The URL can be used to link to this page

Home My WebLink About06-5749 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. C>l.. - .5'1VP Gu~LY €IZ.n( LISA H. WILHELM Plaintiff DOUGLAS E. WILHELM, JR. Defendant : CIVIL ACTION - LA W : 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 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 in the Office of the Prothonotary, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MA Y 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 TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.C>I..-nqr (l;oLL/~ CIVIL ACTION - LAW IN DIVORCE DOUGLAS E. WILHELM, JR. Defendant NOTICE OF AVAILABILITY OF COUNSELING TO: Douglas E. Wilhelm, Jr. You have been named as the Defendant in a Divorce proceeding filed in the Court of Common Pleas of Cumberland County, Pennsylvania. This Notice is to advise you that, in accordance with ~3302(d) of the Divorce Code, as amended, you may request that the Court require you and your spouse to attend marriage counseling prior to a Divorce Decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013 . 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 services 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 from the date on which you receive this Notice. Failure to do so will constitute a waiver of your right to request counseling. Robert D. Kodak, Esquire Supreme Court I.D. 18041 KNUPP, KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, P A 17108-1848 717-238-7151 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Df.. - S ~l.{'T C!. (cX l ~"1 CIVIL ACTION - LA W IN DIVORCE LISA H. WILHELM Plaintiff DOUGLAS E. WILHELM, JR. Defendant COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, Lisa H. Wilhelm, by her attorneys, Kodak & Imblum, P .C., and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth: 1. Plaintiff is Lisa H. Wilhelm, an adult individual who currently resides at Hampden Township, Cumberland County, Pennsylvania, and has since December, 2005 2. Defendant is Douglas E. Wilhelm, Jr., an adult individual who currently resides at Hampden Township, Cumberland County, Pennsylvania, and has since September, 2004. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 3, 1995, in Cresson, Cambria County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, KODAK & IMBbUM, P.C. ~// /'/ ,0 ~// Robert D. Kodak 407 North Front Street Post Office Box 11848 Harrisburg, P A 17108-1848 (717) 238-7151 Attorney J.D. No. 18041 Attorneys for Plaintiff Dated: 1ztj&> VERIFICATION I, Lisa H. Wilhelm, verify that the facts set forth in the foregoing Amended Complaint are true and correct to the best of my knowledge, information, and belief I understand that false statements herein are subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. Dated:~ . Wilhelm ~L 3060155 ~ r t "}::..)~ tt ~ 8 w ~ ~ ~ f0 iQ. -- ~ 9 ~ ~ ~ (") ~ c:: c::> < a" l' U-' \',1 -0 N U) o ....n --I ff,:n -0 ;:;, :f:O ~ ~~~i ';Srn ,;,-1 (f~ 5J -- ..< e <2 Robert D. Kodak, Esquire Supreme Court I.D. 18041 KNUPP, KODAK & IMBLUM, P.c. Post Office Box 11848 407 North Front Street Harrisburg, PA 17108-1848 717-238-7151 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-5749 CIVIL : CIVIL DIVISION - LA W DOUGLAS E. WILHELM, JR. Defendant : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please file the attached Acceptance of Service as signed by Defendant to the above term and number. TO Cumberland County Prothonotary Dated: October 4. 2006 Robert D. Kodak Attorney J.D. No. 18041 Attorney for Plaintiff A1Nf"':CY. . .',' '-'-'1;"';no IS: I ~,ld II J.JO 900l AH;llO:J,:.;-LtJdd :JHl :10 38!!:!O-O:T1!:J <I LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-5749 CIVIL DOUGLAS E. WILHELM, JR. Defendant : CIVIL DIVISION - LA W : IN DIVORCE ACCEPTANCE OF SERVICE I, Douglas E. Wilhelm, Jr., hereby certify that I accepted service of the Complaint Under ~3301(c) or ~3301(d) ofthe Divorce Code in the captioned matter by personal service at 6:30 p.m., October 2, 2006, at the address of 900 Market Street, Lemoyne, Pennsylvania. /..#~~ Douglas E. Wilhelm, Jr., Defendant 2 S : I ~~d II 1::10 9DOZ AU\"J' ,",', "', , f'" , ::JH.l' . -10 . uvll)i'~l)i'tL,\/,j-j -J; :J :i:Jl';:!G-CBll.:l .. -...... Robert D. Kodak, Esquire Supreme Court I.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, P A 17108-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06-5749 CIVIL DOUGLAS E. WILHELM, JR. Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) and 3301 (d) of the Divorce Code was filed on September 29,2006. 2. The marriage is irretrievably broken and more than ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. f Pf( · 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Office of the Prothonotary, Courthouse Square, Carlisle, Pennsylvania, which list is available to me upon request. 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 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. ~4904 relating to unsworn Dated: d \ q \ 01 \ falsification to authorities. g ~ ~ ~ ~:.;, -n :r!:n d (::i g rr": r;,', fl1. r::: --j'" ,-' N -C} rr1 -nO :j,l CJ:) 7-) ~ -"'--': ':;l9, ~-.., '.:': -0 ()B -,.::. .~ - " ::I:: , >?:.tf\ , 0 ./ C ca ---\ 7"- ~ -4 - ::( v:> .r Robert D. Kodak, Esquire Supreme Court J.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, PAl 71 08-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 06-5749 CIVIL DOUGLAS E. WILHELM, JR. Defendant CIVIL ACTION - LA W IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) and 330 1 (d) of the Divorce Code was filed on September 29,2006. 2. The marriage is irretrievably broken and more than ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. ." ~ 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Office of the Prothonotary, Courthouse Square, Carlisle, Pennsylvania, which list is available to me upon request. 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 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. S4904 relating to unsworn falsification to authorities. Douglas E. Wilhelm, Jr. Defendant Dated: Rb /0 ;)00 f "".............--- ,....:7'.~~ -' ""f-f"""".o-di.,,'" g =s: -0\:.:: !"'"'1 r ' --:,0- ')' l. t~.';: ~~=:i .--':r....C.- Z .~ ~ c::::> --'" ...., f"\"i co N (jj -0 ::!1: W .. ~ :t.-n ,11r:;:: --ol-n ~nS? ;~9. ...-C -11 (~o /..rn 9\ ~ - v> Robert D. Kodak, Esquire Supreme Court J.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, PAl 7108-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-5749 CIVIL DOUGLAS E. WILHELM, JR. Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, ROBERT D. KODAK, ESQUIRE, hereby certify that I have this date served a true and correct copy of the Praecipe to Transmit Record in the above-captioned matter upon the below listed individual( s) by causing same to be deposited in the United States mail, first class postage prepaid at Harrisburg, Dauphin County, Pennsylvania, addressed as follows: DOUGLAS E WILHELM JR 4709 BRIAN DRIVE MECHANICSBURG P A 17040 , P.e. ------.,.-- Robert D. Kodak Dated: February 27.2007 "" (:::;:) ('".:;:) --' -r"I rr'l co N co -0 ~ ~ ::::l ...l-::n rn.- -C)p::j :ay C~O =c :r, Q(-) /-rn 9 ~ '1? .r;:- Robert D. Kodak, Esquire Supreme Court I.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, PAl 71 08-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06-5749 CIVIL DOUGLAS E. WILHELM, JR. Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) AND ~3301(d) OF THE DIVORCE CODE AND AFFIDAVIT OF CONSENT 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 Decree of Divorce 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 and Consent are true and correct. I understand that false statements herein are made subject to the penalties of 189 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Dated: ft.1~([ ~ I U I ;) 0 at /?~~~~ Douglas E. Wilhelm, Jr. ; r-V ~ ~ :It ~~ .fBfTl ~ Z ::J.~ ZC: - <f.t C~ 0"\ ~C:; ~ ~:rl 'Z,C) (:J~ __Ci 'f! ~ :P'C: ~ c::> ~ c.,..) Robert D. Kodak, Esquire Supreme Court l.D. 18041 KODAK & IMBLUM, P.c. Post Office Box 11848 407 North Front Street Harrisburg, PAl 71 08-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff LISA H. WILHELM Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06-5749 CIVIL DOUGLAS E. WILHELM, JR. Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND ~3301(d) OF THE DIVORCE CODE AND AFFIDAVIT OF CONSENT 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, ~awyer' 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 Decree of Divorce is entere~ 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 and Consent are true and cqrrect. I understand that false statements herein are made subject to the penalties of 189 Pa.C.S. ~4904 relating to unsworn falsification to authorities. L Dated: ~\ \61QJ ~ ~ ~ '5 ~ ~ ~~, ~1j!, ~ ~.. z ~; C1" ~.-rl m&~ ~ 5 ~ t-. ~ 'ztn g:c., g ~C2 '-B ~ "'P' C;. 0 ;;.;c:. ~ c".) LISA H. WILHELM PLAINTIFF IN TIlE COURT OF COMMON PLEAS . : CUMBERLAND COUNTY, PENNSYL VANIA YS. DOUGLAS E. WILHELM, JR. DEFENDANT : NO. CIVIL DMSION 06-5749 CML TERM 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 3301 (c) 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaintPefendant accepted service of Complaint personally from Plaintiff's Counsel's agent on 10/02/06. Acceptance of Service 3. Complete either paragraph (a) or (b). filed with the Court on 10/11/06. a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiff 2/Q/07 ; by defendant 2/10/07 b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff s affidavit upon the respondent: 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: 2/27 /07 b. Date of plaintiffs Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: simultaneously herewith (3115/07) Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: Simultaneously ~~ Attorney for PlaintifflDefendant g ;;:: .-oOJ n"l rt': Z::;- zr (J)> ~:: ~i:~ )>c~ z =<! r-..:I C) C) -." :::I: > ::0 ~ ~:D ~.~ Q"TJ :2~ o -, :ii -< c::n J> :x '!1 o w IN THE COURT OF COMMON PLEAS <f. OFCUMBERLANDCOUNTY <f. Of. Of. PENNA. STATE OF <f. LISA H. VILBELII ;+; <f. 5749 CIVIL 2006 NO. Of. <f. PLAINTI" ;+; VERSUS DOUGLAS It. 1lILHELII, JIl. <f. DEFDDARr 'f. <f. 'f. 'f. 'f. 'f. '" '" 'f. '10 '10 '10 '10 '10 '" '10 '" DECREE IN DIVORCE ~ rJO 2007 , IT IS ORDERED AND ~ ,J~. AND NOW, LISA H. VII.BELII , PLAI NTI FF, DECREED THAT DOUGLAS It. V1LIIEUI, JIl. AND , 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; PROTHONOTARY ATTEST: 'f. 'f. <f. it; <f. 'f. ;+ !Ii 'f. <f. ;+ !Ii iIi !Ii J. --JII/ f' ~ ~ <.Ote-r ~ r4~~? -p1J t..O-/-e-f . J . . " "0} 'i!: -') , .. '