Loading...
HomeMy WebLinkAbout02-5272SHEREE R. YINGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY A. YINGER, Defendant : NO. 0a - 2'2 7;-- CIVIL TERM : IN LAW - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 relief requested in these papers by the Plaintiff. You may loose money or property or other rights important to you, including custody or visitation of your children. When the grounds for the 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, First Floor, 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 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. Cmnberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SHEREE R. YINGER, Plaintiff RANDY A. Y1NGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. tZ~. 3'.~ '7 ~ CIVIL TERM : 1N LAW - DIVORCE COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, SHEREE R. YINGER, by her counsel, William L. Grubb, Esquire, and complains of the Defendant, RANDY A. Y1NGER, as follows: COUNT I COMPLAiNT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is SHEREE R. YINGER, who currently resides at 246 Kenmar Drive, Fairview Township, York County, Pennsylvania. 2. Defendant is RANDY A. YiNGER, who currently resides at 414 Market Street, Lewisberry, York County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on April 20, 1991, at Lewisberry, Pennsylvania. pa~ies. There have been no prior actions of divorce or for annulment between the 6. Neither party is in the Armed Services of the United States or its allies. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the marriage between the parties. Respectfully submitted, William L. Grubb, Esquire I.D. # 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 Attorney for Plaintiff VERIFICATION I, SHEREE R. YINGER, verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: ~ '~/ ~.~ eree R. Yinger, Plaintiff SHEREE R. YINGER, Plaintiff RANDY A. YINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5272 CIVIL TERM . : : IN LAW - DIVORCE PROOF OF SERVICE BY M~IL I hereby certify that a true and correct copy of the Complaint in Divorce filed in the above matter, was served on Randy A. Yinger by first class, certified mail, return receipt requested, deliver to addressee only, at 414 Market Street, Lewisberry, PA 17339, on October 30, 2002. Addressee acknowledged receipt of the same on November 9, 2002, as shown by the return receipt card attached hereto as Exhibit "A". I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. William L. Grubb, Esquire I.D. 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 · 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. Article Addressed to: D. Isdelive~ad~n~differentfromiteml? [] Yes If YES, enter delivery address below: [] No 3. Service Type [] Registered [] Insured Mail j~[] Express Mail L.I C.O.D. 4. ~ D~ ~ Fee) ~J Yes 2. Article Number (Copy from. service label) '7000 /5"$b o6o p.. 5"-'7~, PS Form 381 1, July 1999 Domestic Return Receipt 102595-00-M-0~52 Exhibit "A" SHEREE R. YINGER, Plaintiff Mo RANDY A. YINGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5272 CIVIL TERM · IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 31, 2002 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from 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 the 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. Dat'~': ~3 SHERLE R. Y~NG~ER, d~_n-t~-f SHEREE RANDY R. YINGER, Plaintiff A. YINGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5272 CIVIL TERM · IN LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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. §4904 relating to unsworn falsification to authorities. Dated: SHER]~]~ R.~YINOE-R(f[ai-nii~v'- -- SHEREE R. YINGER, Plaintiff Vo RANDY A. YINGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5272 CIVIL TERM · IN LAW - DIVORCE SHEREE AFFIDAVIT OF MARRIAGE COUNSELING R. YINGER, being duly swom according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the l~enalties of Pa. C.S. {}4904, relating to unswom falsification to authorities. Sheree R. Yinger SHEREE R. YINGER, Plaintiff RANDY A. YINGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-S272 CIVIL TERM · IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 31, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from 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 the 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. Date: RANDY /f. yrN6~E~~, Defendant SHEREE RANDY R. YINGER, Plaintiff Vo A. YINGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5272 CIVIL TERM · IN LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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 irnmediately 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. {}4904 relating to unsworn falsification to authorities. Dated: P. ANDY/A. 5r[N~JER, Defendant SHEREE RANDY R. YINGER, Plaintiff Mo A. YINGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5272 CIVIL TERM · IN LAW - DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infi)rmation to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under {}3301(c)of the Divorce Code. Date and manner of service of the complaint: 11/09/2002, US mail, certified, restricted delivery return receipt, postage prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff February 10, 2003, by Defendant February 13, 2003. o Related claims pending: NONE Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit the record, a copy of which is attached: (b) Date plaintiff's Waiver of Ng.t. ice in §3301 (c) was filed with the Prothonotary: Februaryo?.~' , 2003. Date defendant's Waiver of Notice in !i3301 (c) was filed with the Prothonotary: February,~, ~, 2003. William L. Grubb, E~q. ' ~'~'-' Attorney for the Plaintiff IN PLEAS THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ,~:~~~, PENNA. SHEREE R. YINGER, Plaintiff VERSUS RANDY A. YINGER, Defendant No. 02-5272 DECREE DIVORCE IN AND NOW,~~~ ~' ,.2003 DECREED THAT Sheree R. Yinger AND Randy A. Yinger 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; NONE J0 PROTHONOTARY