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HomeMy WebLinkAbout02-1590CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2oo - ! : IN DIVORCE NOTICE 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 in 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 THF~ 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 HF~LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES 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 before the court. You must attend the scheduled conference or hearing. CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2oo2- : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(e) OF THE DIVORCE CODE NOW comes the plaintiff, Carol E. Wilson, by her attorney, Rebecca R. Hughes, Esquire, and files this complaint in divorce against the defendant, Raymond L. Wilson, representing as follows: 1. The plaintiffis Carol E. Wilson, an adult individual residing at Box 193, Bendersville, ,Adam~q County, Pennsylvania 17306. 2. The defendant is Raymond L. Wilson, an adult individual residing at 4342 Carlisle Road, Gardners, Cumberland County, Pennsylvania 17324. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on October 6, 1991 in Plainfield, Pennsylvania and separated in February 2000. 5. There have been no prior actions of divorce or for annulment between the parties. 6. There were two (2) children bom to this marriage, ~amely; Cortney N. Wilson, bom September 13, 1990, age 11 years, and Kayla A. Wilson, bom July 4, 1995, age 6 years. 7. Pursuant to the Divorce Code, Section 330 l(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that she has been advised of the availability of co~mqeling and that said party has the fight to request that the court require the parties to participate in counseling. WI~REFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Date: April / ,2002 Respectfully submitted, Rebecca R. Hughes, lgsq~firdI, ~ E. Wilson Attorney for Plaintiff, C: West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I.D. No. 67212 CAROL E. WILSON, Plaintiff Ve RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002- CIVIL TERM : : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, 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. I verify that the statements made in this affidavit are hue and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: April / ,2002 CAROL E. WILSON VERIFICATION I have read the statements made in the foregoing Document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. CAROL E. WILSON Date: S~/ .2002 CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW .. : 2002-1590 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 2, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of 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 ifI 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: '~- !/~Oo>- ,2002 CAROL E. WILSON CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 2002-1590 CIVIL TERM : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the 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 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 affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: "~- /[ '~'~ ,2002 CAROL E. WILSON Plaintiff CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 2002-1590 CIVIL TERM : : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 2, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of 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 ifI 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: t~gq ~3-t~ t~y ,2002 RAeY~OND L. WILSON CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : 2002-1590 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENI'RY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the 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 ifI 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 affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: t~0 ~3-L] t_ ~t ,2002 Defendant CAROL E. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : 2002-1590 CIVIL TERM RAYMOND L. WILSON, : Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND : NOW, Rebecca R. Hughes, Esquire, being duly sworn according to law, does depose and state: 1. That she is a competent adult and attorney for the Plaintiff in the captioned action. 2. That a certified copy of the Complaint was served upon the defendant, Raymond L. Wilson, on April 4, 2002 by certified mail, return receipt requested, restricted delivery, addressed to 4342 Carlisle Road, Gardners, Pennsylvania 17324, with return receipt number 7001 2510 0009 2828 4999. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa~C.S. Section 4904, relating to unswom falsification to authorities. IRWIN, McKNIGHT & HUGHES Date: 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Plaintiff Carol E. Wilson IN ThE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CAROL E. ~LSOII~ Plaintiff STATE OF ~ PeNNA. VERSUS Defendant Decree iN DIVORCE AND NOW, DECREED THAT Carol E. Wilson ,7~2, IT IS ORDERED AND , PLAINTIFF, and Raymond L. Wilson , 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. CAROL E. WILSON, Plaintiff RAYMOND L. WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 2002-1590 CIVIL TERM : : 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Raymond L: Wilson on April 4, 2002, by certified, restricted delivery mail, addressed to him at 4342 Carlisle Road, Gardners, Pennsylvania 17324, with Return Receipt Number 70012510000928284999. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff.' July 11, 2002; by defendant: July 29, 2002. (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 30, 2002. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 30, 2002. Rebecca IL Hughes, Esquire Attorney for Plaintiff Date: August 1, 2002