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HomeMy WebLinkAbout06-2220 . . F:\User FolderlFinn DocsIGendocs2006\3944-1div,complaint wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M. WALKER, Plaintiff v, CIVIL ACTION - LAW /7 r ~ ,7 NO. 2006- );)) O~ ROBERT DUKE WALKER, SR., Defendant IN DNORCE 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 wamed 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 at the Domestic Relations Office, 13 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 the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice, Failure to do so will constitute a waiver of your right to request counseling, . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M, WALKER, Plaintiff v. CIVIL ACTION - LAW NO. 2006- ROBERT DUKE WALKER, SR., Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this \ \+..h- day of April, 2006 comes Plaintiff, Tina M, Walker, by and through her attorneys, Knight & Associates, P.C" and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Tina M. Walker, who resides at 7 Pine Road, Apartment 305, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2, The Defendant is Robert Duke Walker, Sr., who resides at 213 Security Circle, Ocoee, Florida 34761. 3, The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on November 16, 1996, in Kirkwood, New York, 5, The marriage is irretrievably broken, The foregoing facts are averred and brought under Section 330l(c) or 330l(d) of the Divorce Code of 1980, as amended. 6, The Plaintiff has been advised ofthe availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same, WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, (' Se M, Shult Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own, I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties, C-itw1t (jIJIv ~') ~ ~~ """, .-..j ~ :J ~, ~, ~ +- ~, - ~ \' '--" , , V; CO' '" c..,", ~\ ,;:l {,:-\ C' ... -.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M, WALKER, Plaintiff v, CIVIL ACTION - LAW No. 2006-2220 ROBERT DUKE WALKER, SR., Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this ~day of May, 2006, I, Sean M. Shultz, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Divorce filed in the above-referenced matter, The Complaint in Divorce was mailed on April 24, 2006, but actual service took place on April 29, 2006, by Defendant signing for a copy ofthe Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Robert Duke Walker, Sr. 213 Security Circle Ocoee, Florida 34761 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof, Respectfully submitted, Se . Shult , re Attorney ill No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 F:\User Foldcr\Firm Docs\Gcndocs2006\3944-iceruervice.wpd Attorneys for Plaintiff .. -. . 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: ROber+- DUke Wo-/tt'(, SI. 213 Se(L,{( ih Cirde- o C ()~ e I r ,-' / 3410 I A. Signature -L f'r f~ 0 Agent t( ~ ~ Addressee x B. eceived by (Printed Name) C. Date of Delivery D. Is delivery address different from Item 11 0 Yes If YES, enter dellvery address below: 0 No 3. ~~ Type "-CertJfled Mall 0 Express Mall CJ Registered [] Return Receipt for Merchandise o Insured Mell 0 C,O.D, 4. RestrIcted DelIVery'? (Extra Fee) as 2~:',. 700~ ,;L~:llJ9P2 .f,1S8 .~l7,8 . PS Form 3811. February 2004 Domestic Return Receipt " llllllllll 102595-Q2.-M-154(l (') C "=<': -ot, n:!P 2) 81)" .< f"' < ~):."" , '~f- L:; PC: ~ -r < . ,..., = = "" ::E ,.. -< ~ ~:n n.~ =36 ~~~'f-'~ :1:-r, 90 ~-.ITi o ~ "" U1 -0 :lI: ~ N N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M. WALKER, Plaintiff No, 2006-2220 In Divorce v. Civil Action - Law ROBERT DUKE WALKER, SR., Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. 20, 2006, A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4, 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 prior to a Divorce Decree being handed down by the Court, I verify thatthe 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, Date: ~T ,2006 ~!l!- ()/~ Tina M, Walker l~ to and subs ribed beD re me this - day of , 2006, Notary Public Notarial s8at DoIy M. Housel, NollIIy PuIlIc South MIddIoDl Twp., CIInbeItlrld COlI1Iy My Co.",....., ElcpinlsSept 24, 2006 Member. PennsylvanIa AssOdaIion OfNolaries ~ --00:: fnl':' Z;:~ z,." (fl..-," ~t':: ~S y~ ~ q. ~ ~~ ~ ~~ ~ %~ tf! A '3~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M, WALKER, Plaintiff No. 2006-2220 In Divorce v. Civil Action - Law ROBERT DUKE WALKER, SR., Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &330HC) 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! 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 thatthe 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: ~ 1~] Dlt @.:..- "l1- (j/~ T' aM, Walker '2 ~ -0\1) rf\'\'f. "'-;; ~(~. '-!le-. tL.r::~ 'E'~) 'bU 7~ ra Q, ~ ~~ iP -0 - -S (:) ~~. ~ ~~ c.p. ~ (:) ::;>:. .-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M, WALKER, Plaintiff v, CIVIL ACTION - LAW NO. 2006- 2220 ROBERT DUKE WALKER, SR., Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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 330l(c) of the Divorce Code, 2. Date and manner of service of the Complaint: served on Defendant by United States Certified, Return Receipt Requested, Restricted Delivery Mail on April 29, 2006. 3. Date of execution of the Plaintiffs Affidavit of Consent required by Section 3301 (c) of the Divorce Code; August 8, 2006; by the Defendant; August 19, 2006. 4. Related claims pending: None. 5, Date Plaintiff s Waiver of Notice in !l330 1 (c) Divorce was filed with the Prothonotary: August 10,2006. Date Defendant's Waiver of Notice ill !l330l(c) Divorce was filed with the Prothonotary: August 24, 2006. Date: August 23, 2006 ean M, Shultz, EsqUlre Attorney I.D. No. 90946 II Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff F:\Uscr Foldet'lFinn Docs\Gcnd0cs2006\3944-1 praccipe.wpd o C :<" --0 " r'" cr: ~2 ~~c 4.~:. ?~ :2 ....., g """ J> c: G"> N .::- -0 3 ~ o CO o -n :t! m::!J -om :)]0 ~~~ (S '}":::f1 9(') '..m Sl 15 -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M, WALKER, Plaintiff No, 2006-2220 In Divorce y, Civil Action - Law ROBERT DUKE WALKER, SR., Defendant AFFIDAVIT OF CONSENT STATE OF FLORIDA ) !\lrl....nll :SS. COUNTY OF ~ ) 1. A Complaint in divorce under Section 330 1 ( c) of the Divorce Code was filed on April 20, 2006, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4, 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 par1icipate in counseling prior to a Divorce Decree being handed down by the Court. 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 ::::cati; 7;;ritie~'2006-AJ J./ ;O-~ ~Walker,sr.. Sworn to and subscriblid before me this 11 dayof ~ ,2006, ~ Notll.lY Public F:\User Folder\Finn Docs\Gendocs2006\3944-1aff.consent,wpd " ~~ .' . , ,.. ...." -. .. ...,: .. , .:<, ,~ 10t ,.:",....,:. , . \ , \ .1h\.A ., "'-1.,-( ,\ , ~ '--"''1 (') c. S. -oIT; cbC ~( en>' -<: .. 1-:;(: '- 'J,:>.-.. -,;Z" l> --:::-(_1 J:;'-c "" ~ '\ . \~ \ , " ,..>-.. \ -:: -,. '. \;;5 = c1' ~ G"> N .r:- -" 3 N ., ~ '-. .... '. c:> aJ ~ :i! ~~ -ilC;:> 66 ;-j~1-. .",--n 0-- ,~O -"-(T1 9 ~ 'ta. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA M. WALKER, Plaintiff No, 2006-2220 In Divorce v, Civil Action - Law ROBERT DUKE WALKER, SR., Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~330HC) 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! 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 ofthe 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 heIein are made subject to the penalties of 18 Pa, C,S. 94904 relating to unsworn falsification to authorities, fflfft/ ~ &:::L~ 944-1waiver.ootice,.",.pd ~s-.MorIlIia \'7;.i ::--001'-4 ., ~'" ';;:'':..,.2fI11 Date: ."', "".....1 " ........).... .".. "- "'_~ J. ....... ~" 1"". ~\,~~':- , \ ..;. ''t , ~~'*-.r ~".....~} " '." ,,, '. ~ '&'- ~ '" ~ '2 '2' --06 till'" ~".- ~'~~.- ~/t: j;<-C: ~ ..... If'. ....' ~.... . \, , Q, ~-n '~fTI _JM bI,_ ~"4 4" ~.r: ::Q qa .-ffI g ~ --0 ,: N .' o CP -(, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF TINA M. WALKER, Plaintiff . VERSUS ROBERT OOKE WM1<ER, SR., Defendant . . . . AND NOW, . . PENNA, No. 2006-2220 DECREE IN DIVORCE . A-,-:t- c:t e-:rrA.~ . 11 2006 ,IT IS ORDERED AND DECREED THAT TINA M. WALKER , PLAINTIFF, . AND ROBERT OOKE WALKER, SR. , 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; n/a . . . . . ~$$$$$$$$$$$$$$$$$$$$$$e$$' . ATTEST: J, PROTHONOTARY .-# 7 ~ ~}l, fJ}{J, '7 -b W p'1'~ I..w-r'l 'J/' ~b , . ~~t)'" .. .'~. .... .....> , I "",..-. .