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