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HomeMy WebLinkAbout02-4255STACY E. WILLIAMSON, Plaintiff PRIEST J. WILLIAMSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. Oa : : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT,,; 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 divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room I01, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. 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 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, PA 17013 Telephone: (717) 249-3166 STACY E. WILLIAMSON, Plaintiff PRIEST J. WILLIAMSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. C Tk-4t.Z.C ; : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE County. 2. The Defendant is Priest J. Williamson, an adult individual residing at 250 Church Road, Etters, York County, Pennsylvania. 17319. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiffand Defendant were married on January 17, 1998, in York 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. This action is not collusive. 7. Plaintiff and Defendant separated on or about September 1,2000. 1. The Plaintiff is Stacy E. Williamson, an adult individual currently residing at 21 Cottage Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c) - The marriage of the parties is irretrievably broken. B. Section 3301(d) - The marriage of the parties is irretrievably broken. The parties separated on or about September I, 2000. 9. Plaintiff and Defendant have one child under the age of eighteen, namely Sydney Elainemarie Williamson, bom June 2, 1998. 10. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 11. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. Date: ~/~ '3/O ~,- Respect fully submitted, THE LAW OFFI~CES OF SILLIKER & R/~INHOLD 5922 Llnglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Plaintiff AFFIDAVIT ~x,[x?~ ~_c~. ~. Wi ll,'~xffl~0fl, hereby certify that the aforegoing is true I, and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unswom falsifications to authorities. Dated: STACY E. WILLIAMSON, Plaintiff Vo PRIEST J. WILLIAMSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 02-4255 CIVIl_, TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 5, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in 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 falsifications to authorities. - Priest J. Willfi~nson STACY E. WILLIAMSON, Plaintiff Vo PRIEST J. WILLIAMSON, Defendant : IN THE COURT OF' COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-4255 CIVIL, TERM : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION 3['0 REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in ]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 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 verify that the statements made in this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. D Priest j. ~lia~so~~ · STACY E. WILLIAMSON, · IN THE COURT O17 COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 02-4255 CIVIL TERM PRIEST J. WILLIAMSON, · CIVIL ACTION -/,AW Defendant ' IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 5, 2002. 2. The marriage of the Plaintiff and Defendaat is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in iDivorce 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 falsifications to authorities. amsoa'- STACY E. WILLIAMSON, : IN THE COURT 0]7 COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 02-4255 CIVIL TERM : PR/EST J. WILLIAMSON, : CIVIL ACTION - [,AW Defendant : IN 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 in ]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 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 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. Section 4904 relating to unsworn falsification to authorities. STACY E. WILLIAMSON, · IN THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 02-4255 CIVIL TERM PR/EST J. WILLIAMSON, Defendant · CIVIL ACTION - LAW · IN DIVORCE _CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of a Complaint in Divorce was served upon Priest J. Williamson on September 16, 2002, by Certified Mail, return receipt requested, addressed as follows: Priest J. Williamson 250 Church Road Etters, PA 17319 I hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. 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: ~>~.._/(~/~..~ Renee Dreisbach · COmplete items 1, 2, and 3;'Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1..Nticle Add~ to: 2. Article Number "".~ ('rransf~r from ~rvica lal~0 7 fl 0 '1, 2 5 10 PS Form 3811, a.~,_,st 2001 I~ Agent B. Received by (Printed Name) I P-~-~Date of De#very ,,,, s~,, I '~'/~,,o'~" D. Is delivery address di~nt fn:~n ~tem 17 I-I Ye~ If YES, enter delivery address below: I-I No 3. Service Type '----' ~ertified Mail [] Express Mail [] Registered [] Ret,urn Receipt for Merchandies ( 4. Restricted Delivery?/~,,~,, ~ ~ 0006 2853 7388 Return Rec,.aipt 102595-01 -M-0381 STACY E. WILLIAMSON, Plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ·NO. 02-4255 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRIEST J. WILLIAMSON, Defendant To the Prothonotary: P~RAECIPE TO TRANSMIT RECORD 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 ~ ~ of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint.. September 16, 2002, by Certified Mail. 3. Complete either (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: January 16, 2003 by Plaintiff, January 30, 2003 by Defendant. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: Defendant: (2) Date of service of the Plaintiff's Affidavit upon the 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: N/A (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 7, 2003 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 7, 2003 6. Social Security Numbers: (a) Plaintiff: 170-60-9140 (b) Defendant: 181-68-4037 N THE COURT OF COiVlMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA ....................... - ..................... ~() ..... 0..2 - .~255 PRIEST J WILLIAMSON AND NO I' -, -"~ ................ , ' 'sordered and decreed that .... s.t..~.~/<..E. :..W.! 1. 1 iamson , plaintiff, and .. ?~.ies.t..j,. ~.i].]-iamson ............................... , defendant, are divorced from the bonds of matrimony. The court retains iurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; STACY E. WILLIAMSON, Plaintiff Vo PRIEST J. WILLIAMSON, Defendant · IN THE COURT OF COMMON CUMBERLAND COUNTY, PEF NO. 02-4255 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR ?LEAS NSYLVANIA NAME COMMONWEALTH OF PENNSYLVANIA Stacy E. Williamson, being duly sworn according to law, deposes and says that she is the Plaintiff in th~ aboye suit in which final decree from the bon~ls of matrimony was entered and she elects to resume her prior name of Stacy E. Upperman, and, therefore, gives this written notice ~vowing said intention, in accordance with the provisions ofthe Act ofMayi25' 1939, ?. 192, as amended July 13, 1953 (13 P.S. 98). 7 to be known as i Sworn and subscribed to befoj~e me.tt']is. 7·t~lay of ~;, t~t I ,~. , ~-~y E. Upperman