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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF /i~~~~' PENNA,
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TIFFANY D. SHOWERS
6289
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97
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PLAINTIFF
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THANE E. SHOWERS
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DEFENDANT
AND NOW, ' , , .
DECREE IN
D I V 0 R C E J 1:'-11/, "".
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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
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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
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. 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.
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TI Y. SHOWERS
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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(~-
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Bri<1ott Ann~, -KltlIa
Ctill... IIato, CIIIlb.rteI'd
My CommI,,1on expllM J\Int 10,
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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'
./
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awrenc osen. Esquire'
AlIorney for Defendant
1101 North Front Street
Harrisburg, P A 17102
(717) 234.4583
Ally. I.D. 10625
EXHIBIT
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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:
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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 /~
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, " Attorney for Defendant
1101 North Front Street
Harrisburg, P A 17102
(717) 234-4583
Ally, 1.0, 10625
In
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