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HomeMy WebLinkAbout02-4168 SARA LESLIE WILLS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 .. 411.f CIVIL TERM MICHAEL A. WILLS, Defendant LAW - 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 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 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, First Floor, Carlisle, Pennsylvania 17013, Telephone: (717)-240- 6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717)-249-3166 SARA LESLIE WILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2002 - 'III.J> CIVIL TERM MICHAEL A. WILLS, Defendant LAW - DIVORCE COMPLAINT The plaintiff by her attorney, MURREL R. WALTERS, III, ESQUIRE, brings this action in divorce for a Decree of Divorce from the bonds of matrimony and respectfully represents: 1. The plaintiff is SARA LESLIE WILLS, an adult individual, who currently resides at 64 W. Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. The defendant is MICHAEL A. WILLS, an adult individual, who currently resides in the Borough of New Cumberland, Cumberland County, Pennsylvania and who maintains a mailing address as P.O. Box 1011, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on November 16, 1985. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The plaintiff avers that the marriage is irretrievably broken. 7. The plaintiff- requests the Court to enter a Decree of Divorce. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, plaintiff does not request that the court require the parties to participate in counseling prior to a Divorce Decree being handed down by the court. WHEREFORE, the Plaintiff prays that a Decree in Divorce be entered divorcing Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant. Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E. Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No. 24849 VERIFICATION I, SARA LESLIE WILLS, verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. :Sili/1.('~ r&{~j~ L.I.; JJ~ S LE WILLS ~ (:) -ig, 0 C" !::~ .......J ~ ~ :s. c....) "'TJu ,.,., a-Iii u .V? 2:::::, I 0?' (..L ..... ~ e .( 10 r::c. ;D>.. -0 ~ ~(;, :::Ii: ~2~':; "'-c ~ 5' ; 0) c: p:! ~ ~'-...) 5J t1'l -< ~ '--< SARA LESLIE WILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBER~) COUNTY, PENNSYLVANIA vs. NO, 2002-04168 CIVIL TERM MICHAEL A, WILLS, Defendant LAW - DIVORCE AFFIDAVIT OF SERVICE I, MURREL R. WALTERS, III, ESQUIRE, being duly sworn according to law, depose and say that on September 11, 2002, I mailed by certified mail, restricted delivery, a true copy of the Divorce Complaint filed by SARAH LESLIE WILLS, to the defendant, MICHAEL A, WILLS. A receipt was returned to me, which indicates that the Complaint was received by MICHAEL A, Date: ( 'L(2 ~ t2- / ember 14, 2002. Said receipt Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E. Main Street Mechanicsburq. PA 17055 ,. . Complete items 1, 2, and 3. Also complete iten.:...4 if Ri."'Stricted Delivery is desired. . Print you"",,ame and address on the reverse so that we can return the carp to you. . Attach this card to the back of the mail piece, or (i)n the front if space permits. 1. Article Addressed to: ~a.w~ ?:t>. B~ JOIl ~~IxJ' p~ .: . {'7055 2. Article Number (Copy from service label) 7000 ()(;;,oo 00;)5 3CJ yo 700 I PS Form 3811 , July 1999 Domestic Return Receipt t 02595-00.M-09!i2 .n c -? :> -00:' mp' z::r:: ......,..(- ,~ ):>c ~ o (" c::J r1"'\ C'? W o -n -n :;P w'-'lm )::;J ..~6 c:)t~ ~_")i "\1 ~ j:l ~ ""':';::'" N .. .,-J ) ) SARA LESLIE WILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2002 CIVIL TERM MICHAEL A. WILLS, Defendant LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on September 3, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 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. ,~bJo~ 6~~ (~~j.J~ S LES WILLS - Date: b c: s: -OeG mr';"! 2:n ~~i: -<~.. ~c t; :==< >?; ~ o N t::J r>1 ("'") W (") ~. -n i:'''::::::" -~2~ ~-o~! M ....,,-\t t, ~;J ~;""l: =< -:) ~ ():) SARA LESLIE WILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 2002-04168 CIVIL TERM MICHAEL A, WILLS Defendant LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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, lawyer's fees or expenses if I do not claim them before a decree 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, I understand 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. !!i 4904 relating to unsworn falsification to authorities. Date: 10l1;t 11 0 '^ .6~ iPF~ 0..,;11-../ S LESL WILLS (') c: s: '"Om q;J rn ......:n :Z:C ~:~:: kC ~""Cj ~c:) C 'Z :;:i .... o N o i"1 n w o "1'1 ~::J r,l~:J I": t~g -~() ~~~ s! :t! ...-.(~ v ::1:: N ~-J SARA LESLIE WILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 2002-04168 CIVIL TERM MICHAEL A. WILLS, Defendant LAW - DIVORCE AFFIDAVIT OF CONSENT 1, A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on September 3, 2002.. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 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. I d- te::J '0 2 Date: , (") C> 0 e- N -n -;;: CJ ::s... -OU i"'1 92E-' n _1. W ZC' (f) .'T?; -<L~ !;:C -0 )>C' -~- Zo N )>C Z ~ k...J SARA LESLIE WILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2002-04168 CIVIL TERM MICHAEL A. WILLS, Defendant LAW - DIVORCE WAIVER OF NOTICE OF INTENTION 'TO REQUEST ENTRY OF A DIVORCE DECREE UNDER I 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, lawyer's fees or expenses if I do not claim them before a decree 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. I understand 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: 'I ~ (:J.7/o~ ~//' .~.~ SARAH LESLIE WILtS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 2002--04168 CIVIL TERM MICHAEL A. WILLS, Defendant LAW - DIVORCE 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 ~3301(c) of the Divorce Code. 2 . Date and manner of service of the complaint: Complaint served by Certified Mail, Return Receipt Requested on September 14, 2002. Copy of receipt attached. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:: by plaintiff December 27, 2002, by defendant December 27, 2002. (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: December 27, 2002; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: December 27, 2002. 4. Related claims pending: None. --" 5. Complete either (a) or (b). (a) Date and manner of servi.ce of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: December 27, 2002. Date defendant's Waiver of Notice in ~3301(c) was filed with the Prothonotary: December 27, 2002. Dated: J~/~l)01, Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E, Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No, 24849 - 0 co) . \ Q) Cli V\, l!! lil 11\ Q) :g. Q > d ~ . 'iij \' Q) 5E .~ - (.) "0 -5 ~ Q) ~~ c:.9= . <(.~ ~"E-o~ l~ ("j ~l{l ~~ E J "Q)....Q)1tIQ) -- c: .;<: :g ~..c a. -- ltImltl-Q)Q) . C N'O"E:516 d -- ~ ~ i ffi- -m .9--.~ B cnoQ)a.;.."C~ al 6 ~ ~E~liiffi1:: III :t::,tetO~e ~ Cl $~::l~:E~ '0 - '0 Q).- 0 -'~ <( () a.""" >-t;:i.c..... Ql ?: E.=t:516l5 u . o Q)";:: 0:::: .... t ~O- ()~a.Ul<(O <( . . ,..; III ~ '" on '" o ::E 6 o ,;, '" on '" o -- 0 () f' 15. "Iii &l Q a: ~ c: ~ 5 Qi lJ" a: C) \'V) i E 0 Cl O'l O'l O'l ,.... >- ::; """J N ~ 0 c j N --n s: r:::::l -on;; .., cpn~'. n ""----.\.../ w -':1".---- ..t.-..... ~~?; ~Ci -;"J )>0 > Z .' :.:;0 r:-? c: --~ '~ ?O \,0 :< ;f. ;f.;f.;f.;t;;f.;f.;f.;t;;t;;f. ;f.;t;;f.;t;;f.;f.;f.;t;;f.;f. ;f.;f.~ ;f.;f. ;f.;f.~~;f.~ ~;f.~;f. ~;f.~;f.;f. ;f.;f.;f.~;f.;t;;f.;f. ;f.;f.;f.;f. ;f.~;f.;f.;f.~;f. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF SARAH LESLIE WILLS Plaintiff No. VERSUS MICHAEL A. WILLS Defendant DECREE IN DIVORCE AND NOW, -:r~7 DECREED THAT SARAH LESLIE WILLS AND MICHAEL A. WILLS ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA. 2002-04168 ,;r I 0." 33 A.,tJ · ,?ob3 , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, J. 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 ATTEST~~ ~. ;f. ;t; ;f. ~ ;f. ;f.;f.;f. ;f. ;f. ~ ;t; ~ ;f. PROTHONOTARY ;f.;f.;f.;f.;f. ;f. ;f.;f.;f.~ ;f.;f.;f.;f. ~ ~-pf'~~} A/~ ~ ~ ['C7-1../ R~~~-/? Wc./ . .' .... ~ ~ .:. . ," ~ .... .,.