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HomeMy WebLinkAbout97-06289 '\ \\ ) / / / ell ~ i , I I ! I I I i. I ~I i -I .... i .~ I ~. . ~ c;;, 'i 00- (,00, Ii " . C- <). ~ , . ...! ~! i ~' ...( ~I ':'1 ~I ~( ~I ", i ~I ~~ "I ~ '~ I ~ ':' ~ ~) '''I ~( ,~,~.*,.~,~.,~,.*..*..~..~,*.-~.*,.:~,.~,.~..~"~.,~..~.::~.:.'~ .~.;. -:.:- ,:t; -:+;. ':+;, ':+:. .~,. ~: ~ ~: IN THE COURT OF COMMON PLEAS ~ ~ OF CUMBERLAND COUNTY ~ \~ STATE OF /i~~~~' PENNA, "\"~.J""'I ~ * ~ ~ TIFFANY D. SHOWERS 6289 * i\ (I, 97 ~ PLAINTIFF ~ ',' \' 'T,~ll-: * ~ THANE E. SHOWERS ~ ~ ',' DEFENDANT AND NOW, ' , , . DECREE IN D I V 0 R C E J 1:'-11/, "". ~ II 19'f1', it is ordered and decreed that TIFFANY D, SHOWERS , , " plaintiff, dofendant, and ' "" . ,\ll/\NEF;. ,sHoWERS are divorced from the bonds of matrimony, The court retains jurisdiction of the following claims which have been raised of record in this action lor which a linal order has not yet been entered; PROPERTY SETTLH1ENT AGREEEMENT. DATED FJ;:BRUARY 2~" 199!l, IS INCORPORATED INTO THIS ORDh:R ~ ~ .; - :tl . ,_: :...: :.:. :+:- :.,.;. .:+;. .:+;. .:t:. .:..;, <.-:. -:.:. II y r h " ~ ." ~ ATIt.,t: (", .t. ~ €c.(,.. t..,1 (;').J I ~ 1'-/1.1",~ , ,{ , XI:f /!....a~'f~ , , -.I /k". "',....( tyo .A'..zl /.. / ",:- Prothol1oliUY ~ ~ ~ f ..:.:. J, ,', ~ :~ 1* " I~ I: ',' ~ ',' * " ~ " ~ ',' ~ ',' ,', ~ ~ ',' .~ ',' ~ ~ '" ~ ... 1* ~ ~ " ~ ~ ~ ~ * ~ ~ ',' .~ ',' I~ ~ , ~ , I~ ( '~ I'" .~ " ~ ',' :~ ~ ~ ,r TIFFANY J) SHOWEI~S, l'lnintil'l' IN HIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v NO. 97 - 6289 CIVIL TERM TIIANF E SIIOWEI~S, D~f~ndal1l IN DIVORCE .'RAt:CII'E TO TRANSMIT RECORD TO TilE PROTHONOTARY: Trnnsnlltlh~ r~cord, together with the following informntion, to the Court for entry of a divorce decree. 1 (iround for Divorce Irretrievable breakdown under Section (x)3301(c) ()3301(d)(I) of the Divorce ('ode. (('heck applicnble section.) 2 Dale II/Ill mnnner of service of the Complaint: Through Defendant's attorney, Lawrence J Rmen, l'squHe, on Janunry 1\ 1998 by First Class Mail. I (Curnplete either parngraph (a) or (b) (n) Date of execution of the affidavit of consent required by Section ,no 1 (c) of the Divorce ('ode By Plaintiff February 24, 1998; Defendant: February 26, 1998. (h) (I) Date of execution of the Plaintiffs affidavit reqUIred hy Section 3]OI(d) of the Divorce Code:,...._; (2) Date of service of the Plaintiffs nlTidavlt upon the Defendant 4 Related c1nims pending None. , 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in *3301(c) Divorce was filed with the Prothonotary: February 24, 1998. Date Defendant's Waiver of Notice in *3302(c) Divorce was filed with the PI'othonotary: Febraury 26, 1998. &11 Hubert X. Gilroy, Es Attorney for Plain" Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 ... '.. -:1. .. l'- .J t-.: , C' ( ~; .~ i 1.1 1 ~- .'.1- f.; ~ ~ . ."-. " ()i " ' r-. fi: ~ , " !".-.I!t C i/ ., ~ \.,. ~ i , I.L , ~. ,I. .-() ...1 () (.;~ u r'''''>''''''''-''.''' . . .' ~ . BROUJOS Be GILROY, P. c. ATTORNEYS AT LAW 4 NORTH HA~'OVER STREET CA!lLlSLE. PENNSYLVANIA 17013 (717) 2,4:).41574 7...1110 j;. TIFFANY P. SHOWERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v . CIVIL DIVISION - LAW . . 97 -".;;..P/ GIJII~"l . THANE E. SHOWERS, . NO. . Defendant . . : IN DIVORCE NOTICE TO PLEAD , You have been sued in Court. If you wish to defend against the claims set forth ill the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appoarance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice tor any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELE'.PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR Cumberland County Courthouse Carlisle, FA 1.701.3 (71. 7) 240-6200 TIFFANY D. SHOWERS, IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v I CIVIL DIVISION - LAW I c;'vi I [;;,1.,>/ THANE E. SHOWERS, I NO. 97 - "JPCj Defendant I IN DIVORCE COMPLAINT Plaintiff, Tiffany D. Showers, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, Tiffany D. Showers, is an adult individual residing at 175 Meadows Road, Newville, Cumberland County, Pennsylvania 17241. 2 Defendant, Thane E. Showers, is an adult individual residing at 175 Meadows Road, Newville, Cumberland County, Pennsylvania 17241. 3 Plaintiff and Defendant ware married on September 1, 1990, in Bloserville, Cumberland County, Pennsylvania. 4 Both parties have resided continuously in the Commonwealth of Penneylvania and in Cumberland County for at least six months prior to the oOlrumencement of this aotion. 5 The marriage between the parties is irretrievably broken. 6 The parties possess various items of r~al and personal property whioh is marital property under the Pennsylvania Divorce Code and is subject to equitable property distribution. WHEREFORE, Plaintiff requests your Honorable Court as follows I A. Enter an order divoroing Plaintiff, Tiffany D. Showers, from Defendant, Thane E. Showers. B. Equitably divide marital property of the parties. C. Such other relief as the Court deems appropriate. BROUJOS & By C)dI- (l) Hubert X. G lroy, squ~re Attorney for Pla'ntiff 4 North Hanover Street Carlisle, PA 1 013 717 - 243-4574 I verify that the statemsnts in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. ~~ tJ..J~. TI Y. SHOWERS '.'1 , , 't'.! 6 ~ ~~ ~~~ o\)\)() V)() <..., (Q ) ~ , . .~ 'VJ 0J ~ ~ t' '#: ~ ~ ~ ~, '::tl o ~ i ': 1.~'J ~') ~~;: \.;, , >4 .,. -' I',; C',-: _1 '.' ~~- ; , . ,- 'II; '1.. I ~.'.~ ;J": ~j ," ~ TIFFANY D. SHOWERS, Plaintiff IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLY ANlA v NO. 97.6289 CIVIl. TERM THANE E. SHOWERS, Defendant IN DIVORCE M'FmAYl'!' OF SERVl<:.!:; I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced mutter was served on Defendant through his attorney, Lawrence J. Rosen, Esquire, on January 15, 1998. A copy of his Praecipe rbft !J DATE for Entry of Appearance, is attached hereto and marked Exhibit A. _0/JPA_~ ~~~\I~OY, Eire Attorney for Plain f Droujos & Gilroy, P.c. 4 North Hanover Street Carlisle, PA 17013 717 . 243.4574 Sworn and subscribed . 1~ before me thiS _~ day of ~V1998 L(o .~~~~~~ ~ CJU QJA/ NOla(~- _rialS... Bri<1ott Ann~, -KltlIa Ctill... IIato, CIIIlb.rteI'd My CommI,,1on expllM J\Int 10, ie"'..'.... .- C()/pp TIFFANY D. SHOWERS Plaintiff : IN Tlill COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYI.V ANIA v. : NO. 97-6289 CIVIL 1997 THANE E. SHOWERS Defendant : IN DIVORCE TO CURTIS R. LONG. PROTHONOTARY: l'nAF.CIP.: Fon ENTRY API'EARANCa.: Please enter the appearance of the undersigned as counsellor the Defendant, TIIANE .:. SHOWERS in the above-captioned maller. Additionally, I have accepted service of the ('omplaint in Divorce on behalf of the Defendant. Respectfillly submitted, DATE: ,J,p'jfl' ./ ;..-::~- awrenc osen. Esquire' AlIorney for Defendant 1101 North Front Street Harrisburg, P A 17102 (717) 234.4583 Ally. I.D. 10625 EXHIBIT , A '" .~) it.: ~:I I , .. , t' .~ '::~ " \ , I l' : ", r-. ,..) I 1).1' '. e " , I I. I lu... ... I I ~7 .J '. (j~ -.J '. . . . ,.-"', -., v I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I 97 - 6289,CIVIL TERM TIFFANY D. SHOWERS, Plaintiff THANE E. SHOWERS, Defendant IN DIVORCE AFF IDAVIT 0.' CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on November 13, 1997. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimonr' division of property, lawyer's fees or expenses if I do not cIa m them before a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is entered by the c.~urt and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counselling. I do not request that the Court require counselling. r verify that the statements made in this affidavit are true and correct. I understand t.hat false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Datel 62h(d96 W~/% iJ,JkMltlrJU T t ny . Showers/Plaintiff TIFFANY D. SHOWERS, Plaintiff v I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I 97 - 6289 CIVIL TERM I THANE E. SHOWERS, Defendant . . I IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECPEE UNDER GEC'J.'ION .1301 (C) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on November 13, 1997. 2. Tile marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of 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 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counselling. I do not request that the Court require counselling. 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. S4904 relating to unsworn falsification to author:ities. Date: ,;;/:Jt/c;r . . .~ ....::.....-.. ""--, -~.\.~ ': '. . TIFFANY D, SHOWERS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 97-6289 CIVIL 1997 THANE E, SHOWERS Defendant : IN DIVORCE TO CURTIS R. LONG, I'ROTIIONOTARY: I'RAECIPE FOR ENTRY AI'I'EARANCE Please enter the appearancc of the undersigned as counsel for the Defendant, THANE E. SHOWERS in the abovc-captioned matter, Additionally, 1 have accepted service o:'the ('omplaint in Divorce on behalf of the Defendant. Respectfully submitted, DATE .J. J11Lf;: J /~ ~~~~;,~~;;;~--'-- ---- , " Attorney for Defendant 1101 North Front Street Harrisburg, P A 17102 (717) 234-4583 Ally, 1.0, 10625 In " , ,