The URL can be used to link to this page

Home My WebLink About06-4363KEVIN WILSON, IN THE COURT OF COMMON! PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA SHANA WILSON, VS. Defendant CIVIL ACTION - LAW DIVORCE et Ut1, l E)2 1 No. 01. - J/2 3 NOTICE YOU HAVE BEEN SUED IN COURT. If yu 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 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 Cumberland County, 1 Courthouse Square, Carlisle, Pennsylvania. 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. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, Pa 17013 (717) 249-2663 KEVIN WILSON, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE SHANA WILSON, Defendant No. Q(. COMPLAINT IN DIVORCE 1. Plaintiff is Kevin Wilson who currently resides at 501 Windy Hill Road #11, Shermansdale, Pennslyvania, 17090. 2. Defendant is Shana Wilson who currently resides at 36 Oak Avenue, Enola, Pennsylvania 17025. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on September 25, 2004, in Shermansdale, Pennsyvania. 5. No children were born of this marriage. 6. Neither Plaintiff nor Defendant is in the military or naval service of United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between parties. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce permanently severing the matrimonial bonds between Plaintiff and Defendant and other such other Orders as are just and appropriate. COUNTII EQUITABLE DISTRIBUTION 11. The averments of paragraphs 1-10 are incorporated herein by reference. 12. During the marriage the parties acquired marital property, assets and debts which Plaintiff requests the Court equitably distribute and assign. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce permanently severing the matrimonial bonds Plaintiff and Defendant, enter an Order equitably distributing marital property and such other orders as may be just and appropriate. Date: July 19, 2006 Attorney ID No. 43003 3344 Trindle Road Camp Hill, PA 17011 (717) 612-1660 Attorney for Plaintiff Respectfully submitted, VERIFICATION I, Kevin Wilson, verify that the statements made in the foregoing COMPLAINT in DIVORCE are true and correct to the best of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unworn falsification to authorities. Date: /' 2z- 01 Kevin Wilson ?a V t%? : J ?rj a o Irl f \ - _ k` KEVIN WILSON, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA SHANA WILSON, VS. Defendant CIVIL ACTION - LAW DIVORCE No. D(o -,V3&3 ' C vIL 1cr,* AFFIDAVIT OF SERVICE I, Jaimie Arnold, hereby certify that on this date I personally served a copy of the attached Complaint in Divorce in the above captioned matter upon the Defendant by personally delivering same to her at the following location: ASS Won Shana Wilson ?U t ?; SLR ?,1? Z 46-9ak-Arreme I hereby state that the above is a true and correct statement. August 3, 2006 Respectfully bmi J , Jaimie "old 1 c/o3344 Trindle Road Camp Hill, PA 17011 (717)612-1660 A Z ? 1 co KEVIN H. WILSON, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. ,q3103 No. 06-433 CIVIL TERM SHANA A. WILSON, DEFENDANT, CIVIL ACTION LAW - IN DIVORCE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Defendant Shana A. Wilson in the above matter. Pamela L. Purdy, Esquire 0 115 Pine Street Harrisburg, PA 17101 (717) 221-8303 Attorney I.D. #85783 Attorney for Defendant Date: ?? Z00C ,-- ; "? ?- , ?? _ .? ,?; , KEVIN WILSON, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF vs. No. 06-4363 CIVIL TERM SHANA L. WILSON, DEFENDANT, CIVIL ACTION LAW - IN DIVORCE PRAECIPE TO CORRECT CAPTION TO THE PROTHONOTARY: Please correct the Defendant's name in the above-captioned matter to reflect that her middle initial is "L" and not "A". Pamela L. Purdy, Esquire 115 Pine Street Harrisburg, PA 17101 (717) 221-8303 Attorney I.D. #85783 Attorney for Defendant Date: 27/ 2066 I c-n d • . ,..'k Pamela L. Purdy, Esquire Attorney I.D. No. 85783 115 Pine Street, Suite 100 PO Box 1 15 44 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net KEVIN WILSON, Plaintiff VS. SHANA L. WILSON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 06-4363 MOTION FOR APPOINTMENT OF MASTER Sh.ana L. Wilson, Defendant, moves the Court to appoint a Master with respect to the following claims: ? Divorce ? Annulment ? Alimony ? Alimony Pendente Lite ® Distribution of Property ? Support ? Counsel Fees ? Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment of a Master is requested. (2) The Defendant has appeared in the action personally by his attorney, Susan K. Pickford, Esquire. (3) The statutory grounds for divorce are: §§3301(c). (4) The action is contested with respect to the following claims: distribution of property. (5) The action involves complex issues of law or fact. (6) The hearing is expected to take 1 day. (7) Additional information, if any, relevant to the motion: N/A WHEREFORE, the Plaintiff respectfully requests that this Court appoint a Master in the above-captioned proceeding. Date: 3 2 Respectfully submitted, Pamela L. Purdy, Esquire Of Counsel for Plaintiff CERTIFICATE OF SERVICE The undersigned certifies that on the Zip day of March 2007, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Susan K. Pickford, Esquire 3344 Trindle Road Camp Hill, PA 17011 to, -Lv?j Pamela L. Purdy, Esquire Of Counsel for Plaintiff "` c`-? a -t1 t ? ? ,? ? -?' ? y, ? ,???? ; r ??,? i.,_ ??. ?, t`? -4 Ilk Pamela L. Purdy Attorney ID No. 85783 115 Pine Street Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff KEVIN WILSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. : NO. 06-4363 SHANA L. WILSON, Defendant IN DIVORCE INVENTORY OF DEFENDANT. SHANA L. WILSON Defendant files the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory and appraisement are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. Cons. Star. Ann. § 4904 relating to unsworn falsification to authorities. Date: X9 -7 01 hana L. ilson , ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( x) 1. Real property ( x) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( x) 4. Certificates of deposit ( x) 5. Checking accounts, cash ( x) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities (x) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( x) 14. Personal property outside the home ( x) 15. Businesses (list all owners, including percentage of ownership and officer/director positions held by a party with company) ( ) 16. Employment termination benefits--severance pay, workman's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits -2- ( ) 23. Education benefits ( x ) 24. Debts due, including loans, mortgages held ( x ) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other -3- MARITAL PROPERTY Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced. Item Number 1. 2. 3. 4. Description of Property Wife's car 2001 Ford F1 50 Names of All Owners Wife Marital interest in Premier Holiday timeshare Personalty Husband Husband and Wife Husband and Wife -4- NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property Reason for Exclusion 1 • 36 Oak Avenue Premarital Property of Enola, PA Wife- owns with mother 2. Proceeds from sale of interest in Sass Salon Day Spa 3. Certificates of Deposit 4. Personalty 5. Personalty 6. Nonmarital interest in Premier Holiday timeshare Startup money gifted to Wife by grandfather- income/equity earned after separation Wife's premarital property Wife's premarital property Husband's premarital property Balance paid by Wife with separate assets after separation -5- PROPERTY TRANSFERRED Defendant lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years: Item Description of Number Property 1. Ownership Interestin Sass Salon Day Spa 2. Personalty 3. Personalty Date of Consideration Transfer July 24, 2006 $25,000 none none Person to Whom Transferred Desiree Woof Wife Husband -6- LIABILITIES Item Number 2. 3. 4. 5. 6. 7. Description of Propertx Mortgage on Oak St. Property Home Equity Loan on Oak St. property Loan on Wife's car Loan on Ford F1 50 Consumer debt Consumer debt Consumer debt Names of Names of All All Creditor Debtors Bk. of Landisburg Wife and Wife's mother Bk. of Landisburg Wife, Husband Wife's mother Members l st Wife and Credit Union Husband Unknown Husband Capital One Wife Providian (Mass Mutual) Wife Kohl's Wife -7- CERTIFICATE OF SERVICE ?? The undersigned certifies that on the _-Z3 day of March, 2007, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Susan K. Pickford, Esquire 3344 Trindle Road Camp Hill, PA 17011 Pamela L. Purdy, Esquire Of Counsel for Plaintiff -8- C7 tv N -TI rTl . + T Pamela L. Purdy Attorney ID No. 85783 115 Pine Street Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff KEVIN WILSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. : NO. 06-4363 SHANA L. WILSON, Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT OF SHANA L. WILSON INCOME (a) Wages/Salary Employer & Address Sass Salon. 4931 Carlisle Pike Mechanicsburq PA 17050 Job Title/Description Stylist Pay Period (weekly, bi-weekly, monthly) Weekly Gross Pay per Pay Period (I make commission. This is a 10-wk. average: $ 1 316 00 Payroll Deductions: . . Federal Withholding ....................... .. $ 277.00 Social Security ............................... . $ 82.00 Local Wage Tax ............................. . $ 21.00 State Income Tax ........................... . $ 42.00 Retirement ...................................... .. $ Health Insurance ............................ .. $ 9.00 Other (specify) ..................................$ Medicare ......................................... $ 20.00 .............................. . $ Net Pay per Pay Period .............................................. .................................. $ 844.00 (b) Other Income Week Month Year r q% Interest/Dividends ............................. .. $ Pension/Annuity ............................... ..$ Social Security ................................. .. $ Rents/Royalties ................................ ..$ Expense Account ............................. .. $ Gifts .................................................. ..$ Unemployment Compensation ........ ..$ Workmen's Compensation ................ ..$ $ $ $ $ Total, Other Income .......................................$ 0 $ 0 $ $ 0 Household Child Household Child Week Week Month Month EXPENSES Home Mortgage/Rent (bi-weekly) ............ ... $ 453.00 $ $ 982.00 $ Maintenance ................................. ... $ $ $ 50.00 $ Utilities (telephone, heating electric, etc.) ............................... ... $ $ $ 425.00 $ Employment (transportation, lunches) ..................................... ... $ $ $ 80.00 $ Taxes Real Estate (annually) ................... ... $ 1,650.00 $ $ 140.00 $ Personal Property ......................... ... $ $ $ $ Income .......................................... ...$ $ $ $ Insurance Homeowners ................................. ... $ $ $ 25.00 $ Automobile .................................... ... $ $ $ 61.00 $ Life/Accident/Health ...................... ... $ $ $ 9.00 $ Other ............................................. ... $ $ $ 11.00 $ Automobile (payments, fuel, repairs).... .. $ $ $ 225.00 $ Medical Doctor, Dentist, Orthodontist ............ $ $ $ 35.00 $ Hospital .......................................... .. $ $ $ $ Special (glasses, braces, etc.) ....... .. $ $ $ 100.00 $ Education Private, Parochial School ............... .. $ $ $ $ College ........................................... .. $ $ $ $ Personal Clothing ............................................ $ Food ................................................ $ Other (household supplies, barber, etc) .................................... $. Credit payments and loans ............... $ $ $ 50.00 $ $ $ 300.00 $ $ $ 75.00 $ $ $ 650.00 av. $ -2- Miscellaneous Household help/child care ...................... $ $ $ $ Entertainment (inc. papers, books, vacation, pay TV, etc.) ....... $ $ $ 250.00 $ Gifts/Charitable contributions ........... $ $ $ 5.00 $ Legal Fees (accruing fees now) ....... $ $ $ 200.00 $ Other child support/alimony payments ...................................... $ $ $ $ Other (specify) ....................................... $ $ $ $ Total Expenses ...................................... $ $ $ 3,673.00 $ Ownership* Coverage INSURANCE Company Policy No. H W C Hospital Medical .......................... Health/Accident ............... Capital Blue Cross YWP80014147000 X Disability Income............ Other (dental, etc) .................. Delta DentalNision (*H - Husband, W - Wife, J - Joint, C - Child) Accident Aflac PH 326737 X Disability Aflac PH 326736 X Cancer Policy Aflac PH 326738 X -3- I verify that the statements made in this Income and Expense Statement 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: 7 L Shana L. ilson -4- C? r7l w.J CN [7 C 7 - C7 F l V1 -C Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net KEVIN WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : Docket No. 06-4363 SHANA L. WILSON Defendant ORDER APPOINTING MASTER -7 e AND NOW, 20 0 J i &'64 z Esquire is appointed master with respect to the following claims: By the Gv, J. ce) lea- ce) f U- ? N l.? - . Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net KEVIN WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : Docket No. 06-4363 SHANA L. WILSON Defendant IN DIVORCE PRAECIPE TO ATTACH CERTIFICATE OF SERVICE TO THE CLERK: Please attach the enclosed Amended Certificate of Service to the Motion for Appointment of Master filed in the above-captioned matter. Respectfully submitted, Date:& ( l/6 10 Pamela L. Purdy, Esquire Of Counsel for Defendant ,r w CERTIFICATE OF SERVICE The undersigned certifies that on the .2^day of March, 2007, a true and correct copy of the foregoing Motion for Appointment of Master was served by first-class mail, postage prepaid, upon the following: Susan K. Pickford, Esquire 3344 Trindle Road Camp Hill, PA 17011 Pamela L. Purdy, Esquire Of Counsel for Defendant r-? c-n . F Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net KEVIN WILSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 06-4363 SHANA L. WILSON Defendant TO THE CLERK: IN DIVORCE PRAECIPE TO ATTACH CERTIFICATE OF SERVICE Please attach the enclosed Certificate of Service to the Income and Expense Statement filed in the above-captioned matter. Date: Marc?vt1r t Od.7- Respectfully submitted, "-Z:" pv--'? Pamela L. Purdy, Esquire Of Counsel for Defendant i CERTIFICATE OF SERVICE The undersigned certifies that on the 2?daY of March 2007> a true and correct copy of the foregoing Income and Expense Statement was served by first-class mail, postage prepaid, upon the following: Susan K. Pickford, Esquire 3344 Trindle Road Camp Hill, PA 17011 _Z. Pamela L. Purdy, Esquire Of Counsel for Defendant C1 ??. -° t -?c ?. -? _ 1 ? `r J ;-?? L:J ?ey? -,-j'?i ` i r' c - . s- 7 ?^? ? ? ?? ,,` Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net KEVIN WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. Docket No. 06-4363 SHANA L. WILSON Defendant TO THE CLERK: : IN DIVORCE PRAECIPE TO ATTACH CERTIFICATE OF SERVICE Please attach the enclosed Amended Certificate of Service to Inventory filed in the above-captioned matter. Respectfully submitted, Date: G7 i /?201k6t e, La4l?f Pamela L. Purdy, Esquire Of Counsel for Defendant `'41^ CERTIFICATE OF SERVICE The undersigned certifies that on the day of March, 2007, a true and correct copy of the foregoing Inventory was served by first-class mail, postage prepaid, upon the following: Susan K. Pickford, Esquire 3344 Trindie Road Camp Hill, PA 17011 Pamela L. Purdy, Esquire Of Counsel for Defendant Ti 4{?j ?t - -z i ? rs? 01/06/2008 23:18 7172218403 PLRDY LAW OFFICE PAGE 01/04 Pamela L. Purdy Attorney ID No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108-1166 (717) 221.8303 (717) 221.8403 facsimile plpurdy@verizon.com Attorney for Plaintiff KEVIN WILSON, Plaintiff V. SHANA WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4363 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSEN T I . A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 1, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of 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. § 4904 relating to unsworn falsification to authorities. 0 Dated: Ke Wilson /? ? ?' r+? CID, PURDY LAW OFFICE PAGE 02/04 01/06/2008 23:18 7172218403 Pamela L. Purdy Attorney ID No. 85783 308 N. 2"° St., Ste. 200 PO Box 11544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile pipurdy@rerizon.com Attorney for Plaintiff KEVIN WILSON, Plaintiff V. SHANA WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4363 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENI 1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on August 1, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsificatio thvrities. ana Wilson Dated: 1 1-7 10f C ? ?? t_. ? -n n? --:. ??rM ? ;r,~ ,,,? 4.+. : ^ ^n ( ?i?? ::r ? ? ..' . L.... T;;t r i ti..? 01/06/2008 23:18 7172218403 PURDY LAW OFFICE PAGE 04/04 Pamela L. Purdy Attorney ID No. BS783 308 N, 214 St., Ste. 200 PO Box 11544 Harrisburg; PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.com Attorney for Plaintiff KEVIN WILSON Plaintiff V. SHANA WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO, 06-4363 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NQTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorit S flso Dated: ? Cy „?{ ?.. tr- ? -,?, ?- ..?- x.? ? ? =_. =, °.? 01/06/2006 23:16 7172216403 PURDY LAW OFFICE PAGE 03/04 Pamela L. Purdy Attorney ID No. 85783 308 N. 2"d St., Ste. 200 PO Box 11544 Harrisburg, PA. 17108-1166 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verixon.com Attorney for Plaintiff KEVIN WILSON Plaintiff V. SHANA WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4363 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERL§3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. C Kevin -Wilson Dated: 'J ?? Fr .? ' ?wFL I KEVIN WILSON, Plaintiff VS. SHANA L.WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 9363 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this (/t4' day of 2008, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on January 7, 2008, the date set for a conference, the agreement and stipulation having been transcribed, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. QTBY COURT, . Li Edgar B. Bayley, P.J. cc: Susan K. Pickford Attorney for Plaintiff Pamela L. Purdy Attorney for Defendant i l?tr?D$ C'j w sue . , . ?Fa V C-j KEVIN WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 4363 CIVIL SHANA L. WILSON, Defendant IN DIVORCE THE MASTER: Today is Monday, January 7, 2008. This is the date set for a conference with counsel. Accompanying counsel are the parties, the Plaintiff, Kevin Wilson and the Defendant, Shana L. Wilson. Appearing for the Plaintiff is attorney Susan K. Pickford, and appearing for the Defendant is attorney Pamela L. Purdy. This action was commenced by the filing of a complaint in divorce on August 1, 2006. The complaint raised grounds for divorce of irretrievable breakdown of the marriage and the economic claim of equitable distribution. No claims have been raised for alimony or counsel fees and expenses. With respect to the grounds for divorce, the parties are going to sign affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can conclude under Section 3301(c) of the Domestic Relations Code. The Master's office will file the affidavits and waivers with the Prothonotary. With respect to the claim for equitable distribution, after negotiations, the parties have reached 1 an agreement which is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when the parties leave the hearing room today, they are bound by the substantive terms of the agreement even though they do not ultimately sign the agreement. However, the parties and counsel have indicated that they are going to return at 1:15 p.m. on January 9, 2008, to review the agreement for typographical errors, make any corrections as necessary and then affix their signatures affirming the terms of settlement. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe to transmit the record to the Court requesting a final decree in divorce. The parties were married on September 25, 2004, and separated May 9, 2006. There are no children of this marriage. Ms. Purdy. MS. PURDY: 1. The parties agree that Shana L. Wilson shall assume the home equity line of credit held by the Bank of Landisburg that encumbers the property located at 36 Oak Avenue, Enola, Pennsylvania, and Shana Wilson will hold Kevin Wilson harmless from such liability. Shana Wilson shall endeavor 2 to have Kevin Wilson released from this liability, which release may be affected by his bankruptcy proceeding. Husband has filed a bankruptcy proceeding and it is understood that in view of the bankruptcy proceeding, in which he may be discharged from the obligation, the wife may not be able to have him released from the obligation by the bank. Wife agrees to pursue husband's release from said obligation within thirty (30) days from the date of the signing of this agreement. 2. The parties agree that wife shall make a cash payment of $2,000.00 to husband within sixty (60) days from the date of the signing of this agreement. 3. The parties agree that all proceeds that wife received from the sale of her interest in Sass Salon and Day Spa shall be her sole and separate property and husband releases all interest in said proceeds from the sale of wife's interest. 4. The parties agree that they were jointly liable for consumer credit card debt, and said credit card debt has since been paid off by wife. The parties acknowledge that all joint credit card accounts have been closed. The parties acknowledge that wife is seeking no reimbursement from husband for her payments toward said obligations. 5. The parties agree that all marital and separate personalty has been divided to their satisfaction. 6. The parties agree that wife shall keep the membership in Premier Holiday Travel time-share and that husband seeks no reimbursement for any and all interest he may have in said time-share. 7. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or 3 advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. THE MASTER: Mr. Wilson, you have been present during the statement of the agreement on the record? MR. WILSON: Yes. THE MASTER: Do you have any questions about it? MR. WILSON: No. THE MASTER: You understand it? MR. WILSON: THE MASTER: this agreement as the final equitable distribution in t MR. WILSON: THE MASTER: during the statement of the MS. WILSON: THE MASTER: MS. WILSON: THE MASTER: Yes. And are you willing to accept resolution of the claim for his case? Yes. Ms. Wilson, you've been present agreement? Yes. Do you understand it? Yes. Do you have any questions about it? MS. WILSON: No. THE MASTER: And you satisfied that the 4 agreement as stated on the record will conclude all outstanding issues with regard to the economic matters in your divorce case? MS. WILSON: Yes. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: d? usan K. ickf d Attorney for aintiff q o? P mela L. Purdy Attorney for De ant 5 0 Pamela L. Purdy Attorney ID No. 85783 308 N. 2^d Street Suite 200 PO Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Defendant KEVIN WILSON, Plaintiff V. SHANA L. WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-4363 CIVIL TERM 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 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: August 3, 2006, via personal service delivered by jaimie Arnold. The Affidavit of Service signed by ,Jaimie Arnold was filed with the Prothonotary on August 7, 2006. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: 01/07/08 By Defendant: 01/07/08 4. Related claims pending: A Praecipe to Withdraw Economic Claims was filed contemporaneously with this Praecipe. 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: January 11, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary: January 11, 2008. Respectfully submitted, Pamela L. Purdy Date: ? ?3 C7 -2- CERTIFICATE OF SERVICE The undersigned certifies that on this day of March, 2008, a true and correct copy of the foregoing Praecipe to Transmit Record was served by first-class mail, postage prepaid, upon the following: Susan K. Pickford, Esquire 3344 Trindle Road Camp Hill, PA 17011 Pamela L. Purdy, Esquire Of Counsel for Defendant -3- Q .vr IN THE COURT OF COMMON PLEAS KEVIN WILSON, OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS SHANA L. WILSON Defendant NO. 06-4363 DECREE IN DIVORCE AND NOW, P,\ ,C+ k 1? 2008 , IT IS ORDERED AND DECREED THAT KEVIN WILSON AND SHANA L. WILSON ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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. BY THE COURT: ?? -? " v ATTEST: J. PROTHONOTARY •: .` .. .9 ?.a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff (' (~ ' T 3 b Vs File No. IN DIVORCE ~- ~~ ~, ~. cam,-f~~~ Defendant c~ NOTICE TO RESUME PRIOR SURNAME ~"' ~'~ 3 Notice is hereby given that the Plaintiff /defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, _ or ~ after the entry of a Final Decree in Divorce dated 3- ~' ~~ , hereby elects to resume the prior surname of ~ u i .~ G%1 yIOVC /' ,and gives this written notice avowing his /her intention pursuant to the provisions of 5 .S. 704. Signa Signature of name b g resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~t~mltio_rl4nd ) aao On the ~~-'~ day of ! ,~@8_, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he /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. ~~ ~~ Notary ublic »> tom? 1 T ~~ . ~- ~~ ~ __ Ci.: _~ -- ~ - -- 411.00 PO PUFF ~e+ ?.~ 2~l to (o S'O