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Home My WebLink About02-2211 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, Plaintiff TY ANN DAVIDSON, Defendant CIVIL ACTION - LAW NO. (~,~ -~/[ CIVIL 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 judgement 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 grounds for the 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 Courthouse, 1 Courthouse Square, Carlisle, PA 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 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 71%249-3166 WEIGLE & ASSOCIATES, RE. -- ATTORNEY5 AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, Plaintiff TY ANN DAVIDSON, Defendant CIVIL ACTION - LAW NO. D ~. 07 ~ ! 1 CIVIL IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Lindsey T. Davidson, by and through his attorneys, Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Lindsey T. Davidson, is an adult individual presently residing at 331 Farmington Drive, Shippensburg, Cumberland County, Pennsylvania 17257, since August 2000. 2. Defendant, Ty Ann Davidson, is an adult individual presently residing at 331 Farmington Drive, Shippensburg, Cumberland County, Pennsylvania 17257, since August 2000. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on September 28, 2000, in Chambersburg, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. The marriage is irretrievably broken. WEII21LE & ASSOCIATES, RE. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 9. The Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. By: WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esqui~ Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, P.C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257~1397 VERIFICATION I verify that the statements made in thc foregoing Complaint in Divorce arc true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. § 4904, relating to unswom falsification to authorities. Dated: Lindse~T. Davidson, Plaintiff WEIGLE & ASSOCIATES, P-C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBIJRG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, Plaintiff TY ANN DAVIDSON, Defendant CIVIL ACTION - LAW NO. 02-2211 CIVIL IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS Patricia A. Frey, being duly sworn according to law, deposes and says that on May 14, 2002, a true and attested copy of Notice to Defend and Complaint in Divorce were served upon the Defendant, Ty Ann Davidson. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Ty Ann Davidson 331 Farmington Drive Shippensburg, PA 17257 The return receipt signed by the Defendant is evidence of delivery to her and is attached hereto as Exhibit A. PATRICIA A. FREY Sworn to and subscribed before me this O~0~' day of May, 2002. Notary Public I , ~ _n~oenet~. County ASSOCIATES. P-C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBEI~AND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, Plaintiff TY ANN DAVIDSON, Defendant CIVIL ACTION - LAW NO. 02-2211 CIVIL IN DIVORCE $0.57 $1.bU $0. O0 0257 ~5 WEIGLE & ASSOCIATES, AC. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 "~t~'~~ ~m~#~ 4'~'~n,~, I 7000 1530 0003 5402 6307 Ty ~n Oavidson 331 Vamington Driv~~.l~ Shippensburg, PA ~7~ RECEIVED HAY ~~1, ~r 1~ ~ to~97-~179 ~ R~um ~ g Restricted Delivery Fee (Endorsement Required} C3 Total ~gesFe~ $ $4.17 05/08/2002 rtl ~ISent To.n~ & ~ t I = r~,-e~/~;;-~;'~- ........... 7 "7-'--~'""7:7::';::;:: .............. '1 · Cream lm a ~.ddmomd m I I~ Wtlh ~ rl~ I~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lindsey Trey Davidson, Plaintiff Ty Anne Davidson, Defendant Civil Action- Law No. 2.002-2211 In Divorce a.v.m. NOTICE TO PLEAD To: Lindsey Trey Davidson, thru his counsel of record, Jerry Weigle, Esquire You are hereby notified to file a written response to the enclosed Counter-Claim in Divorce within twenty (20) days fi.om service hereof or a judgment may be entered against you. Carol A. Redding, #82041 Attorney for Defendant Ty Anne Davidson REDDING LAW OFFICE 19 North Main Street Chambersburg, PA 17201 (717) 267-1440 IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY, PENNSYLVANIA Lindsey Trey Davidson, Plaintiff Ty Anne Davidson, Defendant Civil Action - Law No. 2,002-2211 In Divorce a.v.m DEFENDANT'S COUNTER-CLAIM IN DIVORCE AND NOW COMES the Defendant, TY Anne Davidson, by and thru her attorney, Carol A. Redding, Esquire, and sets forth the following Counter-Claim in Divorce as follows: COUNT I EQUITABLE DISTRIBUTION The parties have been unable to determine and equitably dispose of their respective rights and interest in the marital property. Defendant will, within 90 days atier service of this Complaint upon the Plaintiff, cause to be fled an Inventory of all property owned or possessed at the time this Complaint is fled. WHEREFORE, Defendant requests the Court to equitably divide and distribute and assign the marital property pursuant to the provisions of Seaion 3502 of the Divorce Code. COUNT H ALIMONY Defendant incorporates by reference the allegations contained in Paragraphs 1 through 2 inclusive of Defendant's Counter-Claim in Divorce, as fully as though set out at large herein. The Defendant is without sufficient property to provide for her reasonable needs, and is unable to adequately support herself through her employment. The Defendant cannot support and maintain herself in the style she was maintaining prior to the separation of the Plaintiff and Defendant without continued financial assistance fi.om the Plaintiff WHEREFORE, pursuant to Section 3701, et seq., of the Divorce Code, Defendant respectfully requests your Honorable Court to order Plaintiff to file within 30 days of service of this Counterclaim upon Plaintiff; a complete income and expense statement and to require the scheduling of a hearing to determine Defendant's entitlement to alimony, and if so, the amount. COUNT IlI AI,IMONY PENDENTE LITE~ COUN~F,L FEES AND EXPENSES 6. Defendant incorporates by reference the answers contained in Paragraphs 1 through 5 inclusive of Defendant's Counter-Claim in Divorce, as fully as though set out at large herein. 7. The Plaintiff has refused to enter into any reasonable and fair property and separation agreement, and Plaintiff will incur substantial legal fees in that regard. 8. Furthermore, the resolution of the issues raised by this Complaint will require Defendant to incur considerable additional expenses and costs. 9. The Defendant is without sufficient means to adequately support herself and to meet the costs and expenses of this litigation and is unable to maintain herself during the pendency of this action. 10. The Plaintiff is presently employed at Shippensburg University, Shippensburg, Pennsylvania and his income is unknown to Defendant but exceeds that of the Defendant. WHEREFORE, pursuant to Section 3702, et seq., of the Divorce Code, Defendant respectfully requests your Honorable Court to order Plaintiff to file within 30 days of service of this Counterclaim upon Plaintiff; a complete income and expense statement, and to require the scheduling of a hearing to determine Defendant's entitlement to alknony pendente lite, counsd fees and expenses, and if so, the amount. Respectfully :submitted, Carol A. Redding, #82041 Attorney for Defendant Ty Anne Da, Adson REDDING LAW OFFICE 19 North Main Street Chambersburg, PA 17201 (717) 267-1440 I verify that the statements in this Petition 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. Ty Anne Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lindsey Trey Davidson, Plaintiff Ty Anne Davidson, Defendant Civil Action - Law No. 2002-2211 In Divorce a.v.m PETITION FOR SPECIAL RELIEF IN THE FOILM OF AN INJUNCTION PREVENTING REMOVAL, DISPOSITION, ENCUMBERING OR ALIENATION OF PROPERTY UNDER SECTION 3505 OF THE DIVORCE CODE AND PA.R.C.P. 1920.43(A); PETITION TO AWARD EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE PURSUANT TO 2.3 P.S. SECTION 3502(C) AND NOW COMES the Defendant, Ty Anne Davidson, Petitioner herein, by and through her counsel of record, Carol A. Redding, Esquire and petitions the Court as follows: 1. Petitioner is Ty Anne Davidson, an individual residing at 2177 Loop Road, Chambersburg, Franklin County, Pennsylvania. 2. Plaintiff, Respondent herein, is Lindsey Trey Davidson, an individual residing at 212 Orange Street, Shippensburg, Cumberland County,. Pennsylvania. 3. Petitioner and Respondent are husband and wife, having been marred on September 29, 2000. Respondent has filed a Complaint in Divorce under Section 3301 (c) and (d) of the Divorce Code on May 6,2002. Defendant has filed a Counter-Claim in Divorce which includes counts for Equitable Distribution, Alimony, Alimony Pendente Lite, and Counsel Fees and Expenses. Said action is continuing as the parties have not reached a property settlement. 4. The parties to this action initially separated on May 6, 2002. 5. The parties to this action subsequently reconciled and recently separated again on or about July 13, 2003. 6. At the time of the most recent separation, Petitioner and Respondent resided in the marital home located at 2177 Loop Road, Chambersburg, Franklin County, Pennsylvania. Said residence is rented from Dale and Rachel Frey, who are the titled owners of the property. COUNT I PETITION TO AWARD EXCLUSIVE POSSESSION OF TIlE MARITAL RESIDENCE PURSUANT TO 23 P.S. SECTION 3502(C) 7. Paragraphs 1 through 6 above are incorporated herein by reference. 8. Since July 13, 2003, the Petitioner has continued to reside exclusively in the marital home with her son, Trent Lee Davidson, date of birth December 18, 2000. The Respondent has lived at other unknown locations since July 13, 2003 but has recently stayed continuously at 212 East Orange Street, Shippensburg, Pennsylvania. 9. Petitioner seeks exclusive possession of the marital residence of the parties' pursuant to Section 3502(c) of the Divorce Code for the tbllowing reasons: A. Since the date of the parties separation on July 13, 2003, Respondent has arrived al: the marital home on multiple occasions and removed from the property numerous items in the marital home and belonging to the Petitioner and subject to equitable distribution. Respondent does not notify the Petitioner when he is coming to the residence. Despite Petitioner's requests for notification and agreement as to personal property being removed, Respondent has refused and has continued this practice Petitioner is fearful of Respondent as the separation of the parties was tension filled and stressful. Numerous threats have been made by the Respondent to the Petitioner. Petitioner continues to be subject to a Protection From Abuse Order entered on May 13, 2002 which is not scheduled to expire naturally until November, 2003. If an order for possession is not entered, the Petitioner could be subject to violation of said Protection From Abuse Order when Respondent comes to Petitioner's home unannounced and uninvited. Respondents name is on the lease for the marital residence; however, Petitioner is making the monthly lease payments and is responsible for all bills associated with the property. Petitioner is the sole proprietor of a catering business, the bulk of which is operated out of the marital residence. I. Petitioner often has potential customers at her home and the Respondent has come to the home during these times causing the Petitioner great ,,stress and anxiety. J. Petitioner also spends a great deal of time at the home baking and preparing for upcoming catering events; thus, the Respondent causes her great stress and anxiety when he arrives at the home unannounced and uninvited. K. Petitioner is concerned that Respondent will disrupt her business to the extent of making it unprofitable. L. Respondent has come to the; marital residence during periods of time when the Petitioner was not present. Petitioner believes that Respondent has removed items of property during these times 10. All of the above contact was engaged in by the Respondent to intentionally make the Petitioner's life burdensome and intolerable and deliberately antagonizing her, thus causing her to be stressful and anxious. 11. It is unknown whether Respondent is represented by counsel. Counsel of Record is noted as being Jerry Weigle, Esquire, of Shippensburg, Pennsylvania. Correspondence has been sent to Mr. Weigle inquiring as to his continuing representation. No negotiations have been initiated regarding a final property settlement. 12. No notice was given to the Petitioner that the Respondent planned on coming to the marital home or notice provided as to what property he was going to take. Petitioner believes that the property taken was the property of the Petitioner and that the Respondent took the property as his own. 13. The Respondent's conduct is intentionally designed to provoke and antagonize the Petitioner and serves no legitimate purpose and is willfully malicious, sadistic and hateful. 14. Petitioner believes and avers that it is the intention of the Respondent to return and remove additional items from the home without: her permission, without her knowledge, and without having ownership of the same. 15. Petitioner is continuously fearful that Respondent will insist in entering the marital home for the sole purpose of harassing and annoying the Petitioner and causing damage to the Petitioner's property, in removing marital assets and otherwise damaging the marital home and interrupting the Petitioner's peaceful possession of same. COUNT H INJUNCTION PREVENTING REMOVAL~ DISPOSITION~ ENCUMBERING OR ^! IENATION OF PROPERTY UNDER SECTION $505 OF THE DIVORCE CODE AND PA.R.C.P. 1920.43~A~ 16. Paragraphs 1 through 15 above are incorporated herein by reference. 17. Subsequent to the date of separation, Respomtent has been selling, transferring, disposing, encumbering, concealing, removing or alienating items of personalty to the exclusion of Petitioner, the sums of which are unknown to Petitioner, to wit: a. On multiple occasions since the date of separation, the exact dates unknown to the Petitioner, the Respondent did, without cause or permission, take multiple items of personal property, which were kept in the above referenced marital home located at 2177 Loop Road, Chambersburg, Pennsylvania. Respondent arrived at the home, entered the home and removed the personal property items despite Petitioners objection. No prior notice was received by Petitioner that Respondent would be removing said property. b. Respondent has told Petitioner that he can come to the marital home anytime he pleases and that Petitioner cannot stop him. c. Petitioner runs a catering business at the marital home and is in a state of constant worry as to whether the Respondent will arrive and take additional items of property. d. Petitioner is away from the home at various times of the day or evening at which time the Respondent has indicated he can come to the house and remove property and further that the Petitioner cannot stop him. 18. By selling, transferring, disposing, encumbering, concealing, removing or alienating said items of personalty, Respondent has wrongfully, intentionally, and maliciously prevented Petitioner from exercising her right and ownership interest in said items of personalty in order to defeat equitable distribution. 19. The conduct of Respondent as heretofore stated has been a continuous misappropriation and Respondent refuses, after demand, to refrain from said conduct. 20. Petitioner has no adequate remedy at law. 21. Said transfer and removal of personalty is to Petitioner's great detriment. 22. Immediate and irreparable harm is being caused[ by Respondent's conduct, which is defeating Petitioner's claims of equitable distribution. WHEREFORE, Petitioner prays for equitable relief as follows: a. that an injunction issue preliminarily and until hearing and finally thereafter, enjoining defendant from disposing, transferring, encumbering, concealing, selling, removing, or alienating any realty and/or personalty; b. that your Honorable Court issue an order requiring an accounting of all items of personalty and that no further transfer or removing take place without further order of this Court; c. that your Honorable Court award exclusive possession of the marital residence to Petitioner, to the exclusion of the Respondent and further issue a temporary order for exclusive possession of the m~tal property to the Petitioner pending a final resolution of this matter; d. such other relief as your Honorable Court may deem appropriate; e. award attorney's fees, costs and expenses. Respectfully submitted, Carol A. Redding, #82041 Attorney for Petitioner Ty Anne Da~fidson REDDING LAW OFFICE 19 North Main Street Chambersburg, PA 17201 (717) 267-1440 I verify that the statements in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of [[8 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Ty Anne Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lindsey Trey Davidson, Plaintiff Civil Action- Law v. No. 2.002-2211 Ty Anne Davidson, Defendant In Divorce a.v.m. ORDER OF COUI~tT ANDNOW, this ~l~ dayof ~___~2003, upon presentation and consideration of the within Petition, IT IS HEREBY ORDERED AND DECREED that a hearing will be held on the within Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of property under Section 3505 of the Divorce Code and Pa. R.C.P. 19,,0.43 (a) on the day of ~ 2003 at ~,~'clock~.m., in Courtroom numbel~,~ of the Cumberland County Courthouse, Chambersburg, Pennsylvania, at which time the Plaintiff/Respondent shall appear to present any evidence to show why the requested Special Relief should not be granted to the DefendantfPetitioner. IT IS FURTHER ORDERED that pending such heating Petitioner shall have temporary exclusive possession of the marital residence AND a preliminary injunction is issued against the Respondent until the hearing enjoining the Respondent from disposing, transferring, encumbering, concealing, selling, removing or alienating any realty and/or personalty pending said heating, and to bring with him to the heating an accounting of all items of personalty in his possession. BY THE COURT, ~G£ IN TB~ COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, Iq~NNSYLVANIA Lindscy Trey Davidson, Plaintiff TV Anne Davidson, Defendant Civil Action - Law No. 2002-2211 In DivorCe a.v.rn. MOTION FOR CONTINUANCE TO T~: HONORABL~, ~IIDC~ES OF SAID COURT: Now comes Carol A. Reddin& Esquiro, Attorney for Defenda~ Ty Anne Davidzc~ and sets forth the following'. 1. Plainfiff~ Lindsey Trey Davidson and Defendant, Ty Anne Davidson, are schedule1 for a Special Relief Hearing on Tue~iay, S~ptemb~ 9, 2003, at 2:00 p.m. 2. Carol A. Reddir~ Esquire, was notified on Friday, September 5, 2003, tlmt ~aid heating was sch~luled for Tuesday, September 9, 2003. 3. Tho Office of Carol A_ Red&ns, Esquire, was contacted on Mo~Aay, September 8, 2003 by Richard Webber, E.,~qult~,, infonnlng her th~t ho was oounsel for ~ 4. The Office of Carol A. Redding, Esquire, to date have not received said Order scheduling hearing and have been unable to r~rve Order onto opposing count. PAGE The Office of Carol A. Kedding, Esq~re has contac'ted Richard Webber, Esquire, counsel for Plaintiff, who concurs with said continuance. VV'IIERICIFORE, Carol A. Reddir~ Aliortm~ +'or Defendant, Ty Anne Davidson, n~speotfully ~que~t tha~ the Sl~ial Reli~ Hearing sch~ul~l for Tu~tay, Suptumb~ 9, 2003 at 2:00 p.m. b~ co~3nued to a n~v date of _, 2003 of the Cumt~and County Courthouse, at __ .m., ia Cou~'oom Number P~svtvaui~ with notice provid~l to all panics. Carol A_ Kedding. Esquire Attorney # 82041 Attorney for Ddgndaut R.EDDINO LAW O~tCE 19 North lt~fin Strict C~ PA 17201 (717) ~7-1440 PAGE 06 09/09/2005 10:31 7172673298 I verify that the statemeats set forth in the gorei~oing dooiment are tree and corr~'t. I understand that fat.se..statements herein are made subject to the pellalties of 18 Pa.C.S. 4904 relating to unsworn falsitcaiion to au~odfies. Carol A. ILcdding, E~ui PAGE 87 Bg/09/2B03 lB:S1 7i72673298 CERTllr[CATE OF SERVICE I DO ItERFJt¥ Cl;llTllq' that on this date I caused the tbregoing Motion for Continuance to be sewed Via F~..~imile (717) 532-5289 to Richard Webber. Esquire.. Richard Wd~b~, Faquire Wdltle & Asr~t~ 126 East King Stnx't Shippeastm~ PA 17257 Date: ~ Carol ,~ Reddin& E~uir~ Attorney No,82041 Counsel for Defendant Ty Anne Davidson PAGE 08 89/09/2003 10:31 7172673298 VF, RII~CATION FROM COUNSEL To thc bea~ cd'my knowledE~ h[mmation and beliet~ formed after an inquiry reasorulble under the circum,stanc~ the foregoing plead/n~ (1) is not being presented for any improper purpose, such as to harass or to cause unnecessary or heelless increa.~e in the. cost of litigation; and (2) the claims, deg~ik~es, and othec legal contentions therein ate ~,arranted by ~xistin8 hsw or by a nonfrivolous argum=nt fur the oaension, modification or reversal of existing law or the establishracnt of new law; and (3) the factual allegations have evidentiaq, support or, if specifically so identified, are likely to have evidemiary suppor~ agter a reasonable opportunity for furthor investi~*ion or discovery; and (4) thc do~ials of fa~ttud all~:gations are warranted on the evidence or, if spedfically so idmtified, are reasonably based on a lack of information or belie/. Carol A. Red&hr, E~luire 0 09/09/2003 10:31 7172G73298 I PaGE 01 PATRICK J. REDDING CAROL A. REDDING A TTORNE ¥S A T LA W Cc: Urgent For Review __Please Co~nment Please Reply COMMENTS: T~.e information trat~mittcd by ~is ~a~imile is considered attorney privileged and . confidential ~nd is intended only for the u~ of~c md~vidu~ or entity n~. If~e ~der of~e m~e is not thc int~d~ r~ipicnt or thc employee or agent tcs~nsible to deliver it to the intend~ recipien~ you should be aw~ that at diss~ination, distribution or copying of~ ~i~tions is ~trictly prohibited. If you have received ~is communication in e~or, pl~se i~ediat~ly notify ~ by telephone ~d r~t~n th~ origin~ m~ssage ' to us at the a~vc addr~s via thc U.S. Pos~l Servia. If you do not receive all of the pages indicated above, please call our office at 717-267-.1440. Additional Comments: Reddln,~ L~w Office 19 Nor'lb Main &~'eet Cbambersburg, Pa 17201 717-267-1440 09/0B/2003 10:31 7172673298 IN '.l'~ COURT OP ~OMMON i~'-AB PAGE 83 Lindsey Trey Davldson, : Plaintiff Ty Aunc Davidson, Defendant Civil Action - Law No. 2002-2211 In Divorce a.v.m. ORD~iR OF COURT A~n Now, t~ '~ 4~aay o~ ~ ,2003, ~ ~ Motion ~ng ~ pm~ ~ ~n~d~ ~d ord~ ~o ~ fil~, it is h~ o~ t~t ~e S~ RcI~ H~ mh~ for the ~ ~y of S~t~b~, 2~3 ~ 2;00 p.m. ~n~ ~ ~ ~ of2~3 ~ /'~ ~.m.,~ P~I~. N~h~ p~cs ~d ~ ~di~ by ~c ~nS of ~n~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, : CIVIL ACTION - LAW Plaintiff : : v. : NO. 02-2211 CIVIL : TY ANN DAVIDSON, : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND ~ 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dated: Ty Ann Davidson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, : CIVIL ACTION - LAW Plaintiff : : v. : NO. 02-2211 CIVIL : TY ANN DAVIDSON, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on May 6, 2002. 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. 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 answorn falsification to authorities. Datea: I a' lq'0 Ty Ann Davidson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, : CIVIL ACTION - LAW Plaintiff : v. : NO. 02-2211 CIVIL : TY ANN DAVIDSON, : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) AND ~ 3301(d) OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 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 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. Dated: /C~ --//Ct~'~ ~ Lin~d'~.~ Davidson, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, : CIVIL ACTION - LAW Plaintiff : : v. : NO. 02-2211 CIVIL : TY ANN DAVIDSON, : Defendant : 1N DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divome under § 3301(c) of the Divorce Code was filed on May 6, 2002. 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. 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. Dated: /C~' /a~ ~ ~ Z/sey~ Lind . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDSEY T. DAVIDSON, Plaintiff TY ANN DAVIDSON, Defendant CIVIL ACTION - LAW NO. 02-2211 CIVIL 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. Date and manner of service of the complaint: May 14, 2002, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff, December 19, 2003, by Defendant, December 19, 2003. 4. Related claims pending: None Date Plaintiff's Waiver in § 3301(c) Divorce was filed with the prothonotary: December 22, 2003 Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: December 22, 2003 WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF .~ PENNA. LIItDSET TRE~ DAVIDSON Plaintiff No. 02-2211 VERSUS TY ~ DAVID$ON Defendant AND NOW, DECREE IN DIVORCE , 200~ , IT IS OrDErED AND DECREed THAT AND LINDSEY TREY DAVIDSON TY~IE DAVIDSON , PLAINTIFF~ ,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; ATTEST: PROTHONOTARY