HomeMy WebLinkAbout06-7062Becky S. Washington, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. C>(-- 761.;k, CIVIL TERM
William C. Washington, Senior, : CIVIL ACTION - LAW
Defendant : 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 in divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the grounds for divorce are indignities or irretrievable breakdown of the marriage,
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 marriage counselors is available
in the Office of the Prothonotary at the Office of the Prothonotary Cumberland County Court
House One Courthouse Square, Carlisle, Pennsylvania, 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS 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 TELEPH()NE f-IEo
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ILP.,
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Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3166
FOREMAN & FOREMAN, P.C. r"
By
Veterans Building, Sixth Floor
112 Market Street
Harrisburg, PA 17101
(717) 236-9391
Attorneys for Plaintiff
Becky S. Washington,
Plaintiff
VS.
William C. Washington, Senior,
Defendant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
. NO.
CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTIONS 3301(a) 3301(c) or 3301(d) OF THE
DIVORCE CODE
The Plaintiff, Becky S. Washington, through her attorneys, Foreman & Foreman, P.C.
makes the following Complaint in Divorce and, in support thereof, avers as follows:
1. Plaintiff is Becky S. Washington, is an adult who currently resides at 3 Prickly
Pear Drive, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is William C. Washington, Senior, is an adult who currently resides at
3 Prickly Pear Drive, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth
of Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were lawfully joined in marriage on May 8th, 1997
in Carlisle, Cumberland County, Pennsylvania 17013.
5. There have been no prior actions of divorce or for annulment between the parties
hereto in this or any other jurisdiction since the date of marriage averred in Paragraph 4, above.
6. There is one (1) minor child born of this marriage, Alyssa Washington, date of birth
May 5, 1993.
7. The Plaintiff has been advised that counseling is available and that the Plaintiff may
have the right to request that the court require the parties to participate in counseling, after being
advised, Plaintiff does not want to exercise her right to request that the Court require the parties to
participate in counseling.
8. This action is not collusive
2
Count I
Divorce Under Section 3301 (c)
9. Plaintiff incorporates paragraphs 1 through 8, inclusive, of Plaintiff's Complaint
as fully as if set forth.
10. That the marriage is irretrievably broken.
11. The Plaintiff requests this Court to enter a decree of no-fault divorce under Section
3301 (c).
WHEREFORE, the Plaintiff, Becky S. Washington, respectfully requests this
Honorable Court to enter a Decree of Divorce in this matter.
Count II
Divorce Under Section 3301 (a)
12. Plaintiff incorporates Paragraphs 1 through 11, inclusive, of Plaintiff's Complaint
as fully as if set forth.
13. Plaintiff was subject to such indignities and abuse by Defendant as to render
conditions intolerable and life burdensome.
14. Plaintiff was subject to verbal and mental abuse by Defendant.
WHEREFORE, the Plaintiff, Becky S. Washington, respectfully requests this
Honorable Court to enter a Decree of Divorce in this matter.
COUNT III
ALIMONY PENEDITE LITE, SUPPORT, COUNSEL FEES AND EXPENSES
15. Plaintiff incorporates paragraphs 1 through 14, inclusive, of Plaintiff's Complaint
as fully as if set forth.
16. By reason of this action, Plaintiff will be put to considerable expense in the
preparation of her case, the employment of counsel and the payment of costs.
17. Plaintiff's income is not sufficient to provide for her reasonable needs and to pay
her attorney's fees and the cost of this litigation.
3
18. Defendant has adequate earnings and income to provide support, Alimony
Penedite Lite and to pay Plaintiffs counsel fees, costs and expenses.
WHEREFORE, Plaintiff requests this Honorable Court to enter an Order for Alimony
Pendeite, support, counsel fees and expenses.
Respectfully submitted,
FOREMAN & FOREMAN, P.C.
Date: G
Harrisburg, Pennsylvania 17101-2015
ID# 201207 Tel. (717) 236-9391
4
Attorney ttorneyfor Plaintiff
112 Market Street, 6`h Floor
Becky S. Washington,
Plaintiff
VS.
William C. Washington, Senior,
Defendant
AN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF COUNSELING
1. I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
Date: b L
Becky S. ashington
5
Becky S. Washington, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. CIVIL TERM
William C. Washington, Senior, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint 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 unsworn falsification to authorities.
Date: 1-1'f 6b
Becky S. Washington
6
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BECKY S. WASHINGTON,
Plaintiff,
V.
WILLIAM C. WASHINGTON, JR.,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 06-7062 CIVIL TERM
: IN DIVORCE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the above-captioned complaint attached for service upon Defendant,
WILLIAM C. WASHINGTON.
Respectfully Submitted,
f
Date:
O? Aso
J ph D. Caraciolo, Esquire
torney for Plaintiff
Attorney I.D. 90919
112 Market Street, Sixth Floor
Harrisburg, PA 17101-2015
Telephone - (717) 236-9391
Facsimile - (717) 236-6602
CARACIOLO, P.C.
p '
00 r' yf-
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-07062 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON BECKY S
VS
WASHINGTON WILLIAM C JR
TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within REINSTATED COMPLAINT was served upon
WASHINGTON WILLIAM C SR
DEFENDANT
the
at 1527:00 HOURS, on the 29th day of September, 2008
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
WILLIAM C WASHINGTON SR
by handing to
a true and attested copy of REINSTATED COMPLAINT
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 5.00
Affidavit .59
Surcharge 10.00
n
Iqla (,
00
-/ 33.59
Sworn and Subscibed to
before me this day
of
So Answers:
' C fig. ,.i?,Y.Y1y°s?? ?/Ji.A'?
R. Thomas Kline
10/01/2008
FOREMAN & FOREMAN
By:
De uty She iff
A.D.
Joseph D. Caraciolo, Esquire
Attorney ID No. 90919
Foreman & Caraciolo, P.C.
112 Market Street, 6"' Floor
Harrisburg, PA 17101
(717) 236-9391 Telephone
(717) 236-6602 Facsimile
joseph@FFClaw.net
Attomevs for Plaintiff
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
F ?.ED-Di IL,-
-IF THE PROTHON01
?.011 SEP 15 PM 12: 2:'
CU PENN YLVAN ANT+`?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Plaintiff, Becky S. Washington, moves the court to appoint a master with respect to the
following claims:
( X) Divorce
O Annulment
() Alimony
O Alimony Pendente Lite
(X) Distribution of Property
() Support
O Counsel Fees
O Costs and Expenses
and in support of the motions states:
1. Plaintiff has not completed discovery as to the claim(s) for which the appointment of
master is requested since Defendant has not cooperated in this action.
2. The non-moving party has appeared in the action pro se.
3. The statutory ground(s) for divorce is 23 Pa C.S.A. §3301(d)
4. The action is contested
5. The action does not involve complex issues of law or fact.
7. The hearing is expected to take one half day.
Dat
Respectfully ub tted,
FOREM1 & .SARA(
Jos D. Caraciolo, Esq>Y
A ey ID No. 90919
1 Market Street, 6th Floor
Harrisburg, PA 17101
Telephone (717) 236-9391
Facsimile (717) 236-6602
Joseph D. Caraciolo, Esquire
Attorney 1D No. 90919
Foreman & Caraciolo, P.C.
112 Market Street, 6°i Floor
Harrisburg, PA 17101
(717) 236-9391 Telephone
(717) 236-6602 Facsimile
joseph@ffclaw.net
Attornevs for Plaintiff
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Joseph D. Caraciolo, Esquire, hereby certify that on the below-noted date, served a true
and correct copy of the foregoing Motion for Appointment of Master upon the following named
Defendant by depositing same, postage prepaid, in the United States Mail, addressed as follows:
William C. Washington, Sr.
3 Prickly Pear Drive
Carlisle, PA 17013
Respectful ly,Submitted,
Date
J s ph D. Caraciolo, Esq`uii
orney ID No. 90919
112 Market Street, 6' Floor
Harrisburg, PA 17101
Telephone (717) 236-9391
Facsimile (717) 236-6602
,r
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
AND
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
c
;MENT OF BECKY S. WASHINGI;O
INCOME:
Employer: U.S. Army Reserves
Address: 6900 Georgia Ave
Type of Work: Supply SGT
Payroll Number: 5570
Pay Period (weekly, biweekly, etc.): 15th and 1 st of each month
Gross Pay per Pay Period: $1,473.75
Itemized Payroll Deductions:
Federal Withholding: $178.31 ± -additional $30.00
Social Security: $83,27
Local Wage Tax:
State Income Tax: $45.15
Retirement: None
Savings Bonds:
Union Dues:
Life Insurance: $27.00
Health Insurance:
Other (specify)
Long Term Disability:
PA Unempl. EE:
Net Pay per Pay Period:
Other Income:
Interest:
Dividends: _
Pension:
Annuity:
Social Security:
Rents:
Royalties:
Expense Account:
Gifts:
Unemployment Comp:
Workmen's Comp:
fn r*s f -
0
-a CD-?I
Total:
TOTAL INCOME:
EXPENSES
Home
Mortgage/Rent: 1St Nationwide Advantage $1,456.00 Home Equity $545.66
Maintenance: $2,000.00+ yearly
Utilities:
Electric: PP&L Budget $201.95
Gas: Area Energy $305.00 budget/month
Oil:
Telephone, Cable and Internet: $100.00+
Water, Sewer and Trash: North Middleton every 2 months $75.71
Employment
Public Transportation: Sometimes over $100.00/month
Lunch: $5.00/day
Taxes
Real Estate: Included in mortgage
Personal Property:
Income:
Insurance
Homeowners: $700.00/year
Automobile: $293.96 All State
Life: $27.00/month SGLI
Accident:
Health:
Other:
Automobile
Payments: $379.00 and $296.58
Fuel: Over $300.00
Repairs: $1,600.00 - $1,800.00/year (Honda) Lincoln & Truck $2,000.00
Medical
Doctor: $15.00 conay
Dentist:
Orthodontist:
Hospital:
Medicine: $30.00
Special needs (glasses, braces, orthopedic devices): Glasses
Education
Private School:
Parochial school:
College: Some tuition fees and book cost $300/semester
Religious:
Personal
Clothing: $1,000.00/year
Food: $500.00 /month or more
Barber/hairdresser: $100.00 every 3 to 4 months
Credit payments
Credit card: Military Star $100+/month
Charge accounts:
Memberships:
Loans
Credit Union:
Miscellaneous
Household help:
Home
Other:
Child care: _
Papers/books/magazines:
Entertainment:
Pay TV:
Vacation:
Gifts:
Legal Fees: $4,000.00 so far
Charitable Contributions:
Other Child Support:
Alimony Payments:
TOTAL MONTHLY EXPENSES:
PROPERTY OWNED
Checking accounts: 1. $400.00 2. $1,000.00 3. $100.00
Savings accounts: $200.00
Credit Union: All the same
Stocks/Bonds:
Real Estate:
Other:
INSURANCE
Hospital:
Medical:
Health/Accident:
Disability Income:
Dental:
Other:
BECKY S. WASHINGTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 06-7062 CIVIL TERM
WILLIAM C. WASHINGTON, SR., IN DIVORCE
Defendant
VERIFICATION
Plaintiff verifies that the statements made in this Income and Expense Statement are true
and correct. Plaintiff understands that false statements herein are made subject to the penalties of
18 Pa.C.S § 4904 relating to unsworn falsification to authorities.
-7 C> , s .
Date BECKY S. WASHINGTON, Plaintiff
Joseph D. Caraciolo, Esquire
Attorney ID No. 90919
Foreman & Caraciolo, P.C.
112 Market Street, 6`h Floor
Harrisburg, PA 17101
(717) 236-9391 Telephone
(717) 236-6602 Facsimile
joseph@ffclaw.net
Attorneys for Plaintifr
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
INVENTORY OF BECKY S. WASHINGTON
Plaintiff files the following inventory 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 in
accordance with Pennsylvania Rule of Civil Procedure 1920.33(a).
Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904
relating to unworn falsification to authorities.
-74
Becky S. ashington, Plaintiff
ASSETS OF THE 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
( ) 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
( X ) 9. Life insurance policies (indicated face value, cash surrender value and current
beneficiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
( ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
() 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
( ) 16. Employment termination benefits - severance pay, worker'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
( ) 23. Education benefits
( ) 24. Debts due, including loans, mortgages held
( ) 25. Household furnishings and personalty (include as a total category and attach itemized list
if distribution of such assets is in dispute
( ) 26. Other:
MARITAL PROPERTY
Plaintiff 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 Description Names of
Number of Property All Owners
2. Lincoln LS William and Becky
Washington
2• Chevy Truck William and Becky
Washington
1 • House 3 Pickly Pear Drive William and Becky
Carlisle, PA 17013 Washington
1 • Chest Freezer (large) William and Becky
Washington
1 • Chest Freezer (small) William and Becky
Washington
1 • Lawn Mower (riding) William and Becky
Washington
1 • Lawn Mower (push) William and Becky
Washington
1 • 2 Couch Set William and Becky
Washington
1 • 1 Set Bedroom Furniture William and Becky
Washington
l • King Size Therapeutic Mattress Becky Washington
1 • Oriental Decor Becky Washington
1 Futon Becky Washington
1 • Misc. Tools William and Becky
Washington
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
Item Description Reason for
Number of Property Exclusion
2• Honda Motorcycle
PROPERTY TRANSFERRED
Item Description Date of Consid- Person
Number of Property Transfer eration to whom
Transferred
LIABILITIES OF THE PARTIES
Item Description Names of Names of
Number of Propert y All Creditors All Debtors
BECKY S. WASHINGTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 06-7062 CIVIL TERM
WILLIAM C. WASHINGTON, SR., IN DIVORCE
Defendant
CERTIFICATE OF SERVICE
I, Joseph D. Caraciolo, Esquire, hereby certify that on the below-noted date, served a true
and correct copy of the foregoing Inventory upon the following named counsel by depositing same,
postage prepaid, in the United States Mail, addressed as follows:
William C. Washington, Sr.
3 Prickly Pear Drive
Carlisle, PA 17013
FO
D le YS
s (I
OLO, PC
jo eph D. Caraciolottsquir
ttorney ID No. 90919
12 Market Street, 6 h Floor
Harrisburg, PA 17101
Telephone (717) 236-9391
Facsimile (717) 236-6602
MyPay
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Page 1 of 1
View other LESS CHK DT 110601 Go'
oeFEN5E FINANCE A ND ACCOUNTING SERVICE MILITARY LEAVE AND EARNINGS STATEMENT
D AME (Last, First, MI)
ASHINGTON BECKY SUE SOC. SEC. NO. GRADE PAY DATE YRS SVC ETS BRANCH ADSNIDSSN PERIOD COVERED
•"'"$494
ENTITLEMENTS E04 000715 10 150412 USAR 5570 CHK DT 110601
DEDUCTIONS
ALLOTMENTS SUMMARY
Type Amount Type Amount Type Amount Amt Fwd
A
B BASIC PAY 1162.95
UBSISTENCEALWS 162
51 ED INC TAX 70.70
ICA TAX Tot Ent 2032.4
C .
AH 582.00 65.70
STATE INC TAX 35
70
Tot Ded 172,1
D AM SEP ALWS 125.00 . Tot Apt
E Net Amt 1860.
F
G CrFwd
H
I EOM Pay
J
K
L
M
N
0
TOTA
L 2032.461 172.10
E F Ba Emd Used r B ETS Bal Lv Lost Lv Paid UseA ose ED age Pe' Wage YT
D
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0 3
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Tax YTD
.
.
0 28.5 .0 .0 55.0 AXES 1162.95 5379.
M
Wage Period Soc Wage YTD Soc Tax YTD Mad Wage YTD Med Tax YTD ISTA St Wage Period Wage YTD 00
.00 1644.50
WS E
T
S 1162.95 11629.50 488.44 11629.50 168.63 AXES PA 1162.95 15379.50 x
ax YTD
S 00 473
25
[ BAO Type BAO Depn VHA Lp Rent Amt Share Stat JFTR Depns 2D JFTR BAS Type
W DEP SPOUSE 17013 .
Cher ty YTD TPC PACIDN
HRIFT
Base Pa Rate Base Pa Current S P Rate GS py y Spec Pay Current Inc Pay Rate Inc Pay Cunent Bonus Pay Rate Bonus Pay Current
00 0 .00 0 .00 0 00
TSP YTD Deductions Deferred Exempt
00 .00
00
REMARKS: YTD ENTITLE 24074.60 YTD DEDUCT 3782.04
YOUR CHECK WAS SENT TO: MEMBERS 1ST FCU 231382241
MECHANICSBURG PA 1705548 AMOUNT: $1,860.36
ACCOUNT NUMBER: 2181234515 ACCOUNT TYPE: CHECKING
COMPANY CODE: C04059 DIRECT DEPOSIT DATE: 06/01/11
' AS OF 13 APR 07, 000 HIGH TEMPO DEPLOYMENT DAYS ACCRUED
SINCE 1 OCT 00 (OR SINCE ENTERING MILITARY SERVICE)
TOTAL PERFORMANCE FY 11: UTA 00 AFTP 00 ET 00 ATA 00
JPT 00 AAUTA 00 RANT 00 RMA 00 SUP IDT TING 00
MCOFT 00 RMAM 00 AT/ADT 240 FHDA 000
ACTIVE DUTY (AD) FOR TRAINING: 16 MAY 11 TO 31 MAY 11
YOUR CURRENT STATE CLAIMED IS: PENNSYLVANIA
SERVICEMEMBER GROUP LIFE INSURANCE COVERAGE: $400,000
YOUR SGLI DEDUCTION INCLUDES TRAUMATIC INJURY PROTECTION (TSGLI)
SPOUSE SGLI COVERAGE: NONE
-DEADLINE FOR PIETRO STOP-LOSS CLAIMS EXTENDED TO OCTOBER 21,
2011. FOR CLAIM INFO GO TO HTTPI/WWW.DEFENSE.GOV/STOPLOSS.
-UNEMPLOYED OT UNDEREMPLOYED? BUILD YOUR RESUME AT
W W W. EMPLOYERPARTNER S HI P.ORG
-4 JUNE 11 NG SOLDIERS CAN START TO SET UP GOARMYMED
ACCOUNTS.
DFAS Form 702, Jan 02 www.DrAs.ars
https://mypay.dfas. mil/LES_DJMSA. aspx?AccessString=DJMSAR--EMAIL&globalid=D... 5/26/2011
MyPay
Printer Friendly Version
INANCE AND ACCOUNTIN!
OC. SEC. NO.
Type Amount Type
A ASIC PAY 1473.75 ED INC TAX
B BSISTENCE ALWS 162.51 FICA TAX
C H 607.50 STATE INC TAX
D fAM
SEP ALWS 125.00 DDTL FITW
E
F
G
H
J
K
L
M
N
0
Soc
BAQ Type BAQ Depn VI
W DEP SPOUSE 11-
I Base Pay Rate Base
Lv Lost I Lv Paid
REMARKS: YTD ENTITLE 29484.72
YOUR CHECK WAS SENT TO: MEMBERS 1ST FCU 231382241
MECHANICSBURG PA 17055.48 AMOUNT: $2,032.03
ACCOUNT NUMBER: 2181234515 ACCOUNT TYPE: CHECKING
COMPANY CODE: C04059 DIRECT DEPOSIT DATE: 07/01/11
AS OF 13 APR 07, 000 HIGH TEMPO DEPLOYMENT DAYS ACCRUED
SINCE 1 OCT 00 (OR SINCE ENTERING MILITARY SERVICE)
TOTAL PERFORMANCE FY 11: UTA 00 AFTP 00 ET 00 ATA 00
JPT 00 AAUTA 00 AANT 00 RMA 00 SUP IDT TING 00
MCOFT 00 RMAM 00 AT/ADT 270 FHDA 000
ACTIVE DUTY (AD) FOR TRAINING: 16 JUN 11 TO 30 JUN 11
YOUR CURRENT STATE CLAIMED IS: PENNSY).VANIA
SERVICEMEMBER GROUP LIFE INSURANCE COVERAGE: $400,000
YOUR SGLI DEDUCTION INCLUDES TRAUMATIC INJURY PROTECTION (TSGLI)
SPOUSE SGLI COVERAGE: NONE
-DEADLINE FOR RETRO STOP-LOSS CLAIMS EXTENDED TO
OCTOBER 21, 2011. FOR CLAIM INFO GO TO
HTTP: /NVW W. DEFENSE.GOV/STOPLOSS.
-INVITED PARTICIPANTS IN DOD'S MILLENNIUM COHORT STUDY
CAN NOW ENROLL IN THE STUDY AT MILLENNIUMCOHORT.ORG.
Page 1 of 1
view other LESs CHK DT 110701 Go
dILITARY LEAVE AND EARNINGS STATEMENT
'DATE YRS SVC ETS BRANCH ADSN/DSSN PERIOD COVERED
0716 10 160412 BU RSA
6670 CHK DT 110701
ALLOTMENTS SUMMARY
Amount Type Amount Amt Fwd
178.31 Tot Ent 2368.7
83.27 Tot Ded 336.7
45.15
Pay
I 1473.76 1189 S 00 30.00 2,
Pay Current Inc
.00
St Wage Period Wage YTD WS Ex
PA 1473.76 18946.60 S 00
epns 2D JFTR BAS Type Charity YTD TPC
A
Inc Pay Current Bonus Pay Rate Bonus Pay
00 0 .00
Exempt
.00
YTD DEDUCT 4692.27
www.
https://mypay.dfas.milILES_DJMSA.aspx?AccessStrinw=DJMSAR-EMAII,&giohatiri=DN ?/70011
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Printer Friendly Version View other LESS CHK DT 110615 - Go
DEFENSE FINANCE AND ACCOUNTING SERVICE MILITARY LEAV
D
AME (Last, First, MI) C
SEC
N0 E AND EARNINGS STATEMENT
.
.
. GRADE
ASHINGTON BECKY SUE "•'8494 EOS PAY DATE YRS SVC ETS BRANCH ADSN/DSSN PERIOD COVERED
000716
ENTITLEMENTS DEDUCTIONS 10 160412 USAR 6570 CHK DT 110616
ALLOTMENTS
SUMMARY
Type Amount Type Amount Type Amount Amt Fwd
A BASIC PAY 1473.75 ED INC TAX 178
31
B SUBSISTENCE ALWS 162.51 FICA TAX .
Tot Ent 2368.7
83
26
C
D BAH 607.50 TATE INC TAX
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Becky S. Washington
vs
William C. Washington, Sr.
To the Court:
Case No. 06-7062
Statement of Intention to Proceed
Joseph D. Caraciolo, Esquire
intends to
Joseph D. Caraciolo
Print Name Sign Name
Date: 9/14/11
Attorney for
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Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
1. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
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BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
ORDER OF COURT
? of ?. 2011,
AND NOW, this a_ day
Esquire is appointed master with respect to the above captioned
matter:
BY THE COURT:
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Distribution:
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- Joseph D. Caraciolo, Esquire
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Harrisburg, PA 17101
Sixth Floor
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112 Market Street,
Owes j7
William C. Washington, Sr. I I _ ?
isl
3 Prickly Pear Drive, Carle, PA 17013
ter,
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BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(c) OF THE DIVORCE CODE
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1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 11,
2006.
2. The marriage of the Plaintiff and the 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 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.
oft ?tJGc,, 02l> ? 1
Date Becky S. Washington
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
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2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or
expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
4. 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.
Date
Becky S. ashington
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
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DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 11,
2006.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have
elapsed from the date of the 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 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.
Date illiam C. Washi on, Sr.
BECKY S. WASHINGTON,
Plaintiff
V.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 06-7062 CIVIL TERM
IN DIVORCE
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DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
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2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or
expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
4. 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 unworn falsification to
authorities.
Date
,__
BECKY S. WASHINGTON,
Plaintiff
v.
WILLIAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-7062 CIVIL TERM
IN DIVORCE
ORDER
AND NOW, this ~ ~~ day of OCi»i~,.~ , 2012, based upon the Motion for
Revocation of Master filed by the Plaintiff above, the appointment of Master is hereby revoked.
BY THE COURT:
Distribution:
i/ Joseph D. Caraciolo
112 Market Street, 6t~' Floor, Harrisburg, PA 17101
~ William Washington
3 Prickly Pear Drive, Carlisle, PA 17013
/ E. Robert Elicker, II
9 N. Hanover Street, Carlisle, PA 17013
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BECKY S. WASHINGTON,
Plaintiff
v.
WILLLAM C. WASHINGTON, SR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY', PENNSY;LVP~IIA
No. 06-7062 CNIL TEKM ~ ~ ~""'
;..
_ c~ ~ _
IN DIVORCE ~~~
i
PRAECIPE TO TRANSMIT RECORD :
TO THE PROTHONOTARY:
decree:
Transmit the record, together with the following inforniation, to the Court for entry of a divorce
1. Gromzd for Divorce: irretrievable breakdown under Section _ X ~301(c) or
3301(d)(1) of the Divorce Code.
2. Date and manner of service of t:he Complaint: Personal service by Sheriff on September 29, 2008.
3. Complete either Paragraph A. oar B.
A. l Date of execution of the Affidavit of Consent required by Section 3301 (c I
of the Divorce Code by Plaintiff: November 21, 2011 _____________,_,_
by Defendant: November 21, 2011 !__`_________ ____
A2 Date of filing of Plaintiff's and Defendant's Waiver of Notice of Intent:
by Plaintiff: November 22, 2011 ,_~_,___
by Defendant: November 22, 2011 ~.___.______.___ ____
4. Related claims pending. None.
B.l Date of execution of the Plaintiff's Affidavit required under Section 3301(d) of
the Divorce Code:
B 2 Date of service of Plaintiff's Affidavit upon Defendant:
Date of service of Notice to Intention to Enter:
Da~
Respect y Su mitted,
FORE ,~/AN 'C
Jcd~ph D. Caraciblb, Es~ire
2 Market Street, 6`~' Floor
Harrisburg, Pennsylvania 17101
ID# 90919 Tel. (717) 236-9391
P,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Becky S. Washington
v.
William C. Washington, Sr.
NO. 06-7062
DIVORCE DECREE
c.~.
AND NOW, ~ ~°~"~ "~'~ , c~dl'l , it is ordered and decreed that
Becky S. Washington _, plaintiff, and
William C. Washington, Sr.
defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any clairns raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None.
By the Courts _ -"~
-~
Attest: J.
Prothonotary
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n,~i ~~~