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Home My WebLink About95-04824 DAVID WILEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. DIVORCE P1llntl" l. "!r,' , ~ VI. , . MICHELE R. WILEY, NO. 85 -tic:,.: 2.'1 IN DIVORCE CIVIL TERM Defendlnt -ria I. ('b, e. ,state that on September ~ , 1995, at s:a V o'clock E...., M. I served the ComplaInt In Divorce and Petition for Special Relief on Michele R, Wiley, at . .5+ ~y handing them to Michele R, Wiley. 4/~~~~ Date:~j. ')7"'" 19CfS- ,".. .. .._<C.L.c.~._._.". " -.,-""-,,.,,-..,,.-.....,..... lA iE :B 7' en Jt >-.. "'~ ...". '" r, ~;,:1 UZ":t ';:a~' -1 ~:: j:r:~. _:J ~l ~ '" ;;1': , 'I' j'J~ '-, I... ~) ..' ", ....~:""':--:~- '.-:0''"',.-''.''''-; \ L .- -... " . g;.30 Q-I4.QCS Co.ro\ L'\V'\~~ C,q\\ed, ~f: \-\a.o..n"~ toMOffi>l0 "'~- '?;"1S W~\~ -\je;, _ W~~\ . ~e.,y.(.. W \ \\ ~L q '""J",,~ \o.-\io"", ~ l.d. 9- 6\rie. \ ") Q,Sk"I1,j ~'r ~ 5~h~v-<"\ I C. Co> "1. Y\uo. \1 C..... . 5"'~ w\\\ ~-\ ~ 'S-\i\,u\Q-hor1 \0 ~ :':-)oYY\<..-\l'M.L \-oVY'\Dt'rol0. ;. . l I ,I , . 11\"""" llII. 4I1~1 . DAVID WILD, IN THE COURT OF COMMON PLEAI OF CUMBERlAND COUN1Y1 PENNlYLVANIA CIVIL ACTION. DIVORCE NO, 8&. t/ti' 2..1 CIVIL TERM IN DIVORCE Plaintiff/Petitioner VI. MICHI~ II. WILlY, : Delendant/R_ponden, : AND now thll , ~ day of +~ I 1995, upon consideration of the within PdIIor', both of the pll1lel to this cue, David Wiley and Michele R. Wiley, are ordered not to remcM from the marItII home any Item of marital property, and not to alienate or otherwlH d1111pete any IUCh property until further Order of Court. A Rule II IlaUId upon Rnpondent to Ihow cause, If any, why this Temporary Order IhouId not be mIde . permanent Order, RULE retumlble at a hearing set for the 15'0 day of J~J)lMv, 1895, Lj be at the Cum rland County Court House In Carlisle, Pennlylvanll In Court Room No, It 1,' i/5 o'clock A .M. By the Court, ~h?4 L /' J. SEP B 3 00 fK '95 'LOlflCE f;f 1',' . lI\OIlOlAr,Y Cll~ 1 p.',..f.1it) f;("H Y . 'lh~H 'w',,,Ni\ <1jlJl'15 PllN~"'...~~ "~",J..J ~DG.\-h\ 0\n:.Jl.,J Nllt..U..\Q ~.t. F'---'--- )-;. . .-lI\-'iiilF,-,'.''''-.,...,'' "- ll\wtII1f111 11II, 4110.95.01 DAVID WILEY, IN THE COURT OF COMMON PLEAI OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. DIVORCE Plaintiff/Petitioner VI. MICHELE R. WILEY, : Defendant/R.pondtnt : NO. 8a. IN DIVORCE CIVIL TERM j)RDeR OF COURT AND now this day 01 , 1995, upon consideration of the within Petition, both of the parties to this case, David Wiley and Michele R. Wiley, are ordered not to remove from the marital home any Item 01 marital property, and not to alienate or otherwlH d1uipat1 any such property until further Order of Court. A Rula Is I..ued upon Respondent to show cause, If any, why this Temporery Order should not be meda a permanent Order. RULE retumabla days from date 01 service. By the Court, J. . 11\""'" III. .111441 DAVID WILEY, IN THE COURT OF COMMON PLEAI OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. DIVORCE Plaintiff/Petitioner VI. MICHELE R. WILEY, Derend.nl/Ra.pondant : NO. 115. IN DIVORCE CIVIL TERM NOW come. Davtd Wiley by and through his counsel, FLOWER, MORGENTHAL, FLOWER & UNDSAY, P.C" and petitions this Honorable Court as follows: 1. Petitioner Is David Wiley who resides at 69 West Main Street, Newville, Cumberland County, Pennsylvania. 2. Respondent Is Michele R. Wiley who resides at 11 Corporation Street, Newville, Cumbartand County, Pennsylvania. 3. The parties were marrlec! on October 21, 1988. 4. The parties separated on September 5, 1995 when Respondent left the marital home at 69 West Main Street, Newville, Pennsylvania. 5. The marital home and Its contents comprises the majority of the marital estate. 6. Petitioner believes and therefore avers that absent an Order of Court, Respondent will remove all of the furnishings and other goods from the marital home. 7. Petitioner Is willing to equitably divide the contents of the home, but he does not want """-.'--.,_........,,.... -~~~~-'- ; " -, ',-:~~o:.:;'_';C~_' .- .--';- .~~",.-:';"t;:,>~'!. -;:~:~:~=:..,~"-~~:""-.,_;' : ',~'~;':?: ::;~;;-.':::>"\;~' , a:\""", 1lIo' 4I1l).9S.G1 the contents to be removed unilaterally. WHEREFORE, Petitioner prays this Honorable Court to enter an Order after a hearing and IIllntertm Order requiring both parties not to dissipate any marital asset. FLOWER. MOROENTHAL FLOWER a UNDIAY, P.C, Attomey. for Plalntlff/pelnlon... By: arol J. ndsay, Esquire 10 * 44693 11 East High Street Carlisle, PA 17013 (717) 243.5513 Date:Sy & . /tlt:J'J" , 2 , . 11\....,... Nt. ..tNlUI ~ I, the underIIgnec:l, hereby verify that the atatements made herein are true and correct. I undtrItand that faI.. ltatementa herein are made subject to the penalties of 18 Pa. C.8, I 41104. rllatlng to unlwom falllficatlon to authorities. fj~ V~ David Wiley Date:-9 /8/CfS ( f .~~~~'~"'f,"+s~'i~if0a~'};h"?-' , i;"<',;..,..-~~Jii~~ _' i "'fi;,,":";:t:\'_'}'. t:\wlIIy.tDlll file' 4110.95.(11 DAVID WILEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE Plllntlff VI. MICHELE R. WILEY, NO. 85 .1_+1 j, 4- IN DIVORCE CIVIL TERM Defendlnt NOIJCE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth In the following pages, you must take prompt aetlon. You are warned that if you fall to do so, the ca.e 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 the.. 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 reque.t marriage counseling. A list of marriage counselors Is available In the OffIce of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWVERS FEEl OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, Fourth Floor Cumberland County Court House Carlisle, Pennsylvania 17013 (717) 240-6200 tn....".".l' .:\wUoy..- nil' 4110.95-01 David Wiley, Plaintiff, by his attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P,C" respectfully represents: 1, The Plaintiff Is David Wiley, who currently resides at 69 West Main Street, Newville, Cumberland County, Pennsylvania, where he has resided since April, 1994. 2. The Defendant Is Michele R. Wiley, who currently resides at 11 Corporation Street, Newville, Cumberland County, Pennsylvania, where she has resided since September 5, 1995. 3. The Plaintiff and Defendant both have been bona fide residents In the Commonweahh of Pennsylvania for at least SIK months Immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 21, 1988, In Newville, Cumberland County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties In this or In any other Jurisdiction. COUNT I 6. The Plaintiff avers that he Is entitled to a divorce on the ground that the marriage Is Irretrievably broken and Plaintiff Is proceeding under Sections 3301 (c) and/or (d) of the Divorce Il\wtley_ l1II' 4I1ll-1IU1 Code. 7. Plaintiff has been advised 01 the availability 01 marriage counseling and 01 the right to request that the Court require the parties to participate In marriage counseling, and does not request counseling. WHEREFORE, Plaintiff prays this Honorable Court to enter a decree 01 divorce. COUNT II . EQUITABLE DISTRIBUTIO~ 8. In the course 01 their marriage, Plaintiff and Defendant have acquired certain property, both personal and mixed. WHEREFORE, Plaintiff prays this Honorable Court to equitably distribute their property. FLOWER, MOROENTHAL FLOWER' L1ND8AV, p.e. Attorneys lor Plllntlff "'->r By: (j~C:; ;.(2 ~~. Undsay, Esquire (/ ID 1/ 44693 , 11 East High Street Carlisle, PA 17013 (717) 243-5513 ~I /11)- / 2 I ! ! '" 11\""'_ 1lII. _tDf5.01 ~ I. the undersigned. hereby verify that the statements made herein are true and correct, underItand that faiN statements herein are made subject to the penalties of 18 Pa. C.S. . 4804, relating to unsworn falsification to authorities. iJ~ ~ Oate: 9 Ie Jqs ( ,