The URL can be used to link to this page

Home My WebLink About96-05087 \. ~ ~ " ~ ~ ~ \. ~ ~ ~ l ~ / { I I i , i t \. ~ ..... . t' bo ~/ .,j( (t-, . ~ ~i . . "~, 'ii; I"- ....... ~ c. }c.:( It c;: _.l:.. :t: '. ~ c.. ~; '1 " In ;.i~ C I ..:7, ,. >- ",:-;) ., - ..\~ . ::0.;. ''') t, r- c.... G ROGER L. GARNERt JR., Plainliff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION, LAW No, 96- 50S? CIVIL TERM IN DIVORCE v. SHEILA L, GARNER, Defendanl NOTICE TO DEFEND AND CLAIM OF RIGHTS You have been sued in Coun. If you wish to defend against the claims set fonh 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 Coun. A judgment may also be enlered against you for any other claim or relief requested in Ihese papers by lhe Plaintiff, You may lose money or propeny or other rights important to you. including cU!ilody or visitation of your children. When the ground for the divorce is indignilies or irretrievable breakdown of the marriage. you may request marriage counseling. A lisl of marriage counselors is available in the Office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE CARUSLE. PENNSYL V ANlA 17013 TELEPHONE: 240-619S IF YOU 00 NOT FILE ACLAL\! FOR AUMONY, DIVISION OF PROPERTY. LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMEfo.'T IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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. COURT ADMINISTRATOR, FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE ICOURTHOUSE~UARE CARUSLE. PENNSYLVA."i1A 17013 TELEPHONE: (717) 240-6200 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA CIVIL ACTION. LAW N'J~~'7 CIVIL 1994 IN DIVORCE ROGER L. GARNER. JR.. Plaintiff SHEtLA L. GARNER. Defendanl ~ COUNT I - DIVORCE UNDER 3301(c) OF THE DIVORCE CODE AND NOW comes Roger L. Gamer. Jr. by and Ihrough Frey and Tiley. attorneys for Plaintiff. and makes the following statement: I. Plaintiff is Roger L. Gamer. J r.. who currently resides at 323 East Loulher Slreet. Carlisle. Cumberland County. Pennsylvania. 2, Defendant is Sheila L. Gamer. who currently resides at 424 First Street. Carlisle. Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of PeMsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 13. 1994 in Cumberland County. Pennsylvania. S. There have been no prior actions of divorce or for annulment between the panies, 6. The marriage is irretrievably broken, 7. P1aintiffhas been advised that counseling is available and that Plaintiff may ha\'t! the right to request that the Coon require the partie!; 10 participate in coun!.eling, WHEREFORE. P1ainliff requests your Honorable Coon to enter a Decree in Di\'OI'Ce. Divorcing Plaintiff and Defendant. ROGER L. GARNER. JR.. Plalntirf v. IN THE COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY. PJ.:NNSYLVANIA CIVIL ACTION. LAW NO. 96.5087 CIVIL TERM IN DIVORCE SHEILA L. GARNER, Derendant AFFIDAVIT OF CONSENT, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE, AND WAIVER OF MARRIAGE COUNSELING I. A Complaint in divorce under Section 3301(c) of Ihe Divorce Code was filed on September 13. 1996. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days h.l\'e elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce wilhout notice. 4. I understand that I may lose rights concerning alimony. di\'ision of property. lawyer's fees. or expenses if i do not claim them before a divorce is granted. S. I understand that I will nOI be divorced until a di\'orce decree is entered by the Court and that a copy of lhe decree will be senlto me immediately after it is filed with the Prothonotary, 6. I have been advised of the availability of marriage counseling and under-tand thai I may mjuesllhat the cowt require that my spouse and I p;uticipale in counseling. 7. I undersland that the court maintains a Iisl of marriage counselors in the Domestic ReI;lIions Office. which list is available to me upon mjuesl. It Being so advised. I do not requeslthat the court mjuire my spouse and I p;u1icipate in ~'OUnseling prior to a diVorce decree being handed down by the court. I \'eriry that the statements made in thn aIfldavil are trUe and comet. I under-tand thai fillsc: statemeftls herein are miMk subjcct to the renalt~ of III Pa, C. S. t4~ relallngtll Uft,,\'orn fahllkillklllto authont~. Il-\n, ! ~\. - L . , " "- .. ~" .. -, ~ 4 Jt/ ." .' ~~~'~ .' " .,- , L (. . r, _ ~~, .\ summer. These weeks shall he mutually agreed upon by the panies. Father agrees to pay mother twenty dollars ($20) per week for each of the weeks father has custody of the child during the summer fur the purpose of sharing day care expenses. 7. During the perillds of father's panial custlldy, the child shall at all times be in the presence of the father and/or father's girlfriend, Heather Weist. and during those periods of panial custody. father agrees to accept responsibility for protecting the child from any abuse. 8. Neither pany shall engage in any conduct, panicularly in the presence of the child, which would tend to denigrate the other parent. Each parent shall encourage the child's love and respect towards the other parent. 9. Roger Garner is prohibited from consuming alcohol while visiting with his daughter. Mariah. 10. Both panies recognize that the child has an allergic condition that is aggravated by the presence of cigarette smole. Roger Garner agrees not to smoke cigarettes in front of his daughter, Mariah, during any visits. Both panics will male reasonable effons to provide a smole free environment during periods of custody. especially while lhe child is in the home of either pany. 11. The panics agree that this Agreement will be entered as an Order of Coon and will continue in full force and effect until funher agreement or Order of Coun. .....'\.. ..,.., "(;;-1 ...::::. '" ""< . '~ 1 i