The URL can be used to link to this page

Home My WebLink About02-4276IN THE-COURT OF COMMON PLEAS OF CUMBERLAND coUNTy, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff : Defendant : Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS YOUH. AVE BEENSUED 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 the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, 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 CLAIM ANY OF THE1M[. 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 ......... (717) 249-3166 Ee han demandado a usted a la cone. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO. 2002- '~/.~7~- - ~ ~,,-4~ : CIVIL ACTION - LAW Defendant : : 1N DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ~'~xx t~x~e~x., ~,A~ls~ (f~-nq~, who currently resides at ! Cumberland County, Pennsylvania. 2. Defendant is &~t~l~ ~, [/k~l,~, who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ! 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parities. at 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Ql/~P~)ln t i IT, Pr~ ~e I,'~ ~ta~'~g'C~ .\~ ~CYq-~l~, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243 -9400 Plaintiff vii. Defendant : : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE pETITION TO PROCEED IN FORMA PAUPERIS The Petitioner, -] ct~d t -r o. ~. /..) ~ ] I I a. tkx 5 , is the Plaintiffin this action, On her behalf, I, Joan Car~y, attorney for MidPenn Legal Services, do hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn Legal Services is assisting the Petitioner in filing a divorce casepro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests leave to proceed without payment of fees or costs. Respectfully su~,tted: ,(~. ' ey, Attorney - ~//' ~l~idPenn Legal Services Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 Plaintiff VS. Defendants : IN THE COURT OF COM3~ON PLEAS OF : CUMBERLAND COLrNTY, PENNSYLVANIA : : NO. CIVIL TERM : : AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS. 1. I am the~in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing 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. I represent that the information below relating to my ability to pay the fees and costs is true and correct, Co) Social Security Number: If you are presently employed, state Address: Salary or wages per month: Type of work: k~ I ~ If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: ~c,-b ~.~ (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: 10 I ~ Dividends: 1,3 Pension and annuities: k3 Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: k) [A Workman's compensation: k~ [~ Public Assistance: ~ ~0~- t2~ Other: N~ (d) Other contributions to household support (Wife)(I-Iusband) Name: 14 If your (husband) (wife) is employed, state Employer: Salary or wages per month: k){ Type of work: ID ]/~ Contributions from children: (e) Property owned ~.{~ Cash: ~ 6. OC~ Checking Account: ~ ¢{~ .~ ~ Sav~gs Account: ~ ~.~ ~ Cea~tes of Deposit: ~ ~ ~ R~ Es~te Oncluding home): ~ l ~ Motor vehicle: M~e~ y~ ~q Cost ~ Amount ow~ Stock; onas: Other: U j~ Debts ~d obliga~ons Mortgage: ~ Rent: ~ Mont~y Expenses: ~ ~ ~ ~. 0 0 (g) Persons dependent upon you for support (Wife) (Husband) Name: k~ {/:k Children, if any: Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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. DIVORCE INFORMATION SHEET ~URSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT ~,EQUIRED BY THE STATE EFFECTIVE JANUARY 1,2002. THE :)ROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF hiE VITAL STATISTICS FORM. '1-O THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: DATE OF MARRIAGE: SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: DOCKET NUMBER: PLAINTIFF/PETITIONER NAME: DEFENDANT/RESPONDENT SS # Juanita R. Williams V. Samuel J. Williams Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-4276 : : CIVIL ACTION - LAW : : IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Submitted, [ta~.'~qq~lliams, P laintiff'~ Pro Se Juanita R. Williams Plaintiff VS. Samuel J. Williams Defendant IN THE COURT OF COld.tON PLEAS OF CUMBERLAND COUN'D[ PENNSYLVANIA No. 02-4276 CIVIL TERM · IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this. affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on -'~"O_v~uor-q ~g6. Iqq ~' and continued to live separate and apart for a period of two years. 2. The marriage is irretrievably broken· 3. I understand that I may lose fights concerning alimony, division of marital property, lawyer's fees, or expenses ifI do not claim them before a Divorce is granted. I,-.~ ~' xar~ ~4-t~_-:~. I ~ \'~ i l ~c~ na.5 , verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. D~?-0~ ~i~tiff, Pro Se ' ~~ Juanita R. Williams, Plaintiff VS. Samuel J. Williams, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 024276 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICI~ I, Margaret A. Darhower, understand, after communicating with Shaleeta Washington, a legal intern at MidPenn Legal Services on July 14, 2003, that MidPenn Legal Services had mailed a true and correct copy of the Complaint in Divorce and Affidavit under section 3301 (d) of the Divorce Code to the Defendant on November 18, 2002. On November 20, 2002, I accepted service on behalf of the Defendant of the envelope sent by MidPenn Legal Services and certify that I was authorized to do so. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Margarel~/k. Darhower Date Juanita R. Williams, Samuel J. Williams, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 - 4276 : CIVIL ACTION - LAW : : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL I,~,,'~%.~k,~'~l'~q~ , do hereby swear that I served ,~ala~~_ with a Compliant under Section 3301(c) or (d) of the Divorce Code pursuant to Pa.R.C.P. 1920.42(a)(2) on the ] ~'rh day of [x~Oit V_.M~E--P..,, 2002, by certified mail, return receipt, restricted delivery, to the person and address below: ! I,~'-'O,t~x~/~. (~ .~kk'~(gk*-a% , veri~?that the statements made (Nme of person who mailed the complaint) in this Affidavit of Se~ice are ~e and co~ect. I underst~d that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to ~swom falsification to au~orities. ~~ ~~~, Date: i 'Z ~ O { - ~ ~ S~a ,~,~ Juanita Williams, Plaintiff VS. Samuel J. Williams, Defendant I, Shaleeta Was Entry of§ 3301(d) Div Code pursuant to Pa.R person and address bel I, Shaleeta W~ true and correct. I un Pa.C.S. Section 4904 Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 02-4276 CiVil_ TERM : IN DP~ORCE AFFIDAVIT OF SERVICE BY MAIL fington, do hereby swear that I mailed the Notice of Intention to Request ,me Decree and a Counteraffidavit under Section 3301 (d) of the Divorce ~.p. 1920.42(a)(2) by regular, first class mail on October 29, 2003, to the ~w: Samuel J. Williams 1234 Market Street Harrisburg, PA 17103 shington, verify that the statements made in this Affidavit of Service are terstand that false statements herein are made subject to the penalties of 18 relating to unswom falsification to authorities. Juanita R. Williams : Plaintiff : : VS. : Samuel J. Williams : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 024276 CWIL TERM IN 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 Divorce Code 2. Date and Manner of service of the Complaint: _Sent bx~Lcertified mail, return receipt r_equested, restricted delivery. Defendant's agent signed Accepl:m_ce of Service on July 25, 200't stating that she had accepted service of the Complaint on behalf of the defendant on November 20 2002. 3. Complete either paragraph (a) or (b). (a) Date °f execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by Plaintiff, N/A: by Defendant, N/A. (b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: June 4, 2002. (2) Date of filing and service of Plaintiff's Affidavit upon Defendant: Filing Date: ~ Date of Service: November 20, 2002. 4. Related claims pending: .There are no outstanding claims. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: Mailed by re~lar first class mail on .October 29, 2003 to Defendant at 1234 Market Street, Harrisburg, PA 17103. (b) Date Plaintiff's Waiver of Notice in Section 3301(,:) Divorce was filed with the Prothonotary: N/A. (c) Date Defendant's Waiver of Notice in Section 330][(c) Divorce was flied with the Prothonotary: _N/A. Plaintiff's Social Security Number: 080-52-1369 Defendant's Social Security Number: 265-91-0005 Jessie~ Dian~ondstone - - Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Juanita R. Williams : Plaintiff : : VS. ; Samuel J. Williams : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COI_rNTY PENNSYLVANIA No. 024276 C~wL TEPd~ IN DIVORCE NOTICE OF INTENTION TO RE UEST ENTRY OF '3301 d DIVORCE DECREE TO: Samuel J. Williams You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after November 19, 2003, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit, which you may file with the prothonotary of the court, is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPOHNE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR 1-800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COIJ NTY STATE OF ~ PENNA. Juanita R. Williams Plaintiff VERSUS Samuel j. Williams Defendant NO. 02-4276 CIVIL DECREE IN DIVORCE AND NOW, DECREED THAT AND Samuel j. Williams Juanita R. Williams ARE DIVORCED FROM THE BONDS OF MATRIMONY. , ~ IT IS ORDERED AND , PLAINTIFF, .,DEFENDANT, 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; ALL CLAIMS HAVE BEEN RESOLVED. BY THE COURT: ~ F