HomeMy WebLinkAbout06-7147
, .
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-Cunninabam
() Co' 11 t.f '1 cLJll fa"
Case Number:
Plaintiff
)
)
)
v.
Judge:
)
Defendant
)
)
)
)
S.mmuel J. Cunninllham
Notice to Defend and Claim Rights
TO: Sammuel J. Cunningham
You have been sued in Court. If you wish to defend against the claim 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 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
child(ren).
When the grounds for divorce are indignities or irretrievable breakdown of the marriage, you may
req(!t marriage counseling. A list of marriage counselors is available in the office of the prothonotary
at l.lVY\~ri(Jrd euuV\~ ,Pennsylvania.
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 telephone tile office set forth below to find out where you can get legal help.
Lawyer Referral Service:
~~~~$~~it ~~f~((~~llcJ[ 3
Date: ld~1 ~-O l",
...
Mailing Address: 509 Grant Drive, Camp Hill, P A, 17011
Phone: 814-553-3257
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-Cunninlham
Case Number:
(j~ -7/'17 cl..J,1 +er~
Plaintiff
)
)
)
V.
)
Judge:
Sammuel J. Cunninl!bam
Defendant
)
)
)
)
Complaint for Divorce
This suit is brought by Amijo L. Whitton-Cunningham, the Plaintiff, Pro Se, Social Security #:
188-68-4814, Drivers License/State ID #: 24340645, age 29 years old, who resides at: 509 Grant
Drive, Camp Hill, PA, 17011 with a home phone number of: 814-553-3257.
Defendant is Sammuel J. Cunningham, Pro Se, Social Security #: 186-58-8219, Drivers
License/State ID #: 24357927, age 29 years old, who resides at: 509 Grant Drive, Camp Hill,
Pennsylvania, 17011 with a home phone number of: 814-553-3256.
l. RESIDENCY:
The Plaintiff has been a resident of the State of Pennsylvania for the preceding 6 (six) months and
a resident of the county in which this Complaint for Divorce is filed for the preceding 10 (ten)
days.
2. MILITARY STATUS:
The Plaintiff is NOT active in the United States Military.
The Defendant is NOT active in the United States Military.
3. SERVICE OF PROCESS:
A Waiver of Citation will be filed by the Defendant, therefore, no service is necessary at this
time.
4. JURISDICTION:
The Court has the required jurisdiction to hear this case. Neither party has ever been involved in
any other domestic relations proceedings involving the other party in this or any other
jurisdiction.
5. MARRIAGE: . I .
The parties were married on April 28, 2001 in the city of Westover, m the state ofPe~y vanIa,
and separated on or about, September 4, 2006, at which time they separated and ceased to hve together
with the intent to terminate the marriage.
An official marriage license is attached to this Complaint for Divorce for reference.
6. GROUNDS: .
Irretrievable breakdown of the marriage and the spouses intend to file affidaVIts that they consent
to the divorce.
7. PREGNANCY:
The Plaintiff is not currently pregnant.
8. CHILDREN:
There are no minor children born or legally adopted of the marriage.
9. PROPERTY AND DEBT:
The property and debt, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
10. RETIREMENT ACCOUNTS:
The retirement accounts, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
II. SPOUSAL SUPPORT:
The spousal support, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
12. HEALTH INSURANCE:
The health insurance, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
13. TAX ISSUES:
The tax issues will be settled by a formal written Marital Settlement Agreement, which will be
submitted to the Court.
14. PROTECTIVE ORDERS:
There are no protective orders between the Plaintiff and Defendant.
15. NAME CHANGE:
The Plaintiff requests that the Court order a name change for the Plaintiff and that the name be
changed to: Whitton (maiden/prior name).
16. PRAYER:
The Plaintiff respectfully requests this Honorable Court to grant this Divorce pursuant to Section
3301 (c), or on the alternative, Section 3301 (d) of the Divorce Code.
17. REPRESENTATION
The Plaintiff has chosen to act as her own attorney in a pro se fashion, and understands that she
has the legal right to representation by an attorney. She fully understands her rights and consider the
terms of the attached Marital Settlement Agreement to be fair and reasonable.
.
18. VERIFICATION
I verify that the statements made in the Complaint for Divorce are true and correct. I understand
that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Dare: ~r{~ ~&. .
1fw,1 ~ t, {)hi '/l'j ~HI iJr J,Cl41/f
~~e ( lainriB; Pro ,Se b
~;f.JIUdf4<6;b
Signature (Plaintiff, Pro Se)
Mailing Address: 509 Grant Drive, Camp Hill, P A, 17011
Phone: 814-553-3257
~
~r>
'- ~
~ V\
~ r-
~
"
w
,
~
~
.........
~
_t::::::.
V,l
~
(/
c""
:co;;;
-c.11-':;'-'-
r;-, ;'
I'..
2~
_~i
-~
~
~
c3
c
. ~;: ~ ~
,.....;)
t::::;)
2:;:~
o
P'j
CJ
,---
~Ii
:;!
Fh::n
:rf,"::;
, 'c'"
-":) c'
,.j
,.'
C;)
~
-.;.';:..
/-
:~~
:u
--<
i'
,
~'-, .-
t
..
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-Cunnin2ham
Case Number: 0 & - 71 L/7 C3"~ I +~r It"
)
)
)
Plaintiff
v.
Judge:
)
Sammuel J. Cunnin2ham
Defendant
)
)
)
)
Affidavit of Verification
THE STATE OF: PA
COUNTY OF: Cumberland
BEFORE ME, Amijo L. Whitton-Cunningham, the undersigned authority and the Plaintiff in the
above referenced case, on this day personally appeared who, being by me duly sworn, upon oath says:
My name is: Amijo L. Whitton-Cunningham
Social Security #: 188-68-4814
Driver's License/ State ID #: 24340645
My mailing address is:
509 Grant Drive, Camp Hill, P A, 17011
Phone: 814-553-3257
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that I am authorized to make this affidavit.
Date: _l J- l ~v<o, .
~ /J-m(j) (-J Jh/ttOf;1-0JlltIJ (fVhCl f11
Prin~Pbmrifi) c::/
~ ._~~~ .
Signa re ( laintiff)
~~O~ TO tD}J~C~ED ~EFORE ME by ~he saiA.\-
~1'10 _.Lt/W\l~lt)~nthIs \ CJ
certify wliich witness my Ntnd and seal of office.
,~ .200~to
r~outL ~:rtOIL)WY
Notary Public, State of P A
Notary Seal
. L(-LI-Q9
My commission expIres:
NOTARIAL SEAl
CLAUDIA' BREWBAKER NOTARY PUBliC
Caltis/e Bore Cumberland County
My Commission Expires April 4, 2009
~ 0
~ -11
c::J
1'1
n
co
CJ
c.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-CunniD2ham
Case Number: (J ~ -7 I i7
Plaintiff
)
)
)
v.
)
Judge:
Defendant
)
)
)
)
Sammuel J. CunnineJIam
Notice of Intention to Retake Prior Name
On this :~th.. day ofJ'PC'e n1 ~er .2 r.oCn ,before me, a Notary Public,
the undersigned officer, personally appeared Amijo L. Whitton-Cunningham, known to me to be the
person whose name is subscribed to the written instrument, and acknowledge that she executed the
same for the purposes therein contained.
Notice is hereby given that the Plaintiff in the above matter, having been granted a fInal Decree of
Divorce, on the ~ day of jy (LaW ,2 ~ , hereby elects to retake
and hereafter use her previous name of Whitton, and gives this written notice avowing her intention in
acco ance with the provisions of 54 P~. .S.A. Section 704.
>/',
TO BE KNOWN AS:
Whitton
~OlUf 1;Q A~I?~~~,sC~D BE:O~ ME by ~e saj~
W'I '1U \.,.LNu 1icsv) j...iilnl rCf tU'-on thIS 1tJr'-
certifx which witness my hand and seal of office.
CJ)Qudo_ tt~
Notary Public, State of P A
Notary Seal
,~. ,ZCCJlDto
My commission expires:
'---I '- L/ -C) 9
NOTARIAl SEAl
CLAUDtA f BREWBAKER NOTARY PUBUC
Callisle Borv ..;umberland County
My wmrrnSSIOI. Expires April 4. 2009
c') ~
c c::> 0
=
~ ~~' Ci"' -n
~ ~ ~, .i-'-. C) -t
1 ~ rT1 -r-
~ -...j ~ rl1 ::D
\II , ;. C"i ,-
~ () c ;g8
~ CO
C'"'" ~
r-
-- :.:;,'
~ ~ :;;::::r.-~
......s ~ -"-
./
V\ ~ 9 >.J
~ ..-.::: ...... :L~
- :D
CJ'; .<
Aon,j 0 {. lu~,'fhM - c..."'VJ'gJ,OfY'l,
p/r;!'A f,.!f
]::"1/\ R ~o.M- of G-.."" pt"iLf,
C (J. ",,~'I' \<.Mp a..'I'1-~, {l"6ylJ 1.-.1 a.
&.It;.
NO,' 00 - 7(l(7
G\J ~ { ftu-tCfV'- - t,.,4OJ
'Y'^ 0 " 1I () J2.c -t-
~""..."'''{ u. G.Vl""~. ~~
~J~d~
A cc..epw (.. 0 ~ 5av,'c-e-
.-r:.. QCC~rf; 5e(ll/tG~ of. C@Wl{J~' UvJu ~!CfY\
3~ lCc) or 1k- Ol~ uo&( axle,
lJo.-/d: ! J /( f/ p-6
'"
=
<::::>
cy,
o
11
:::::!
-1__
IT1-'--
r-'
IT":
Q
D
(11
c-;;
co
:t:,..,
-,,.,,..
C)
(.11
W
. - . '\.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-Cunninlham
Case Number:()W- 1 ~l
Plaintiff
)
)
)
)
Judge:
v.
Sammuel J. CUDnin'irham
Defendant
)
)
)
)
AFFIDAVIT OF CONSENT (Plaintiff)
THE STATE OF: PA
COUNTY OF: Cumberland
I. A Complaint for Divo~ under Section 3301 (c) of the Divorce Code was filed on
U~ l~ , ~"(io .
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint for Divorce.
3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the
Decree of Divorce.
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.
2. I understand that I may lose rights concerning alimony, division of property, distribution of debts,
lawyer's fees, or expenses if! do not claim them before a Decree of Divorce is granted by the Court.
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 of Divorce 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
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
fJ?aYd1 / r 'I::J+
L.
,.., .~
~, i ~:n
~g~,., ~ ~~
Zt,. ',' .,... O~,b,'
Ct.:! ,j'....... --r .
=<'10': _ ::!;i
~':. ~ ~~
'Z,"-'; 9
5~ -:: ?n
~ ~ ~
i . "-'
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-CunniD2ham
Case Numbert:')(o-i (l.(,
Plaintiff
)
)
)
)
Judge:
v.
Defendant
)
)
)
)
Sammuel J. Cunninpham
AFFIDAVIT OF CONSENT (Defendant)
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
~rYlber I~ 'O{-()<o.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint for Divorce.
3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the
Decree of Divorce.
WAIVER OF NOTICE OF INTENTION TO
REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE.
I. 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, distribution of debts,
lawyer's fees, or expenses ifI do not claim them before a Decree of Divorce is granted by the Court.
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 of Divorce 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
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
,-'
2
~
:Y. (r;
~+~}
~"--.
m~T~
.<t;
~-.,
~~o
<..-
~g
~
~
:5
-:;1&.
~
.~
~~
11
~ ..~~
-0 ~B
:Jt(5.fl"\
- ~
:- ~
C1"
..- -.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Amijo L. Whitton-Cunniqham
)
)
)
Case Number: (')0- ,I ~ 7
Plaintiff
v.
)
Judge:
Sammuel J. CUmUnfham
)
)
)
)
Defendant
Praecipe to Transmit Record
To the Prothonotary:
Kindly Transmit the Record, together with the following information, the Court for entry of a
Decree of Divorce:
I. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and Manner of Service of the Complaint for Divorce:
Approximate date of service: De(.~ IIY\ LY'v IK~ C)('J::Ja.
Type of service: tQ personal or ( ) certified mail.
3. Complete Paragraph (a) or (b).
(a) date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the
Divorce Code: t:h...
By Plaintiff: !A~:ct l ~'UL\
By Defendant: I
, (1x I(
, riCin
(b) date of execution of the Affidavit /Consent Waiver required by Section 3301 (d) of the
Divorce Code:
By Plaintiff:
By Defendant:
4. Related Claims Pending: None.
Date: rno ft h / q t/iJ) ,3m 7
.l'\YY\ \~ 01 J.)'(1 (\;1 (Ji\ - ~il i Il'1 \,wnn
2ame (Plambff), \J · · I
- ti'/Jl2~ ~
Signa~ (Plaintiff) ,
Mailing Addresdll9 GraAl DR... c~~J ~~~~ Lane ~?A 17:>17
Phone: 814-553-3257 ' , tl
1;...... ""
0 ~ ~
~ =.3 ~~
,fi 'j :S
~~ ~
BC?
c -
tn.~; v::> ~~
~ ....
~c -0 ?'J5
~c) :s Zrtl
~; - 9
.. ~
C1'
:f.
:f.
ill
Of. Of.
~ IN THE COURT OF COMMON PLEAS
:f.
'"
'"
'"
'"
OF CUMBERLAND COUNTY
PENNA.
:f.
STATE OF
f1m-'jO l;.) nttfU'(\ -~V1 i:; 'm~
No.
C)to -11 u.l
!f.
!f.
Of.
!f.
!f.
!f.
:f.
!f.
!f.
VERSUS
SQJlV\\j\1\U (' \ b.VJ Iili ~hu ill
!f.
!f.
!f.
!f.
!f.
!f.
DECREE IN
DIVORCE
AND NOW, M7J LL ? \ , 2()07, IT IS ORDERED AND
DECREED THAT -Am,~() (vhrctrJV1- &v]trti~hqWJ . PLAINTIFF,
AND ~ \'V\\IVIUe r Glllil:JY10 L'Y) . DEFENDANT.
!f.
!f.
!f.
!f.
'"
;f.
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;
A TTES
'" !f.
!f.
Eli '" '"
Eli
!f.
Eli
'"
'" "''''''''''!f.''' !f.Eli
!f.:f.:f.:f. !f.
'"
'"
:f.
:f.
:f.
!f.
'"
'"
'"
!f.
'"
;f.
if.
Of.
J.
* -42 ~ ~~ c..c;r;r:e' [:,
~?~~-~ LO.'c"t--E
. ''I.. .
. .,." ~ ~,.
~ ,'Ir ... ~