HomeMy WebLinkAbout02-4908CYNTHIA D. SHAW,
Plaintiff
VS.
KEITH B. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No.
:
· ' ACTION 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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
(717) 249-3166
CYNTHIA D. SHAW,
Plaintiff
VS.
KEITH B. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. {~),:,2 ~ t/q O ~- Civil Term
:
:ACTION IN DIVORCE
:
COMPLAINT UNDER SECTION 3301 of the DIVORCE CODE
1. Plaintiff is Cynthia D. Shaw, who currently resides at 105 A Partridge Circle, Carlisle,
Cumberland County, Pennsylvania, 17013.
2. Defendant is Keith B. Shaw, who currently resides at 105 A Partridge Circle, Carlisle,
Cumberland County, Pennsylvania, 17013.
3. Plaintiffand Defendant have been bona fide residents of the Commonwealth for at
least 6 months previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on October 19, 1991 in Colorado
Springs, Colorado.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The man'iage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
8. Plaintiff and Defendant have one child, together, namely, Nicholas T. Shaw, date of
birth, December 20, 1999.
9. Defendant is a member of the United States Army, and is currently on active duty.
10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken;
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
I verify that the statements made in this Complaint 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.
Cynfilhia D. Shaw, Plaintiff
Respectfully submitted:
~~!~uire
Carlisle, Pa. 17013
ATTORNEY FOR PLAINTIFF
CYNTHIA D. SHAW,
Plaintiff
VS.
KEITH B. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:No. ~)~C/~ ~' CivilTerm
:ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF NOTICE TO
DEFEND AND COMPLAINT
AND NOW, this October 21, 2002, I, Jane Adams, Esquire, hereby certify that
on October 18, 2002, a certified tree copy of the NOTICE TO DEFEND AND COMPLAINT
was served, via certified mail, restricted delivery, return receipt requested, addressed to:
Keith B. Shaw
105A Partridge Circle
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
'-36 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
YES, enter deliverY addreSs betoW:
Yes
No
UNITED STATEs POSTAL SERVICE
° Sender: Please print Your name, address, and
ZIP+4 in this box ·
JANE ADAMS
/~TTORNE¥ AT LAW
36 S. PITT STREET
CARLISLE, PA 1701~1