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HomeMy WebLinkAbout07-1246DANIEL L. SHUGHART, Plaintiff V. CANDICE A. SHUGHART, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007- 4;X/6 CIVIL : CIVIL ACTION-LAW 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 at the Cumberland County Court House, Carlisle, Pennsylvania. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU,CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 ... DANIEL L. SHUGHART, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007- 1-741 CIVIL CANDICE A. SHUGHART, CIVIL ACTION-LAW Defendant DIVORCE COMPLAINT 1. Plaintiff is Daniel L. Shughart, an adult individual who currently resides at 1471 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Candice A. Shughart, an adult individual who currently resides at 51 Hickory Drive, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 10, 2005, in Newville, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 6. Neither Plaintiff nor Defendant is in the Armed Forces of the United States. 7. Plaintiff avers that the marriage between the parties is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. Respectfully submitted, O'BRIEN, BARIC & SCHERER 01? 4??' Michael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff DATE: 3, - 0 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Danie . Shughart 3, o?l Date: i Vc?` re c? \lA? ?'Jr V V O A Q } ^ O PO r7 ::?1 DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 D AN_RE GAN@C OM CAST . NET Daniel L. Shughart, Plaintiff V. Candice A. Shughart, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-1246 CIVIL ENTRY OF APPEARANCE I hereby enter my appearance for Candice A. Shughart, Defendant in the above matter. Respectfully submitted, DAN REGA Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: March 22, 2007 N c) f' c G DANIEL L. SHUGHART, Plaintiff V. CANDICE A. SHUGHART, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- 1 ?\qll CIVIL CIVIL ACTION-LAW ACCEPTANCE OF SERVICE AND NOW, this -4 day of MarC4 , 2007, I, Candice A. Shughart, Defendant above, hereby accept service of the Divorce Complaint filed in the above- captioned case. ice hughart szz, _ r- .+ti ?(• VSO ,.y ^ ?)J_: b DANIEL L. SHUGHART, Plaintiff V. CANDICE A. SHUGHART, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007- 1246 CIVIL : CIVIL ACTION-LAW DEFENDANT'S AFFiDAViT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 March 7, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 1 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. 1 have been advised of the availability of marriage counseling and understand that i may request that the court require counseling. 1 do not request that the court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: tza.Q 16? co ?- Candi A. hart 3 "l ?? ^ ? t ? , ? Gr -?' ?'' fid? t -' - mow. ,' 1'' . ?f DANIEL L. SHUGHART, Plaintiff V. CANDICE A. SHUGHART, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- 1246 CIVIL : CIVIL ACTION-LAW PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 March 7, 2007. 2. Defendant signed an acceptance of service form on March 15, 2007. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 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. 6. 1 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. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. 1 Date: 0d ° `7 Daniel L. S ghart r? C a . ' .... <? ? -r? ?;r" ? ?-z-t s t ? s t ?.?-t-E ? ?? fi 'U;,7 ?- ' ?" x.i ?"". {? "'.. ?? L _. ?? ? -? ?,. DANIEL L. SHUGHART, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007- 1246 CIVIL CANDICE A. SHUGHART, CIVIL ACTION-LAW Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Defendant signed an acceptance of service form on March 15, 2007. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on June 20, 2007; and Defendant on June 18, 2007. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, hI N,QA C H n ?I ! ?t,-. . Michael A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Q cx) t ; .. :.. J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DANIEL L. SHUGHART, Plaintiff VERSUS CANDICE A. SHUGHART. Defendant NO 2007-1246 Civil No. DECREE IN DIVORCE AND NOW, D7, IT IS ORDERED AND V V DECREED THAT DANIEL L SHUGHART PLAINTIFF, AND CANDICE A. SHUGHART I 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. PROTHONOTARY ?rna 469 '?