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Home My WebLink About97-00352 \ ! ~ q " V) '" ~ ~ " " It \l , ~ '~" , /.// l ! ! \. i ~ I I :- i - .:) I ... ! <::.J I ! , ~ I ~I ~, I <:ri . . I ~i .,- Cl .... l~ c;. l:', ,:: .' , .f ,"'j ..:T I' , . ~;. ~. . : ( I'. .. ~', .(1 ,('" two - '.I;':. : \...:'" :..J ~; c.:. 'q\l \k ,'- , . ! ~J,.. "'" ,'- p, C'l' '" t,) G' <:) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROSE A. SHEARER, I Plaintiff I I CIVIL ACTION - LAW v. I IN DIVORCE I EDWARD L. SHEARER, I NO. 97- '35--;} C \.k-L&J ~~ Defendant I 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 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, Cumberland County Courthouse, 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. Cumberland County Court Administrator One Courthouse Square, Fourth Floor Carlisle, Pennsylvania 17013 (717) 240-6200 HANtJQ r>>-- William C. vohs, Esquire Attorney for plaintiff c.~'ClIYOIl1tDoI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROSE A. SHEARER, I Plaintiff I I CIVIL ACTION - LAW v. I IN DIVORCE I 9 7 - .3 5'.2. tlu.J ..,- .u-- EDWARD L. SHEARER, I NO. Defendant I COMPLAINT UNDER SECTION 33011C) OR 3301ld) OF THE DIVORCE CODE AND NOW, this day of January, 1997, comes the Plaintiff, Rose A. Shearer, by and through her attorneys, HANFT & VOHS, and files this Complaint in Divorce, and states as follows I 1. Plaintiff is Rose A. Shearer, an adult individual who currently lives at an undisclosed location in Cumberland County, Pennsylvania. 2. Defendant is Edward L. Shearer, an adult individual who currently resides at 161 E. High Street, Apt. 3, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 1, 1990, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in C.~l'llM*a.f."'OW VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusions and averments authored by counsel in his capacity as attorney for the party or parties hereto. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. ! ~ IJ~Jk/l-PA.J Rose . Shearer ~...-a."'" ROSE A. SHEARER, . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . I . ;. vs. NO. 97-352 CIVIL TERM , : I EDWARD L. SHEARER, CIVIL ACTION - LAW : : Defendant . ACTION IN DIVORCE . ACCEPTANCE OF SERVICE I hereby affirm I was served on January 25, 1997 the foregoing Complaint in Divorce filed January 22, 1997. DATED: 4/13/99 By' dlgw)X~ EDWARD L. SHEARER n \D 0 ~; UJ ." ~ , I) r.., 'U " n" , ~.;J 'r" f51!'., ,:',-, ,., O. ~ ~~~ ,. r:.'.. ~ :iJ --.:.; r ) . ., '"';'"'1 )::i.:.: r:- :.~'I ~ :::> ::0 0 -< , \ \. ( I (") U) c U) ;::: :too "Urn -0 n-'rn - ., -) , .~., .. '" ,. , ) .' II t .. ~-, :~) . , ";,:; -. (:J :.; r \ f I ROSE A. SHEARER, : IN THE COURT OF COMMON PLEAS plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 97-352 CIVIL TERM . . . EDWARD L. SHEARER, . CIVIL ACTION - LAW . Defendant . ACTION IN DIVORCE . AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Rose A. Shearer, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on January 22, 1997. 2. The marriage of plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. D.to< (I, /, 91 \"~Il>:lO- n. Uoa;wtJ ROSE A. SHJikER Sworn to and subscribed before me this Isl day ea;;; '-" ' 1999. Notary N\I':'\'I~I:"*.t4 M1ft.n n':'I.(\'"I. N'J~ i", Olln'lC Hm"IY'II)" r J,f' . :.>J"I~".lf':d ':'~IJn'1, My r._:'l'l""lj.,~n E~~:OS July z.'..!tXI.l 'I n ..? 0 C \0 -" '." "'" ,:;-.1 "'~I ' -u ", fdr' O:J I:.;,.:,; %:" . ~.71 -, ': '";:1 ('"I 0\ , -' . -;() r:; ;" :~ .- " " ~f: .-' dn l.,.. -.(., ~i.~:() , I n .-' , .. , ,=> )> '-j ~ -.. 0 n \.0 0 ~ w 'f1 "" :J ."r;I." "'J . :ilJ nh' :'"";J .7~": :j , :Irq '";", .:0 ':..?: en ..:(1.., S.~ (.. -:J ;'~i .:( :! :~'i '" ;n ---~.~ .. ~~ :::> ..' ... JJ -~ I;:J -.; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROSE A. SHEARER, I Plaintiff . . I CIVIL ACTION - LAW V. I IN DIVORCE I EDWARD L. SHEARER, I NO. 97-352 Defendant . . AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 22, 1997. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of the filing of the Complaint in Divorce. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. I understand that the costs of these proceedings will be paid for by Plaintiff. 6. 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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. 1~ 11;/ - Datedl 1rl/q~ r9'J/l(~t/l, ~ ~rd L. Shearer ~.WJIOI'OON.IU IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROSE A. SHEARER, I Plaintiff I I CIVIL ACTION - LAW V. I IN DIVORCE I EDWARD L. SHEARER, I NO. 97-352 Defendant I WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER S3301(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 statemonts made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. Datedl '1(7/1"'1 ')~ ~/K1d!A' . ~ E ward L. Shearer e- .._-~ (') t.n () ~:;: \.0 '1'1 ho .~-J "I'll ., '-q r.U! =-u .jt~"; ~=; "~~1 0') . ::-J ;:::-, :(~) ~~. ' -. -n ~ _: -j-' "t.., I .~. <i< 'C.l z;- "-rn 'I. '..) 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