HomeMy WebLinkAbout01-04465IN THE COURT OF COMMON PLEAS
SHARON R. CYRON
VERSUS
RONALD S. CYRON
Defendant
N O. 01-4465
CIVIL ACTION -LAW
DIVORCE
DECREE IN
DIVORCE
AND NOW, ~rca,,,/..~ 7 ~ 26+~ IT IS ORDERED AND
DECREED THAT SHARON R. CYRON PLAINTIFF,
AND RONALD S. CYRON 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;
PROTHONOTARY
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SHARON R. CYRON,
Plaintiff
v
RONALD S. CYRON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ol - 4465 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
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. Grounds for divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: Service was by Plaintiff's previous
counsel, Michael Kane, Esquire, evidenced by the filing of Defendant's Acknowledgement and
Acceptance of Service on July 31, 2001.
3. (a) Date of execution of the Plaintiff s Affidavit of Consent: November 7,
2001; Defendant's Affidavit of Consent: November 7, 2001.
4. Related claims pending: No claims were raised.
5. Date of filing of Plaintiff s Waiver of Notice: November 26, 2001. Date of filing
of Defendant's Waiver of Notice: November 26, 2001.
Respectfully submitted,
HOFFMAN LONG LLP
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Richard W. Long, Esq e
Date: ~~f,Z7~0~
Sup. Ct. ID # 79152
P.O. Box 11475
Harrisburg, PA 17108-1475
(717)233-1112
Attorney for Plaintiff
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SHARON R CYRON, COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. v J- N ~P ~ s ~,:-Q 7-.~.-.
CIVII. ACTION-LAW
RONALD S. CYRON,
Defendant IN DIVORCE
NOTICE TO DEFENDANT AND CLAIM OF 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 aze warned that, if you fail to do so, the case may proceed
without you and a decree of divorce or annuhne~ may be entered against you by the Court. A judgment may
also be entered against you for any 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 grounds for divorce is indignities br irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's office at the
Cumberland Courrty Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FH.E A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT I5
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 OUR WHERE YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Cumberland County Courthouse, 4th Floor
Carlisle, PA 17013
(717) 240-6200
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available
to disabled individuals having business before the court, please contact our office. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
Michael 7. Kane Reg. No. 46215
Kane and Mackin, LLP
3300 Trindle Rd.
Camp Hill, PA 17011
(717) 214-3700
Attorney for Plaintiff
SHARON R CYRON, COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. o l- y ~fGS' ~Q T:e..~--
CIVIL ACTION-LAW
RONALD 5. CYRON,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(C) AND 3301(D) OF THE DIVORCE CODE
COMES NOW, Sharon R. Cyron, through her attorney, Michael 7. Kane, Esquire, and avers
as follows:
COUNT ONE -DIVORCE
1. Plaintiff, Shazon R. Cyron is an adult individual, whose current address is 13 Clover
Lane., Mechanicsburg, Cumberland County Pennsylvania 17050.
2. Defendant is Ronald S. Cyron, who resides at 925 Spring Circle, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
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. The Plaintiff and Defendant were married in October 7, 1995 in Mechanicsburg, PA.
5. There have been no prior actions of divorce filed in this matter.
6. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United States.
7. The marriage is irretrievably broken and the parties are proceeding under Section 3301 (c)
and 3301 (d) of the Divorce Code.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right
to request that the court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests the court enter a decree of divorce.
COUNT II
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502(a) OF THi; DIVORCE CODE
9. Plaintiff and Defendant have acquired marital property as defined by the Divorce
Code, which is subject to equitable distribution pursuant to Section 3502(a) of the
Divorce Code.
10. Plaintiff and Defendant have been unable to agree as to the equitable division of said
property as of the date of filing of this Complaint.
11. Defendant requests that this Court equitably divide, distribute or assign the marital
property between the parties.
WHEREFORE, Defendant respectfully requests that the Court enter an order of equitable
distribution of marital property pursuant to Section 3502(a) of the Divorce Code.
Respectfully submitted,
Michael 7. Kane No. 46215
Kane and Mackin, LLP
3300 Trindle Rd.
Camp Hill, PA 17011
(717) 214-3700
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in this complaint are true and correct to the best of
my information and belief. I understand that false statements herein are made subject to the
penalties of 18 P. S. § 4904 relating to unsworKn~lf~~a~l~siUfi~c~,at~'io~n~t~`o• authorities.
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SHARON R CYRON, COURT OF COMMON PLEAS
plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 01-4465 Civil Term
CIVIL ACTION-LAW
RONALD S. CYRON,
Defendant IN DIVORCE
PRAECII'E TO FILE RETURN OF SERVICE
AND NOW, Michael J. Kane, Attorney for Plaintiffhereby submits Defendant's
Acknowledgment and Acceptance of Service in the above-captioned case.
Respectfully submitted,
Ill,\~--
Michael J. Kane eg. No. 46215
Kane and Mackin, LLP
3300 Trindle Rd.
Camp Hill, PA 17011
(717) 214-3700
Attorney for Plaintiff
SHARON R CYRON, COURT OF COMMON PLEAS
Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA
v.
RONALD S. CYRON,
Defendant
NO. 01-4465 Civit Term
CIVIL ACTIOI~T-LAW
IN DIVORCE
ACKNOWLEDGMENT AND ACCEPTANCE OF SERVICE
I Ronald S. Cyron acknowledge that I am the Defendant in the above-captioned case and that a
copy of the complaint for divorce has been sent to me by certified
Date: 7~~"~ ~~
Ronald S. Cyron
925 Spring Circle
Mechanicsburg, PA 17055
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SHARON R. CYRON, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. Ol - 4465 CNIL TERM
RONALD S. CYRON, CNIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on July 24, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of 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. §4904 relating to unsworn
falsification to authorities.
Date: /~- ~' ~ ]
RONALD S.CYRON
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SHARON R. CYRON,
Plaintiff
v.
RONALD S. CYRON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01 - 4465 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
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.
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 aze true and correct. I understand that
false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities
Date: ~~- 7~U~
RONA D S. CYRON
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SHARON R. CYRON,
Plaintiff
v
RONALD S. CYRON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ol - 4465
CIVIL ACTION -LAW
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that Sharon R. Cyron, Plaintiff, after the entry of a Final
Decree in Divorce dated December 4, 2001, hereby elects to resume the prior surname of
MILLER, and gives this written notice avowing her intention pursuant to the provisions
of 54 P.S. § 704.
Respectfully submitted,
HOFFMAN LONG LLP
BY: ~ V" +
RICHARD W. LONG, ES
Supreme Court LD. #79152
105 North Front Street
P.O. Box 11475
Harrisburg, Pa. 17108-1475
(717)233-1112
~ Attorneys for Plaintiff
Dated: d ~ d~
VERIFICATION
I, Sharon R. Cyron, verify that the statements made in the foregoing document are
true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities.
Sharon R. Cyron
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SHARON R. CYRON,
Plaintiff
RONALD S. CYRON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. O1- 4465 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on July 24, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of 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. §4904 relating to unswom
falsification to authorities.
Date: l ~ 7 0~
HARON R. CYRO
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SHARON R. CYRON,
Plaintiff
v.
RONALD S. CYRON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ol - 4465 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
&3301(c) OF THE DIVORCE CODE
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. §4904 relating to unsworn
falsification to authorities
Date: / 7 0 /
R. ~-..
SHARON R. CYRO
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