Loading...
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 ;~ ~s ~~~~.~ so_Ji~ ~°~ ,~.~~~, L. 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 ~- 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 •:.9 ~' _~ C3 C< 1 °' _ ~i, ~ ` ' o ~ ~ ~ :~. ., ~x _ -~ cwt _ . . i~- _ . ' 7 ~ .I (~ ~~ T Ccc~ C~ ~o' ist-Nw, 's ' >azNR s,nc4iGhM-~, }A~I~RA~ 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. 7• a3-o~ ~' Date laintiff ~ ~~ c ~~ ~ -~~ ~ z ~~ ~ ~, \ W 0 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 ~S ~e 0 w .o a 3 :: ~: ; ; ' ~` 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 Social Security #: Z°j--S 2- ~ ~ 6~ c= _. `;; 'U ir` Phi Pi: ~7 - -°:-?- I `~ r:~ , LfJ~c. cY, - . ~:; :%C _~ -W ~ i q ~ h7 .~:' ~-.i J' ,JF fti? CS £O f ~' .~ eF.1~~Y:`tfRi.c i+Ei::: d kt. u:.;- d ,.rzrp;~fryn,~+b`H~afi!x.=M13r45Eai~~W~'-+i4"SEN75f 5~ ;. 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 asset i c, u~ c, -a e~~ ~' c? - ~r~, ~~ ~ - ~ ~ ? ~c ` ~, "` ~ _.~ _i = :~~ %~ c i`` c.; r _ N ~ ~:; .,~ =< in N ~~ 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 Date: lj ~~ ~ ni rj i F -^~ I \ ~ Z.~ ~.~. n : ~..7 •~ ~ \(1J } ~-_ t_ _ r ~ ~1 ~ ~J V7 ., r -c. :n __ .- ~ ~~ ~ ~ ~_, ~ '~ :may i -~ o 3 <,~ ~5 ~o .~ 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 Social Security #: (~Iw~-(0'7 '~~-7~. ('3 ~ ~) C. -" ~ i xv cz; ~ _ ~:'; ~t-i, ~ N ' ,. _ _ `_ j 4/~ _.c: -C ~,.. CF s ~ 1. rte' ;,_. } ~ ~ ,, -~~, . ~~= t~a ' _ :~ :=, '~ `:. --C Ev -< 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 ass~o ~ r-. G- .t cJ ~i~; a C ~`~ i ;__ f~3 r t ~; .n . __, 'fi'r. ~ ~) " . J ~.S ~0 ~ .. ±a6=e.. ". iQ dam :Yx"-t9» ., .:e;,= ,+a.'r±4*,'•~.",'A~3~. ~n"~-~ ",::~'-