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JAMES FREDERICK DAVIES,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
VS.
JUDITH GRISWOLD DAVIES,
Defendant
NO. 95-1852
CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following Information to the courl for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under ~3301 (c)
lGOOt~~jN~H:DNocOlKlllOldIK
(Strike out Inapplicable section).
2. Date and manner of service of the complaint: See attached copy of Defendant's
Affidavit of Consent Fnllnwin') ser"ice of COlllpl.aJ.nt,-dQf.Qrn;tant filga an
Answer on August 29, 1995.
3. Complete either paragraph (a) or (b).
(a) Date of execullon of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plalnllH nq / nl/99 : by defendant 08/02/ qq
. .
(b) (1) Date of execullon of the affidavit required by ~3301(d)
of the Divorce Code:
(2) Date of filing and service of the plalntlff'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 Inlenllon to file praecipe to transmit record, a
copy of which Is atlached:
(b) Date of plalnllff's Waiver of Notice In ~3301 (c) Divorce was flied with
the Prolhonotary: 0 9/1 5/99
Date defendant's Waiver of Notice In ~3301 (c) Divorce was flied with
Ihe Prothonolary: n q ! n 1 ! q CI
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JAMES FREDERICK DAVIES
Plaintiff
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ci6 - 18'3.J. c",~c.) -[re",
CIVIL ACTION-DIVORCE
.
vs.
.
.
JUDITH GRISWALD DAVIES
Defendant
.
.
COMPLAINT
1. The plaintiff is James Frederick Davies residing at 400
Orchard Lane, Mechanicsbur~, Cumberland County, Pennsylvania 17055.
2. The defendant is Judith Griswald Davies residing at 4216
Sunnyside Drive, takeland, Polk County, Florida 33809.
3. James F. Davies has been a bona fide resident of the
Commonwealth of Pennsylvania since Auv,ust 2, 1994.
4. Judith G. Davies has been a bona fide resident of the state
of Florida since August 5, 1994.
5. The plBlntiff and the defendant were married on March 2). 1974
at Clearwater, Pinellas County, Florida.
6. There has been prior action of divorce on,September ;0, 1992
which was not carried through. periods of separation occured in
1975, 1979, 1990, 1992-93 and 199~-95.
7. There is serious marital discord adversely affecting the
attitude of one or both of the parties toward the marria~e and
all attempts at counselin~ and/or reconciliation have failed.
8. The ~rounds for this divorce i8 no fault and the marriage i8
irretrievably broken.
9. The plaintiff requests the Court to enter a Decree of Divorce.
Wherefore, the plaintiff prays that a Decree in Divorce be
entered divorcing Plaintiff from the bonds of matrimony heretofore
existing between Plaintiff and Defendant.
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JAMES FREDERICK DAVIES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-1852
JUDITH GRISWOLD DAVIES,
Defendant
: IN - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER ~ 3301(0) 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,
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 unlll a divorce decree Is entered by
the Court and that a copy of the decree will be sent to me Immediately after It Is tiled with
the Prothonotary.
I verity 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: qj, /4 '1
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JAMES FREDERICK DAVIES, Plaintiff
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JAMES F. DAVIES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION. LAW
JUDITH G. DAVIES,
Defendant
NO. 95-1852 CIVIL TERM
ORDER OF CO! JRT
AND NOW, this 27th day ofOctobcr, 1998, upon considcration of Pia intiIT's Motion
to Petition This Casc From Being Purged, it is ordered that
(I) a rulc is issued upon Defendant to show cause, if any she has, why Plaintiff is not
entitled to the relief requested;
(2) Defendant shall file an answer to the petition within 21 days ofthis date;
(3) the Petition shall be decided undcr Pa. R.C.p. 206.7;
(4) depositions shall be completed within 35 days ofthis date;
(5) argument shall be hcld on Friday, Fcbruary 12, 1999. at 3: 15 p.m., in Courtroom
No. I, Cumbcrland County Courthouse, Carlisle, Pcnnsylvania; and
(6) notice ofthe entry ofthis order shall be provided to all parties by Plaintiff.
BY THE COURT.
J. Wcsl
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.JAMES F. DAVIES
Plnintiff
vs.
JUDITH G. DAVIES
Defendnnt
IN TilE COURT OF COMMON
PLEAS OF CLlMBEHLANI)
COUNTY, I)I~NNSYL VANIA
CASE 95-1852 CIVIL
DIVORCE
MOTION TO PETITION THIS CASE FHOM BEING
PURGED.
AND NOW, this 27th dny of October , 1998, in responsc 10 the delendanl's
counter complaint for divorce. The issue has bccn rcsolvcd and the divorcc will
be final within ninety (90) days,
FOR TilE COURT,
BY; .IAMI~S F,I>'~.IEI':~~, I~\INTIFF
~'I~...i!.'
CC: DEFENDANT
COURT OF COMMON PLEAS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
JAMES FREDERICK DAVIES,
Husband,
and
JUDITH GRISWOLD DAVIES,
Wife.
CASE NO. 95-1852-CIVIL
I
RESPONS~ TO COMPLAINT
COMES NOW, Wife, JUDITH GRISWOLD DAVIES, pro se, and files
this her Response to
alleges:
1. Admi t .
2 . Admi t .
3 . Admit.
4. Admit.
S . Admi t .
6 . Admit.
7 . Admit.
S . Admit.
9 . Admit.
the Husband's Complaint for Divorce and
.;
WHEREFORE, Wife having fully responded to the Husband's
Complaint prays that all relief sought by the Husband be denied
save and except that which is admitted by Wife.
COUNTER-COMPLAINT FOR DIVORCE
COMES NOW, Wife, JUDITH GRISWALD DAVIES, pro se, and files
this her Counter-Complaint for Divorce and alleges:
,
1. This is a Counter-Complaint for Divorce.
2. The Wife has been a continuous resident of the State of
Florida for more than six months prior to the filing of this
Petition. The Husband has been a continuous resident of the State
of Pennsylvania since the filing of this Petition.
3. The Parties were married to each other on March 23, 1974
in Clearwater, Florida and resided together as Husband and Wife
until their final separation. The Parties are no longer residing
together as Husband and Wife.
4. The marriage of the Parties is irretrievably broken.
5. There have been three children born of the marriage, to-
wit: ZACHARY JASON DAVIES age 17, PAUL JORDAN DAVIES age 14 and
EVAN JAMES DAVIES age 12. The children are presently residing with
the Husband.
6. The Wife is entitled to and should receive visitation with
the minor children. In that the children reside in the State of
Pennsylvania, the Wife requests that she be awarded visitation with
,
the children at least six weeks during the summer and one week
during Christmas and one week during the Easter vacation.
7. The Wife would affirmatively state that she is paying the
sum of $190.00 per month for the support of the oldest child,
ZACHARY in order for this child to complete high school in the
State of Maryland. The child is residing with friends in order to
finish high school and the mother is sending support to the child.
8. There is an order of Custody on the above styled cause of
action, wherein the Parties agreed that the two youngest children
would remain with the Husband and the oldest child would reside
with friends in order to complete school in Maryland.
9. The Wife would state that she currently has medical and
dental insurance for the benefit of the Parties' minor children and
will continue to agree to maintain medical and dental insurance.
Each Party should be equally responsible for all unpaid medical
expenses not provided by said insurance.
10. The Wife is in need of and the Husband has the ability to
pay alimony to the Wife in the amount of $200.00 per month. The
Wife is in need of returning to school to further her education in
order to properly support herself as she has become accustomed to
during the course of the marriage.
WHEREFORE, Wife prays that this Court will enter an Order
that:
1. Dissolves the marriage of the Parties.
2. Awards the Wife the sum of $200.00 per month as
rehabilitative and permanent alimony.
3. Awards the Parties Shared Parental Responsibility of their
minor children, and awarding the Wife visitation with the children
as outlined above.
4. Orders the Wife to continue to provide medical and dental
insurance for the benefit of the Parties' minor children. Each
Party should be equally responsible for all unpaid medical and
dental expenses incurred for the benefit of the children.
5. For such further and different relief as the Court deems
fair and equitable.
/,
JAMES FREDERICK DAVIES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
JUDITH GRISWALD DAVIES,
Defendant 95-1852 CIVIL TERM
IN RE: PURGE LIST
ORDER OF COURT
AND NOW, this 27th day of October, 1998, upon
consideration of the purge list and the Plaintiff, James
Frederick Davies, having appeared in court and indicated that he
was unfamiliar with the new rule regarding presentation of a
petition with proposed rule to show cause in connection with the
purge list, and that he does intend to file such a petition,
this case will not be purged at this time if the Plaintiff does
file a petition in accordance with Cumberland County Rule of
on today's date.
Procedure 228 and proposed rule to show cause before 3:00 p.m.
By the court,
J
James Frederick Davies, Pro se
Plaintiff, Pro Se
Judith Griswnld Davies
Defendant, Pro Se
Court Administrator's Office
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..' JAMES F. DAVIES,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JUDITH G. DAVIES,
Defendant
No. 95-1852 CIVIL TERM
ORDER OF COURT
AND NOW, this 12th day of February, 1999, upon
consideration of plaintiff's Motion To petition This Case From
Being Purged, and it appearing that no answer was filed to the
Motion or RUle To Show Cause issued by the Court on october 27,
1998, and neither party having appeared in person or through
counsel for the argument on the matter, the Rule To Show Cause
so issued is made absolute, the case is stricken from the purge
list, and the matter shall proceed as an active case.
By the Court,
JAMES F. DAVIES, PRO SE
400 orchard Lane
Mechanicsburg, PA 17055
Plaintiff
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JUDITH G. DAVIES, PRO SE
4216 sunnyside Drive
Lakeland, FL 33809
Defendant
Court Administrator
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