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HomeMy WebLinkAbout94-00924 \..0 Q) d - o 3 \., cV ~ - o 3 , , ,......~ _~__..__..__.__.w.., .~. _. ,... .~. ....,...' ..... ......~.....r..~~....~...~..~........~.~~ . ,..or.' .~...: '..__ _- ....... ......... .-.. ,'..-- '--, '--. --- ..... ".._' ....... ..-' .....,... .....,.. .""'.. .....,.. ....,.. ~,_._..--""....--..'..""",.....---.'..--,..--,....--......~ e - . ~ ~ . ~ ~ ; IN THE COURT OF COMMON PLEAS : $ ~ ~ ,> ~ ~ ~ s ~ ~ V. !.' OF CUMBERLAND COUNTY STATE OF '* PENNA. ........~IE~.wouWER." ............. II I, ... .... ..Plaint.ifL..........1 II N ( ), ......~,?!!........... ......9.~1dJ 19 94 ,', ~ $ .', ~ ~ $ 8 $ a ~~ ,.~ ~ ~ $ e !~. ~ ~ ~ ~ $ :; w ~~ ~.~ ~ ~ ~.~ ~ ~ ',' .' ~ ~ ',' ~ '.' ~ ~ ',' ~ ',' :,tr/~:?;~Ih..~,,~';7"J: ,1 / ...,,-/ 1'..:' ~': 14 k' ~ 1':' ~ ~ .~ X2P7 . . P~olho~olary 'I':c! ~ S ~ '.._ _ _._ .. _. _ ...... 'II 't~.....-.-~~_......__ ...--..~_ ____.....---.-.___._ .__. ~""' _'.. _'~_ ~ ~ -'.-' .,......._....___.. ...-...... _ -~-......... .-__., .', ......_--. . .... . ~ ~ ._~~~***~*_*_~~_~~_**_*_*__ro~~~. VCl'SlIS Ii :1 ...,....... \1 II .. SJ:J:.YE R... \,UlAVER, e e 8 ~ ;;, P,i ~ " Defendant. DECREE IN DIVORCE ~ ..; ~ ~ ~ ~ ~ $ ~.~ ~ ~ t ... AND NOW, ' .. hJgust ...., {,4::.. .. .., " 19,94.." it is ordered and decreed that", ,AlI1P;'~, f,.. Wplll.v~r". ,." """"""""""" plaintiff, and" ",St.eve ,R. ,Wolaver", , " ,,' , " " , , , , ,',' . , , " , ., ,,' , '" 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; None .......... ...... ,... ................ ......................................, s V. ~.4 . ...... ...... ...... .................................. ... ~ ,', ~ ~ ~ "~"'-"""'*"-" '-'; - ,'-';"-"..', t t t i i IK 1'1 I, I ~ i'i II 1;1 !, 71Htie /JY~ 8"~~tfY CONNIE F. OOUVER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 924 CIVIL 19 94 STEVE R. OOLAVER, Defendant PRABCrPB TO TRANSMrT RBCORD 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 Section 3301 (c) lIZOCk~dllXO<:k"x of the Divorce Code. inapplicable section.) 2 . Date and manner of service of the complaint: by Sheriff I s service at Landis Inc. Mt. Hollv Sorim!s. PA. on March 9. 1994 (strike out 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: Plaintiff: 8-4-94 ; by Defendant 7-25-94 by the . (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: N/A . (2) Date of service of the Plaintiff's affidavit upon the Defendant: N/A 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301(d) (1) () of the Divorce Code. N/A Bradley L. Griffie, "::P en - ::0:: -=0: .:3' N O":l - ~ ::. .... >-... :,-;... ~" ~ t.J(,)~'~ ~~~.r. l6..0 ..t .4 XO,:~ ~,.' ~.- "r. . ; _ ...;>- -.:;:.~ .,.., ;:..r..:~ '-'; 4, or:. LC'1hJ t.~'" ...'" 0'-' ./"'\ 1 11 - ~~ ~ _. ~: . " 0'> rr.. ~ ~ C') :. boo r<'I :r '::",) \/\ '-9 ~ ~ .,J 'J .... "" I, "" 'i "'It .'''' " -- *- ~ l,j , f5 """;3 I' -1 ...... ~ ~ tL. O;::i ~~ Il<~ ~ en Zffi ~ .... w .. .... .... ~ ~ ~Il< ~ .,.j J ~ 0 tL.~~~~ .... Q - ~ ... fI1 .. N ~c U .. III - .. " ~;g z o oJ a 0 a - o l...l H en .:. t.I ~ ~ < ~~ " III a. ~8i5~ ;::Sll< ~ en 1 ~ <( g ~ ci <( .. z a. ~ ~.. . .. .. a 8~HU~ ~ ~~J:~ .. :f: ~ ~ - " ~;tc:: . . a: % ~ ~ X .. ~ W 0 ... .... III ~ a ~~~~~ tL. _ ... a a: a .. . l&. :c 0 ,j o " ~ c:: Z I ~ l&. Z ~ it 8 .. .. _ x Huu2~ (!) N U CONNIE F. WOLAVER, . IN THE COURT OF COMMON PLEAS OF . plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . v. . CIVIL ACTION - LAW . : q~~ STEVE R. WOLAVER, . NO. CIVIL 1994 . 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 will proceed without you and a decree in 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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. Court Administrator Fourth Floor Cumberland county Courthouse Carlisle, Pennsylvania 17013 '-'t,~o/ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No.9,). 't CIVIL 1994 IN DIVORCE CONNIE F. WOLAVER, plaintiff STEVE R. WOLAVER, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Connie F. Wolaver, an adult individual currently residing at 2149 Newville Road, Carlisle, Cumberland county, Pennsylvania. Ms. Wolaver has resided at said address since April, 1986. 2. Defendant is Steve R. Wolaver, an adult individual currently residing at 2149 Newville Road, Carlisle, Cumberland County, Pennsylvania. since March, 1989. 3. Plaintiff is a bonafide resident of the Commonwealth of Mr. Wolaver has resided at said address Pennsylvania and has been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on March 17, 1989, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United states of America or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. - (~' ....-:-':' 8. Plaintiff and Defendant are citizens of the United states of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that Defendant will, ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. section 330l(c). COUNT II INDIGNITIES 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent injured spouse, as to make his condition intolerable and life burdensome. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. 330l(a)(6) of the Divorce Code of 1980, as amended. Respectfully submitted, GRIFFIE & ASSOCIATES L. Griffie orth Hanover Carlisle, PA 1701 (717) 243 - 5551 1-800-347-5552 I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: .2.-,25-'1'1 ~~~ CONNIE F. WOLAVER, Plaintiff SHERIFF'S RETURN CCM-lONWEAL'I1I OF PENNSYLVANIA. COUNl'Y OF CLMBERLAND In The Court of Common Pleas of Cumberland County, Pennsylvania No. 924 Civil Term 1994 Complaint in Divorce and Notice Connie F. Wolaver VS Steve R. Wolaver Dav id Rudv , ~ll41WXR41 Deputy Sheriff of ClInberland County, Pennsylvania, who being duly sworn according to law, says, that he served the within Complaint in Divor~p ~n~ Nn~i~p upon Steve R. Wolaver , the defendant, at l\.c;C; o'clock p.M. EST / ~KR. on the day of M;:Ir~h , 19-441t 09 rAnn~a Tn~ r Mt Hnlly ~pr;nQR , Cunberland County, Pennsylvania, by handing to St..v.. Wol aver a true and attested copy of the Comalain t in Divorce and Notice and at the same time directing his attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs. Docketing Service Affidavit Surcharge 14.00 3.92 ?~~~ 2.00 19.92 Pd. by Atty. 3-11-94 R, Th1S Kline, Sheriff 1/ /7 by , I ~-./ litH /)~ // DeputY S fiff Sworn and subscribed to before rre this / l' ~ day of )h .... -<-1..../ 19 ''''1-- A.D. \....t,.. C.Jlto....(....... ,1C"lij' l / 'I Prothonotary STEVE R, WOLAVER, Defendant IN DIVORCE 6113.pral.. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PBNNSYLV ANIA CIVIL ACTION. LAW NO. 924 CIVIL 1994 CONNIE R, WOLAVER, Plaintiff PRAECIPE FOR BILL OF PARTICULARS TO THE PROTHONOTARY: Enter a rule on Plaintiff to file a Bill of Particulars within twenty (20) days after service of the rule, or suffer judgment of non pros. MARTSON, DEARDORFF. WILLIAMS & OTIO By 1"~~9 bvJt.~ Thomas J. Williams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: March 16, 1994 RULE AND NOW, this Uiday of 111a'I.cJ.., 1994, a Rule is issued upon the Plaintiff to file a Bill of Particulars within twenty (20) days from service hereof or suffer judgment of non pros. ~L<[i,~ Yh (O/IAt~l ~k-IJ" P , thonotary , CBRTIFlCA TE OF SERVICB I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Bradley L. Griffie, Esquire Bradley L. Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 MARTSON, DEARDORFF, WILUAMS & OTIO BY',e~.:u. W~~" Thomas J, 'iams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: March 16, 1994 6213~om.uu1.. CONNIE F, WOLAVER, Plaintiff IN TIm COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PBNNSYLV ANIA CIVIL ACTION . LAW v, NO. 924 CIVIL 1994 STEVE R, WOLAVER, Defendant IN DIVORCE ANSWER AND NOW, comes the Defendant. Steve R. Wolaver, by his attorneys MARTSON, DEARDORFF, WILliAMS & OlTO, and avers as follows in answer to Plaintifrs Complaint in Divorce. I. Admitted. 2, Denied as stated. Defendant previously resided at 2149 Newville Road, Carlisle, Cumberland County, Pennsylvania, but presently has no pennanent address. 3. Admitted. 4. Admitted. S. Admitted, 6. Admitted. 7. Defendant demands marriage counseling in accordance with the Pennsylvania Divorce Code, as amended. 8. Admitted. 9. Denied. Defendant believes this marriage can be saved with proper counseling and mutual good will on the part of both parties. 10. Denied. At the present time, Defendant does not consent to a divorce, WHEREFORE, Defendant demands that Plaintifrs Complaint be dismissed with prejudice. COUNT II INDIGNITIES 11. Paragraphs I through 10 hereof are incorporated herein by reference thereto. 12. Denied that Defendant ever committed indignities upon the person of Plaintiff, Further denied that Plaintiff was the innocent or injured spouse. Further denied that Plaintifrs condition is intolerable and life burdensome. , ~..,_.--...;..:,._^ WHEREFORE, Defendant demands the Plaintiffs Complaint be dismissed with prejudice. COUNT m COTTNTERCLAIM FOR EOllITABLB Dl~TRmlmON OF MARITAL PROPERTY 13, The Plaintiff in Counterclaim, Steve R. Wolaver, incorporates by reference paragraphs 1 through 12 hereof as though fully set forth herein. 14. Plaintiff in Counterclaim, Steve R, Wolaver. and Defendant in Counterclaim, Connie F, Wolaver, have acquired property, both real and personal, during their marriage, WHEREFORE, Plaintiff in Counterclaim, Steve R. Wolaver, requests this Honorable Court to detennine marital property and to order an equitable distribution thereof pursuant to 23 Pa, C,S, ~3502, COUNT IV COUNTERCLAIM FOR COUNSEUNG 15, The Plaintiff in Counterclaim, Steve R. Wolaver, incorporates by reference paragraphs 1 through 14 hereof as though fully set forth herein. 16. The marriage is not irretrievably broken. WHEREFORE, Defendant requests a maximum of three counselling sessions pursuant to 23 Pa, C,S. ~3302. Respectfully submitted, MARTSON, DEARDORFF. WlWAMS & OTIO By r-; ~~~ wJ.tCA. -.ov'\ Thomas J, WiI iams, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Date: March 16, 1994 s..~..., Ii, LJoP~ Steve R, Wolaver - VERIFICATION The foregoing Answer and Counterclaim is based upon infonnation which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon infonnation which I have given to my counsel, it is tme and correct to the best of my knowledge, infonnation and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Fa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false avennents, I may be subject to criminal penalties. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer and Counterclaim wa:; selVed this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Bradley L, Griffie, Esquire Bradley L. Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 MARTSON, DEARDORFF, WILUAMS & O'ITO By (~cW-2 ~4--~- Thomas J. Wi lams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: March 16, 1994 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 924 CIVIL 1994 IN DIVORCE CONNIE F. WOLAVER, plaintiff STEVE R. WOLAVER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 28, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4!;, I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: 12u.Jd c; 111ft! ~:r. w~ ~ CONNIE F. WOLAVER, plaintiff d!; >-.. ""... \ - :!:r. .., =-= Wn;:)_ ..... OZOzo en W:o(,);! C\/ 4..~~:... !:::::! -? c...:n ..:)~y.-'z _I". a;z' 1UL..JW Ln .. ....c:,'j~ t:~: ::> c:t ~(.) => ex . '" , . .. CONNIE F. WOLAVER, , IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . CIVIL ACTION - LAW . . . STEVE R. WOLAVER, . NO. 924 CIVIL 1994 . Defendant . IN DIVORCE . APPIDAVIT OP CONSENT 1. A complaint in Divorce under section 3301 (c) of the Divorce Code was filed on February 28, 1994. 2. . The marriage of Plaintiff and Defendant is irretrievably broken -and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. ~ (I-L~ STEVE R. WOLAVER, Defendant DATE: ., - ? ..,- -9,r/ .- 6; - >-... ~o- ,...~... Wc.~.~... Uzc.tz ~ou:c ~..=~~ ~~~~ ,.I..'''f~ '....r~ ;r. ..J'il..u ~r~n. :,;, ~'" "0> iE ... o M l'?1 <.:> =>- - , . ... CONNIE F. WOLAVER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTION - LAW . . NO. 924 CIVIL 1994 . STEVE R. WOLAVER, . . Defendant IN DIVORCE NOTICB OP ELECTION TO RETAKB FORMER NAME Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in Divorce from the bonds of matrimony on the 16th day of August, 1994, hereby elects to retake and hereafter use her previous name of Connie Faye Lehman. (? ~-L- 7a...Ei.t- ~'-'''A / CONNIE FAYE WO VER &.~ .-, ~..Ii'm<<IJ CONNIE FAYE~ COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND On the d/..,r day of ; a-'LL , 1995, before a Notary Public, personally appeared Connie Faye Wolaver, now known as Connie Faye Lehman, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. '--';?~JI~ irdN-irf.U Notary P ic NolBriBI SOBI Robin J. Goshom, Notary Public CBr1IB1B BolO, CumbBriBn~ CounlV My CommlB8lon ExplrBsAprll 17,11199 ,'... .""".... .-....~-'/ ,j ~ '" .. ~ ~ - ~ ....'T Q .., S? ;. ~~c I.., j...,~'" ~p,; '~I t.... ci~.:r ;::;-;: ..-~ -J ;,. .: ~.. .u ~ ~ ..., >'. ~.,. 1/,,,- I ?; i,l '::"