 relating to unsworn falsification to authorities. Dated: -, o(P C1JMo JAd~~~ 1/L AMANDA L. WILSON (') c ....0 :;;;:) o~ .s--. s-:::: ~ \"....) o I,:) -n ::::I _J-_-r1 n1p:' -,~\:C' '('- F. :;;;: ".,~ r::"~,' ~': en ~.D --", -,..,\ ~:Q. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. 2006-01451 CIVIL TERM V. CIVIL ACTION - LAW RUAN C. WILSON, IN DIVORCE Defendant WAIVER OF NOTI ;EST S~~~~ c U E 1. I consent to the entry of a final decree in 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 in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to ",.wom f,'.ft",t;oo to ,,,hont;,,,. I tJ, ~ f\ Dated: n M'1JJf){A~, ~L. WILSON 0 ,'-' r.:::.::;:~ ~2 1.:;,..:~ ,,-'. 0.... .. .--l ;:;-; :I.! ," r" j"') ..."rn 0 - ~'IC) ~::: 'l.{.) ::'~~ :':.2. :0 -~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. 2006-01451 CIVIL TERM V. CIVIL ACTION - LAW RUAN C. WILSON, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 15, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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. Section 4904 relating to unsworn falsification to authorities. Dated: ;X-;{O-07 ~~._-~ ~ :s\ [~.' 2..r~.: ;z: C", (fJ ,,"- ::..-:' ,: r::.c :.c:::. ~c -c" $c: ~ r--) c:;:;. g -T\ t'""'1 CP t"V --l ~ ::r; N .- ~ ~:!l 'hb; ;Bq OCt :<: i"~ Oc:i i;e; m '::::i ?O ~ coon IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. 2006-01451 CIVIL TERM V. CIVIL ACTION - LAW RUAN C. WILSON, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (Q OF TH~DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or exp~nses 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 ~opy of the decree will be sent to me immediately after it is filed with the Prothonotariy. I verify tha~ the statements made in this Waiver 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. Dated: ;)-.2 tY ~ 0 7 '-~-_..='--_.. .~ RUAN C. WILSON o c: 3:- -0 er' q)q.; "- .,,-' 2S:; ~~'~,. rlt~- )>0 Z'CJ >c: ~ ,.....,:, = = -.J ~ rrt CO N -.l -0 :It ~ o -\'l :i!-n r11p :9 f.I{ (~6 G~ 517n -I "'";.>- ::P -< c..n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA L. WILSON, Plaintiff NO. 2006-01451 CIVIL TERM V. CIVIL ACTION - LAW RUAN C. WILSON, IN DIVORCE Defendant PRAECIPE OF 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 Section 3301 (c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filinsz of Complaint: 3/15/06 b. Manner of Service of Comolaint: Certified mail Restricted Delivery c. Date of Service of Complaint: 3/25/06 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: 7/13/06 b. Defendant: 2120/07 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301 (D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: NI A b. Date of iFiliml: NI A c. Date of Service: NI A 4. RELATED CLAIMS PENDING: No issues have been raised in this case, and there are no issues outstanding. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COpy OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301 (D)(1 )(1) OF THE DIVORCE CODE: a. Date of ~ervice: NI A b. Manner of Service: NI A OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's '1{~: 7/20/06 b. Defendant's Waiver: 2/27/07 DCLlFF, ESQUIRE 3448 le Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717)737-0100 (") c: <- -oeD in II -"-" 4...,......... "-:;lr-S.' Cis) --" c2C ....~ )?: :;~;; ~ -< f'o..) <::::> = -..I ""T1. f'"'l1 co N -.J o "l1 :r:" fl1- -0'23 :J:J I 90 --' .'1'. ~.:;;: -ri ~J (') Zrll o ~ -< -0 ::v:: N c;r-. it' '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" "'~ ;t1'f."'''' '" '" '" '" "'''' '" '" "'''' '" '" "''''''''''if''' '" "'if"''''''''''ififif''''''if'''''' "''''''''''''' "''''''' '" "'''''''''' '" '" '" '" '" '" '" '" '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. AMANDA L. WILSON, No. )006 1451 CIUTT, TERM Plriint-iff VERSUS RUAN C. WILSON. Defendant DECREE IN DIVORCE M~LL ? AND NOW, ,2007 , IT IS ORDERED AND DECREED THAT AMANnA T. WTT.SON , PLAI NTI FF, AND RUAN C. WILSON , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; No issues have been raised in this case, and no issues are outstanding. ATTEST: By THE COURT: PROTHONOTARY "'''' "'''',. "'''' "''''''''''''' '" "''''''',.'''''''''''''''''' "'''''''''' "''''''''''''' "'''''''''' '" '" '" "'''''''''''''''' J. _ ~ 'I ~ _Tit, (.0 $ - [' ~ p ~~ -",p --;"'9 LO- !,-t' . , ,:... .. >~, .