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Home My WebLink About02-5314ROBERT H. SNYDER, Plaintiff SANDRA P. SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW NO. oo2- ~"~i~ CIVILTERM IN 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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. Cumberland County Bar Association T~vo Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ROBERT H. SNYDER, Plaintiff SANDRA p. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. Off.- 1N DIVORCE CIVIL TERM COMPLAINT IN DIVORCE .NO FAULT 1. Plaintiff is Robert H. Snyder, an adult individual currently residing at 905 Newburg Road, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Sandra P. Snyder, an adult individual currently residing at 905 Newburg Road, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiffis a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 25, 1978, in Chambersburg, Franklin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. I 0. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divome. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. ~OUNT II EQUITABLE DISTRIBUTION 11. 12. 13. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. Plaintiff and Defendant are joint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, Wendy J.'~. Gr~el a~ir~ Attorney for Plainti~.~ [j GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I tmderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE:/~-..,,wO-Oo~, _ ROBERT H. SNYDER, Plaintiff Vo SANDRA P. SNYDER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-5314 CIVILTERM : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ~'~' ~day of November, 2002, comes Wendy J. F. Grella, Esquire, counsel of record for Plaintiff, Robert H. Snyder, and states that a copy of a Complaint in Divorce was sent to Defendant, Sandra H. Synder, at 905 Newburg Road, Shippensburg, PA 17257 by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on November 6, 2002. ~t~drnYe~'fFo 'r Gp;ea?na'.~e GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to befor$1me.this,__~)_~ day of ~6q (/~. ~ /? ,2002 l......... Notarial Seal Kansa J. Lehman, Notary Public .. C~_rtlsle,Bo. ro, Cumberland · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt 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. Is delivery address different from item 17 [] Yes If YES, enter delivery address below: [] No 3. Service Type ~:~)e~tifiad Mai~' [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Transfer from service label) --~ PS Form 3811, August 2001 Domestic- Return Receipt 102595~)2-M-0835 r--~ R ricted Delivery Fee ROBERT H. SNYDER, Plaintiff VS. SANDRA p. SNYDER, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5314 : : IN DIVORCE ,PRAECIPE Please mark the above-captioned action as discontinued and withdrawn. Date Respectfully submitted, ~~, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-55;52