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HomeMy WebLinkAbout07-1481Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. © ) - 1y9f CIVIL 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 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. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 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 Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. d 7-/1S-( CIVIL IN DIVORCE NOTICE REGARDING THE AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prepared by: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 DAN_REGAN@C OMCAST . NET Shawn Donohoe, Plaintiff V. Lauren Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 47-Iq l CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Shawn P. Donohoe, who has been residing at 719 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, since April 2004. 2. Defendant is Lauren C. Donohoe, who has been residing at Apartment 201, 7 East Front Street, Shiremanstown, Cumberland County, Pennsylvania, since September 2006. Defendant's mailing address is 7 East Front Street #201, Shiremanstown, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 7, 2004, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between Plaintiff and Defendant. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage between Plaintiff and Defendant is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require Plaintiff and Defendant to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 25 Pa.C.S. § 3301(c). Dated: March 13, 2007 Respectfully submitted, DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Shawn Donohoe, Plaintiff VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. Dated: '31a147 41e? 1)4re?? Sawn Donohoe, Plaintiff -2 - Shawn Donohoe, Plaintiff V. Lauren Donohoe, 1 Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Dan Regan, certify that I have this day served a true and correct copy of the foregoing Complaint by delivering same to Defendant personally. DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Shawn Donohoe Plaintiff Dated: March 15, 2007 n o ra o a F ) Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07- 1µ8I CIVIL IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the "Complaint Under Section 3301(c) of the Divorce Code" in the above captioned matter. C?tTJOn?f?-?w"?, ren C. Donohoe, Defendant 7 East Front Street #201 Shiremanstown, PA 17011 Dated: 311 U 07 -n r C-io 0 Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-1481 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 15, 2006, and an Acceptance of Service was signed by Defendant on March 16, 2007 and filed March 19, 2007. 2. The marriage of Shawn P. Donohoe, Plaintiff, and Lauren C. Donohoe, Defendant is irretrievably broken. Ninety days have elapsed since the date of service of the Complaint. 3. 1 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 of Consent are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. ?Ai7 Shawn P. Donohoe Dated: C -' C :?- Ln X- -G a Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-1481 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 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. 3. 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. I verify that the statements made in this Waiver of Notice are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authoriti s. wn P. Donoh Dated: t,- ?,1 ?? .-: ?.:= t3? `??. -s° a? ..- ?£? s ? ..? t" 0 Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-1481 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 15, 2006, and an Acceptance of Service was signed by Defendant on March 16, 2007 and filed March 19, 2007. 2. The marriage of Shawn P. Donohoe, Plaintiff, and Lauren C. Donohoe, Defendant is irretrievably broken. Ninety days have elapsed since the date of service of the Complaint. 3. 1 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 of Consent are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dated: u 11107 0-7 Lau C onohoe, Defendant G ?~'' `, ; - ?_ t? •= ? ? ?+ ?. ,?" Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-1481 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that notice of the decree will be sent to me immediately after it is filed with the Prothonotary. verify that the statements made in this Waiver of Notice are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to author ies. l u ur C. onohoe Dated ?- n 0 *116 Shawn P. Donohoe, Plaintiff V. Lauren C. Donohoe, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.07-1481 CIVIL IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree. 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Personal service by Dan Regan, Esq. in Lemoyne, Pennsylvania, on March 16, 2007, per Acceptance of Service filed March 19, 2007 3. Date of execution of Affidavit of Consent required by § 3301(c) of the Divorce Code: By Plaintiff: June 19, 2007. By Defendant: June 17, 2007 4. Related claims pending: NONE. 5. Date Plaintiff's Waiver of Notice under § 3301(c) of the Divorce Code was filed with the Prothonotary: June 25, 2007. Date Defendant's Waiver of Notice in § 3301(c) of the Divorce Code was filed with the Prothonotary: June 25, 2007. 6. Plaintiffs Social Security number: PLACEHOLDER Defendant's Social Security number: 060-74-9367 Respectfully submitted, n??4, DAN REGAN-' Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: June 25, 2007 -2- C'? rv ca° C? c_q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SHAWN P. DONOHOE No. 07-1481 Cdr. VERSUS LAUREN C. DONOHOE DECREE IN DIVORCE AND NOW,T.,pt Z!: , ZDO?, IT IS ORDERED AND DECREED THAT SHAWN P. DONOHOE , PLAINTIFF, AND LAUREN C. DONOHOE 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; BY THE COURT: ATTES u J. Z4 C-'r PROTHONOTARY Ca ° 6,& f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S`hawrt P 1DoI1,ho.0 . Plaintiff Vs File No. 07 - /qg / IN DIVORCE Laccrtri C Donohoe Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated a7 ?007 hereby elects to resume the prior surname of it arf n eZ , and gives this written notice avowing his / her intention p t to the provi ions of 54 P.S. 704. Date: ,2-2av 'gnature Signature of a being esumed COMMONWEALTH OF PENNSYLVANIA } COUNTY OF ) On the /c?-f'-day of 200i , before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. SEAL PROMONOTARY NOTARY CAALI$I.EBERLANp PMtC Cm WANcommm MY 10MMIMON EVIRES dAN M 4 Pr thonotary or Notary Public y rn U ^ ?Y ?.3 Ott ? E? ? 9!