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Home My WebLink About02-5904Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DEBORAH M. MCDONALD, Plaintiff VS. DOUGLAS R. MCDONALD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 02 .~o ¥ CIVIL TERM : : 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 may proceed against you and a decree in 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 with 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 the 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 A ~ ~Orew C. Sheely, Esquir~ PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 7L2-697-7050 (Phone) 717-697-7065 (Fax) DEBORAH M. MCDONALD, Plaintiff VS. DOUGLAS R. MCDONALD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBEP~LAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 02 ~gO~J CIVIL TERM : IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is DEBORAH M. MCDONALD, an adult individual who currently resides at 5 Pamela Place, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is DOUGLAS R. MCDONALD, an adult individual who resides at 5 Pamela Place, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 16, 1998 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. This action is not collusive. 10. The parties separated on or about September 10, 2002. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: December ~ 2002 Respectfully submitted, Andrew C. Sheely, Esquire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: December~, 2002 DEBORAH M. MCDONALD Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DEBORAH M. MCDONALD, Plaintiff VS. DOUGLAS R. MCDONALD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 02 - CIVIL TERM : : IN DIVORCE AFFIDAVIT DEBORAH M. MCDONALD, being duly sworn 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 Domestic Relations Office, 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 Section 4904 relating to unsworn the penalties of 18 Pa.C.S.A. falsification to authorities. December ~, 2002 DEBORAH M. MCDONALD $0. In the Court of Common Pleas of Cumberland County, Pennsylvania oa.---~'q o~ ci.~rtr'-- To Prothonotary 19 /PA- ~'D Attorney for Plaintiff 6 z.cl ?o q '?t'~- t., ~l 7 No, Term, 19 ~ Filed PRAECIPE Atty. Andrew C, Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DEBORAH M. MCDONALD, Plaintiff VS. DOUGLAS R. MCDONALD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBEP~LAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 5904 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS : ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon Douglas R. McDonald, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt cards, on January 16, 2003. SWORN to and subscribed before me this~Wday of January, 2003. Notarj Public ~- My Commission Expires: ~///~///<3~~ Hechantcsburg Mefn ~ ~7~3;~nsylvenfe 01/~7/2003 _~800)275-8777 05,23 ~7 "Y Pr/ce ~;nel estr/ct.. ~ $0 60 . ~ecefpt $3.50 Label Se~'ial #: 700~25~000003029~38~ To,al: Paid by: Persona/ BI11#: Clerk: ~2 Refunds Only ""-"-' Than~( You for ~?? DMt,I P014 CUs t or~e;U~;p by us ' ness (Endorsement R~quired~ · 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: 62803 A. Received by (P/ease Pdnt Clearly) B. Date of Delivery C. Signature [] Agent DELIVERY 2. Article Number (Copy from service label) 7DD1 PS Form 3811, July 1999 _ _ . Domestic Return Receipt [] Express Mail r-I Registered [] Return Receipt for Memhandise [] Insured Marl [] C.O.D. 4. Restricted Delivery? (Extra Fee) __~.~.Yes __ 2510 0000 3029 4361 I02595-00-M-0952 DEBORAH M. MCDONALD, Plaintiff vs. DOUGLAS R. MCDONALD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 02 - 5904 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certificate of Service filed January 16, 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Defendant on May 8, 2003, by Plaintiff on April 18, 2003. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: NONE 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. May lb, 2003. Date Defendant's Waiver of Notice ih~ection C) Divorce was filed with the Prothonotary. May%d-, 20037301 ( IN THE COURT OF COMMON PLEAS DEBORAH M. MCDONALD, OF CUMBERLAND COUNTY STATE OF ~ PLAINTIFF VERSUS DOUGLAS R. MCDONALD, DEFENDANT NO. PENNA. 02 5904 CIVIL ACTION - LAW IN DIVORCE DECREE IN DIVORCE A N D N O W, ~. , 2003 DECREED THAT AND MCDONALD DOUGLAS R. MCDONALD , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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. ALL RESOLVED BY SEPARATION AND PROPERTY SETTLEMENT AGREEMENT DATED NOVEMBER 25, 2002. BY THE CO PROTHONOTARY DEBORAH M. MCDONALD, Plaintiff vs. DOUGLAS R. MCDONALD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 5904 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certificate of Service filed January 16, 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Defendant on May 8, 2003, by Plaintiff on April 18, 2003. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: NONE 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. May IL, 2003. Date Defendant's Waiver of Notice iq~ection 3301 (C) Divorce was filed with the Prothonotary. May%t~, 2003. 717-697-7050