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Home My WebLink About95-01374 ~ ~ - :3 -7 c o II) c '-5:J - '- ~ .-J . " .~-~'~~'-~~~~~~~--~----_Y~:~~:'~._~'-~'~~~~ ~ -- ~ ~ w ~.. '="' .', ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .. PENNA. .'. ~ ~ ',' .:.. ~ .', ~ " ...' 8 ~ JAMES C. WILKINSON, iI ! N (), ..,~,~,~,1?!,~.. ..,~,~~,~,~ 1995 . . . . _ . . . . .. . . . . .. .. i " ,', * ~ ',' .... ....... PLAINTIFF .', ~, V el':Hl~ MARIE F. WILKINSON, ~ ',' ......... .......... 1 $ ~ ,;, ., !' ~ DECREE IN ~ AND NOW, .~..~.~.~.~.~ 1~9.~. ~'d:~:~'1 : decreed that, , '" " "~,~~~~, ,~:, ~,I,~~~~,s,~~, , . " ", ,," ""'" plaintiff, and, " " " " '" , ., ", ,t:t~~,I,~, ~,', ,~~~~,I,~~?~, " " , '" ,"",' " defendant, are divorced from the bonds of matrimony, DEFENDANT ,'. ~ .' w ',' s ~ ',' ~ ',' ~ ,; ~ ',' " ~ ~ ,,' ~ ~ ',' $ .~ ~ ,', ~ ~ .... 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 8 M ,,' ~ " ~ ,,' w ., .... ,................ .... .... ,.. .... ...... .... ............ rFP 4l3SCO Due (l,tltt!y v. ~.' I · ,y.,u,,"Wf<l'-<. [', k)<!.~ ,e..~~' Au" 0J.~;"4 k" ~,~ . F If -7 "'~~notnry ~ .. .. ~ .:.:. .:.:. .:+:. .:.:. .:.:. .:+;. .:+:. .:.:. .:+:. .:+:.' ~ ',' ~ ,'. * ~ g $ " " ~ ~ ~ t;~ .'. * ,;, ., v. ~.~ $ w ~~ .'~ ~ ~ ',' ~ ~.' v. ... v. ... ~ ',' ~ ~ '.' $ ,'. ~ $ ~ ',' ~ ~ '. JAMES C. WILKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. MARIE FAYE WILKINSON, Defendant : NO. 95-1374 CIVIL 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 Section 3301(d) of the Divorce Code. 2. Date and manner of service c,f the complaint: served on March 28, 1995, United States mail, certified, restricted delivery, return receipt requested, postage pre-paid. 3. Date of execution of the Plaintifrs Affidavit required by Section 3301(d) of the Divorce Code: March 16, 1995; Date of service of the Plaintifrs Affidavit upon the Defendant: March 28, 1995. 4. Related claims pending: none. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: United States mail, certified, restricted delivery, return receipt requested, postage prepaid, this 22nd day of May, 1995. Date &,-/5-95 ~d~~ Tina Si pson Student ~;'ML- THOMAS M. PLACE Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 '-,~ c' ~~ ,~ ... 1"'1 ~~.5;~-: ~.- ';::!:r. '., ,~~ :~-~ ~ :; r; r< ....l i,~ .,r.... _~ 1.- -<"" .~ ~ z: en w U1 en -0 ::J: - c.c c.n JAMES C. WILKINSON, Plainitiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. MARIE FAYE WILKINSON, Defendant : NO. 95- CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the aIlegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE 1. The parties to this action separated July 1989 and have continued to live separate and apart for a period of at least 5 years. 2. The marriage is irretrievably broken. 3. 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. 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 3 /;t;/C; S- /7 '1"' lie? ~. ./ ,4 '1 1/ J .: ,,- /. . ' (// p.\/ I { 11/ .''0, 've't ....... /'James C. WilkInson JAMES C. WILKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARE FAYE WILKINSON, Defendant : NO. 95- CIVIL TERM ATTORNEY'S AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I, Tina Simpson, of the Family Law Clinic, attorney for the party petitioning to proceed in forma pauperis, certify that I believe petitioner is unable to pay the costs of instituting this action and that I am providing free legal service to petitioner. Plaintifrs Affidavit showing inability to pay the costs of litigation is attached hereto. Date ,3 - J~, - clb ."J~~h"_nJ"')'_) Tina Simpson 1 Student Attorney /}lnh 1l-,tJ- THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney THOMAS L. PEELER Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 '. JAMES C. WILKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : NO. 95- CIVIL TERM v. MARIE FAYE WILKINSON, Defendant AFFIDAVIT SUPPORTING PETITION FOR LEAYE TO PROCEED INFORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The Petitioner, James C. Wilkinson, currently incarcerated at the Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, PA 17013, upon his oath deposes and says: 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. . 3. This affidavit is made to inform the court as to my status of indigency and to induce the court to grant me leave to proceed in this cause as an indigent. 4, In making this affidavit, I am aware that perjury is a felony and that the punishment is a fine of not more than $3,000 or imprisonment for not more than seven years or both. 5. I do not have any money on my person, at home, or elsewhere which could be used for the expenses of this proceeding. 6. I do not own real estate, personal property, or any other assets. I am not owed any amounts of money by any person. 7. I represent that the information below relating to my ability to pay the fees and - ...;.~~. costs is true and correct. (a) Name: James C. Wilkinson Address: currently incarcerated at the Cumberland County Prison, Carlisle, Pennsylvania 17013 Social Security No.: 184-48-3756 (b) Employment If you are presently employed, state Employer: N/A Address: N/A Salary or wages per month: N/A Type of work: N/A If you are presently unemployed, state Date of last employment: 1993 Salary or wages per month: $680.00 Type of work: Stock person (c) Other income within the past twelve months Business or profession: NI A Other self-employment: N/A Interest: N/A Dividends: N/A Pension and annuities: NI A Social security benefits: N/A Support payments: N/A Disability payments: N/A Unemployment compensation and supplemental benefits: N/A Workman's compensation: N/A Public Assistance: N/A Other: NI A (d) Other contributions to household support Name: N/A Employer: N/A Salary or wages per month: N/A Type of work: N/A Contributions from children: NONE Contributions from parents: NONE Other contributions: NONE (e) Property owned Cash: NONE Checking account: NONE Savings account: NONE Certificates of deposit: NONE Real estate (including home): NONE Motor vehicle: NONE Cost , Amount Owed $ Stocks; bonds: NONE '. JAMES C. WILKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA v. : CIVIL ACTION. LAW : IN DIVORCE MARIE FAYE WILKINSON, Defendant : NO. 95-1374 CIVIL TERM CERTIFICATE OF SERVICE I, Tina Simpson. Student Attorney, of the Family Law Clinic, hereby certify that I have served a true and correct copy of said Divorce Complaint on the defendant Marie Faye Wilkinson, residing at 67 West North Street, Carlisle, Pennsylvania 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid, this 24th day of March, 1995. \.)IJ'tL... (n'I))~l ,_: Tina Simpson' Student Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 / JAMES C. WILKINSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MARIE FAYE WILKINSON, Defendant : NO. 95-1374 CIVIL TERM CERTIFICATE OF SERVICE I, Tina Simpson, Student Attorney, of the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Notice Of Intention To Request Entry Of Divorce Decree and a Defendant's Counter-Affidavit Under Section 3301(d) Of the Divorce Code on the defendant Marie Faye Wilkinson, at 67 West North Street, Carlisle, PA by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid, this 5th day of May, 1995. c' Vl/l1tl-:.V L~-- n" Co - ~ Tina Simpson' Student Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 = .'., .... -< c...u = , j.. ..~;:;;:;' :.r:-l - ~ .... -< ~. -: 'J1 W -0 ::J: - c.c c.n