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Home My WebLink About00-07175 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . , . ;. '-- , ~--, '",O"_=, ..J_~ w . . . . . . '" "'ff. "':F. ;F. . .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROSANNA E. SHUGHART, No. 00-7175 CIVIL TERM PLAINTTFF VERSUS EMMANUEL S. SHUGHART. DEFENDANT DECREE IN DIVORCE AND NOW,~)"ve......Lu 2..0 , 2001 , IT IS ORDERED AND DECREED THAT ROSANNA E. SHUGHART , PLAINTIFF, AND EMMANUEL S. SHUGHART , 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 . .. . . . . BYTH~T: AnT~ PROTHONOTARY . , ~ ",. " , "1iii~",. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . " ~=" '-. ""," ""-I'''~''-''-~< 7~"',' -~--" ""..,,,", .-"".---'""^"' ~'-'~-rl"-'__'-',N~' ,,-=;.,-, ".,--w.;"-_'__'_"_I'~-_'<'",""""",""""''''_'''~~'-----"";;"lliI1ft",:,],.1"j" , . ....... ." 1(;;/,(// MC7*?_~~' 4~ /ld/.~I 7f~ ~ ~ ~ - - eo ~_ "_ ~~~. ~, F=.~rfJ,~~!.'!~~~~~!\lij~,~i!!I\lMJln'm;!\\'!I.~fI!!iIII!l, .~.,: - '-~~i!;f~0;.,.__ ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 00-7175 CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE 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 S3301(c)(1) of the Divorce Code, 2. Date and manner of service of the Complaint and Notice to Defend and Claim Rights: received by Defendant on October 31, 2000, as shown by his signature on the attached Acceptance of Service filed with the Court. 3. Complete either paragraph (a) or (b), (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff November 6, 200 I; by Defendant November 6, 200 I. (b) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: NI A; (2) Date of filing and service of the Plaintiff's .affidavit upon the respondent: NI A 4. Related claims pending: Nm1e.. 5. Date of filing the Notice of Intention to Request Entry of Divorce Decree Under Section 3301(c) was filed with the Prothonotary: by Plaintiff November 19, 2001, by Defendant November 19, 2001. ~~~ 701 East King Street, Shippensburg P A 17257 (717) 532 - 9476 Attorney forPlaintiff lliilb'"' "'~iM~~~~~j",Wh,,,;,;;;i~iO!.'R"i_.;,!t;<:~l. ')"_~'!,l_,*hl'N"i-'-'m""" ,- " ~_ , -~>-c: ,..~ ,-~ , ^__,,~, _~""'n'_",_>-' lUaII_t"'''''' - '''~ltlilUi~:iiI,\![i!i'''-"'"- ,-., ~ () Q f; 0 :-0 ~~ 2: .., OJ -., fYg:; 0 '~ <:.- '; "'" ,-::i-'l.:n <r' C6J> 1.0 -(';in ~~., c~i ~C:} '" ::b1.. $l:J ::;.~ .::::::6 Pc: - ~?! C) - rn 2: 0 =< w ..~ d-:-"': f..) .lJ -< . '-"'- 'I, ,--,'--",-'~, ." ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: OD- 7/1,-) CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One South Hanover Street, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNiJLMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE PA 17013 (717) 249 - 3166 ~!hinJE{!L~ Attorney for Plaintiff, ROSANNA E. SHUGHART 701 East King Street Shippensburg PA 17257 (717) 532 - 9476 , ~, d< ., , ,I "l _," , -- ""-~'~":$( ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: H-.. 7l"2s" CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant COMPLAINT IN DIVORCE COMES NOW, the Plaintiff, ROSANNA E. SHUGHART, by and through her counsel, Sally J. Winder, Esquire, and represents as follows: 1. Plaintiff is ROSANNA E. SHUGHART, who currently resides at, and whose mailing address is, 2348 Ritner Highway, Carlisle, Cumberland County, Pennsylvania, since May, 1999. 2. Defendant is EMMANUEL S. SHUGHART, whose last known mailing address is, 1469 Shughart Road, Carlisle, Cumberland County, Pennsylvania, since July 1999. 3. Both Plaintiff and Defendant have been bona fide residents of 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 June 27, 1998 at Carlisle, Pennsylvania, 5, There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. - ,-- J,-._. ,1.-" '-.,'J. ,," ~"-' 7. Plaintiff avers that she has been advised of the availability of counseling sessions for both parties upon request of either party or by order of court, and that a list of qualified professionals who provide such counseling service is available at the Domestic Relations Office upon request. By the filing of this Complaint, the Plaintiff acknowledges having been advised by her attorney of record of the availability of counseling sessions and of a list of qualified professionals. Plaintiff further avers that she has been advised that the choice of a qualified professional shall be at the option of the Plaintiff and Defendant and need not be selected from the list available upon request and, further, that arrangements for and the payment of the services of the qualified professional shall be the responsibility ofthe parties and will not be included in the docket costs of this proceeding. 8. Plaintiff requests the Court to enter a decree of divorce. ~~;r,l!!u0-- . Attorney for Plaintiff, ROSANNA E. SHUGHART 701 East King Street Shippensburg PA 17257 (717) 532 - 9476 Date: /D) /1/ 6D t ( .rom diskctte~d. . . "" [" ~ 'i'" . ., ' "<~- VERIFICATION 1 verify that the statements made in this complaint are true and correct to the best of my personal knowledge and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date:/O/; 7 J b 0 I ' ~~ -~ ~-~..~" ~ i~"ij_~,.o'-, ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 00-7175 CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 17,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I 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 are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. section 4904 relating to unsworn falsification to authorities. Date: b; /vOl! ZoO I , ~u..~ ROSANNA E. SHUG ;'11. -";''''''.''i~~~li;,\;j''-~.il.J;.jlli~I;\,''~,",.;l;-.wii';'Oill~l1iliil~~;~id~''".i- "'f~--'~p""Y.'A '_~llilioi~i1!l-"""~ - 'r"",-,:"mJL,^"-",, _,~~._~__"' _ ,o~__"__h'"~_ .,,.,,, ."-"",,,. _,",_~,.__"i."_""""~ ,~-,,_-?,,~. .,,,,__~,,, ,,<,,~~I ~_-_"~'~_' -_~^_, ,,"', __r_~~ "~ Ll 0 C> 0 C --n ~ Z _"cJ -oeL: D rn 0:: .-- ['-iii~ :2_\. JF? zS;= '"0 ~,L .~~ t<C) """ ::;p.r~ =,:;: z,""":: --C.J - J>c: .' --' Z (.t.) ~ ~ r0 -< ~- . - ~ I ~~ '"~"~h<~~'\\-__\ ROSANNAE. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 00-7175 CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 17, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I 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 are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. section 4904 relating to unsworn falsification to authorities. Date: If - (, - () ( ~/~ EMMANUEL S. SHUG T ;.~ ~~~#lAi~ill.i.nIMl;,,:iii~"""'i'_Sk,.,;,".ill!i--$lliiiMi\E~.i:iM'lIIllllI~tlilllBiMl;""'~" ~-!'_lOlii;i!;li>l;iR-"""\{li'" lii ,'--' ".}',"' --~" ~~-=~~ "-~,~~ ._,,<, '-'"-' ,~__~. , __ '."n. . '"_' ~w ,~I, . o c: s: -o-t::tJ mm 2'1! 2::;:- cn.P -<-'"10- r-' C'-. ,;.:- ~o -<':.r-{ ;S'-' ~ .;;:J -< - C> C) " """ C5 ~ ;'{'ipo :",fT, ~~~;; f5F~ 'i::! 55 -<: '.0 ,:D..,. ::a: - - w r" ~ ~J . , ..........~"'"&'''''...'''',''"',,,,', ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 00-7175 CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. section 4904 relating to unsworn falsification to authorities. ,~~ .t./M1J)t~ hi ROSANNA E. SHUGHAR Date: G Nov .2. {)O I --~1., ~~~~ih',~",jg...!:,'iai<!;""li.;;;p~r;o")""'h,,>-,.i;t;",dl:-~'T.~ -~ ~ ~,,- , -~,,'>'_.'-"'~,~~ >-... Iior~~ . - 'iili!~-- _~,_, w.,_'o<-_"_""''-~''_ ~_-.__-~.""-_~'~___"_-< d- "_~'~"-""'.",.,,-~,-_^ _~,I,_" '.'_, ~~"" -~..~ () S :$; fRee ~fJ3 C/};; - ~.rS \.0 .P- :b :CeQ ::?: :s- _ s;:. - =Ii <:0 r", <::> o .., S "<::: :-ii ,::'i-ijJJ ~-f:t! c:s::B ~?C) c1Cl1 ';;! :5 -< . '_ I ~"~ .~~"""""'" ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 00-7175 CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant 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 of divorce without notice. 2. 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. 3. 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. 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. section 4904 relating to unsworn falsification to authorities. Date: 11- t:, - 6 I E~~ filII' j'1iiDl~~~lNiiil!!W>~JF";~:llt;L~~'"'''-'"'t;'f-i.liI'''''~",,\If~'mu,t-'.M'~-~''' -~" -"'I\l~"-"~",,-~ -,_. ~.., ~> " ~-~. &h~-"-!Jt~-~_ "' ~~-, 'I 0 C 0 c: -~ -'1 -05:1 Z _.i mlj] c:> -hJ2 2...1 ,,<= 21] i~;~~~ (f)':> '.0 -<:2:: \S::C .,~ J""~ --'r-',-, ~O :x :.~ 'Tl ~.r') >8 - om - ~ w ;;! :a N -< """""lll~ 11 ~.~ " - _"",""_~'.!l(,,' ROSANNA E. SHUGHART, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 00-7175 CIVIL TERM EMMANUEL S. SHUGHART, IN DIVORCE Defendant ACCEPTANCE OF SERVICE I, Emmanuel S. Shughart, do acknowledge that I have received a true and correct copy of the Complaint in Divorce and Notice to Defend and Claim Rights in the above-captioned divorce and accept the service thereof on ()c.tobe.r '51 ,2000. I verify that the statements made in this Acceptance of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.S. Section 4904 relating to unsworn falsification to authorities. Date: II - ~ - 0 I ~~ Emmanuel S. Shughart "'~':iilW~ it:4)1W__~~i&ill&~kid!ill>t",,;.o;f'-"fofu:;:;;ii~jJiMjf.iliifj ~"" ~-.~~1<llI 0 <:::> 0 c " - s. Z :::;::1 -Pro 0 :_-...,...., mm ,,<::::: ;; I ~.-'...! Z:X:1 ,- Zr;:- ~~?'d ~~- \.0 L.. ~:~~!~ <,0 :>> ;0. .;1; -H zQ - ;7Q ~u On, Pc ~ w ::;;! (.J ~