HomeMy WebLinkAbout01-05485
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
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BAMBIE R. LOWER
VERSUS
SHANE M. LOWER
N p, 01-5485
DECREE IN
DIVORCE
AND NOW, ~+ 11~~7 C ~ 2002 IT IS ORDERED AND
DECREED THAT BAMBIE R. LOWER PLAINTIFF,
AND SHANE M. LOWER ,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;
ALL CLAIMS RESOLVED.
By THr Co
ATTdS1T
J.
PROTHONOTARY
BAMBIE R. LOWER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA
vs. NO. 01-5485
SHANE M. LOWER, CIVIL ACTION -LAW
Defendant 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. Ground for divorce: irretrievable breakdown under Section 3301(d)(1) of the
Divorce Code.
2. Date and manner of service of the complaint: November 5, 2001 by certified
mail/restricted delivery/return receipt.
3. (B) (1) Date of execution of the plaintiffs affidavit required by Section
3301(d) of the Divorce Code: April 13, 2002;
(2) Date of filing and service of the plaintiffs affidavit upon the
defendant: Filed April 19, 2002 and served April 30, 2002.
4. No Counteraffidavit has been filed to Plaintiffs Affidavit under Section
3301(d) of the Divorce Code and therefore the averments of the same are deemed
admitted.
5. Related claims pending: None.
6. Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached, if the decree is to be entered under Section
3301(d)(1)(i) of the Divorce Code: Served June 21, 2002 by certified mail/restricted
delivery/return receipt.
WHEREFORE, the Court is requested to enter a final Decree in Divorce in
compliance with Section 3301 (d) of the Divorce Code and Pa. R~C.P. '~9?0.42(a)(2).
Je~n~#~r L. Frechette, Esquire
Dated: July 12, 2002 Att ney for Plaintiff
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BAMBIE R. LOWER,
Plaintiff
v.
SHANE M. LOWER,
Defendant
IN THE COURT OF COMMON PLEA5 OF
CUMBBRLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
IN DIVORCE
NO. O1-~,~ CIVIL TERM
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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE 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 OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717)-249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the American 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 lease 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
BAMBIE R.LOWER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION- LAW
IN DIVORCE
SHANE M. LOWER,
Defendant NO. O1-_~ $s CIVIL TERM
DIVORCE COMPLAINT
The plaintiff, Bambie R. Lower, by her attorneys, the Family Law Clinic, sets forth the
following cause of action for divorce:
COUNT I.
DIVORCE UNDER 23 Pa. C. S. SECTION 3301 (c , 3301 ~d, , 3301 a)(5) AND 3301 (~61
1. Plaintiff is Bambie R. Lower, who currently resides at 39 Cold Springs Road, Carlisle,
Cumberland County, Pennsylvania, since January 2000.
2. Defendant is Shane M. Lower, who is currently incarcerated at State Correction
Institution, Camp Hill, Cumberland County, Pennsylvania 17001, since Sept 18, 2000.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. Plaintiff and defendant were married on March 5, 1999, in Towson, Maryland.
5. Plaintiff and defendant have lived separate and apart since January 5, 2000.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
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8. Plaintiff avers that defendant, in violation of his marriage vows under the laws of the
Commonwealth of Pennsylvania, has offered such indignities to the person of the plaintiff, his
injured and innocent spouse, as to render the condition of the plaintiff intolerable, and life
burdensome.
9. Plaintiff avers that Defendant was convicted of, inter ah receiving stolen property, in
the Court of Common Pleas of Perry County, on April 10, 2000. On July 13, 2000, Defendant
was sentenced to imprisonment for not less than 2 years nor more than 5 years. A true and
correct copy of the Order accepting Defendant's guilty plea and Sentencing Order is attached as
Exhibit A, and incorporated herein by reference.
10. Defendant was also convicted of driving under the influence, in the Court of
Common Pleas of Dauphin County. On September 18, 2000, Defendant was sentenced to
imprisonment for not less than 10 days nor more than 24 months. A true and correct copy of the
sentencing record is attached as Exhibit B, and incorporated herein by reference.
11. Plaintiff is an innocent and injured spouse.
12. 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.
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WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
marriage.
Date a-~-6 ~ ~,~., P. ~~,----
Matthew P. Hughson
Certified Legal Intern
L
H S M.PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717)-243-2968
VERIFICATION
I verify that the statements made in this Divorce 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 unswom falsification to authorities.
Date: . 'U -' U J
Bambie R. Lower
EXHIBIT A
NWEALTH :IN THE COURT OF COMMON PLEAS
:OF THE 41ST JUDICIAL DISTRICT
V. :OF PENNSYLVANIA-
:PERRY COUNTY BRANCH
M. LOWER :NO. 465 of 1999
O R D E R
AND NOW, July 13, 2000, sentence as to the offense of
ceiving Stolen Property is that the defendant pay the costs
f prosecution, make full and complete restitution, and undergo
sonment in a State Correctional Institution for a period
f not less than two (2) years, nor more than five (5) years.
Sentence as to the offense of Driving Under the Influence
s that the defendant pay the costs, pay a fine in the amount
f $300, and undergo imprisonment for a period of not less
han thirty (30) days nor more than one (1) year. Sentences
s to all other offenses are that the defendant pay the costs
f prosecution and make full and complete restitution which
hall include costs and expenses necessary to extradite the
~~~....a..~.
All sentences shall date from-dats of commitment and
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un concurrent with each other: ~`.-
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It is the recommendation of this tburt_that the defendant
e favorably considered for the foot C~~tnp program available
t the State Correctional Institution Y.evel.
The Sheriff of Perry County is directed to transport
prisoner to the State Classification and Diagnostic Center
t Camp Hill, Cumberland County, Pennsylvania for execution
sentence.
CERTIFIE~~~RUE C Y
PRO NOTARY~~/ v/c o v.1g
~~n~rvnn ASR ~ s
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COMMONWEALTH IN THE COURT OF COMMON PLEAS
OF THE 41ST JUDICIAL DISTRICT
v• OF PENNSYLVANIA
PERRY COUNTY BRANCH
SHANE M. LOWER N0. 465 of 1999
O R D E R
AND NOW, April 10, 2000, the defendant having appeared
with counsel, Daniel McGuire, Esquire, and tendered pleas of
guilty to all counts in the Information, including the summary
offenses, the plea is accepted.
A pre-sentence investigation report is hereby ordered
prior to sentencing. According to the plea agreement, the
defendant would receive a 2 to 5 year state prison sentence,
with the recommendation of Boot Camp eligibility.
BY THE COURT:
cc: DA's Office
Daniel McGuire, Esq.
Tpr. Taylor, PSP
Probation
File
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- DC - 300B (PART 1) Sentencing
(Rev. IO-BS) '
COURT COMbIITMENT
STATE C¢RRE a4L INS11'fITIl'ION
Cb!mrnonweat~P,elaosy~°a~a ""~~n`
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T~miiuv -.Clinno 1LfirkEinT - _ . .. ,_... _..._ ,
Type or Print Legibly
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COMMONWEAE.'FH,QF PENNSYLVANIA
DEP.+Y1rhT1~P Q11;~ECTIONS _
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NOTE: Addit[otisl s~p~y of form avaz7able at above ~. .
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address: .. ,_._ ,___.__ _.,..., - .:
.-' ^ ..DG300B. (Part Il) attached
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_ . __,-_,,_.....Dauphtn ..__.__._ ~ . _..,. 2081 CD 99 I 9/18/1000
The above defendand, after..," ` . """ ®pleadmg gmlty ""~--^ nolo conteadre - -- E} beingfoond gu>7ty was on ; -
September IBth 2000 'sentencedTiy JudgelDistnct Justice "°Hon. Scott Evans "' ° to a tezm of
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. nor mote than ~..._~.___... __-- . -__.
not less than years..... months 10 days "_ __, .
years 14 months days, of
for the offense of DUI
(Section 75 §3731 A2 ' - - of the Crimes Code) or (other statute)
It is further ordered that the said defendant be delivered by the proper authority to and treated as the law
directs at the SCI Camp Hill facility located at P.D. Box 8837,
FMF f'l1STS RF_STTTT
avtouNT s 600.00 AMOUNT s pending
So Be Paid To: ~ To Be Paid By:
J() IC COUNTY n COMMONWEALTH n COUNTY ~ DEFENDA.N'C
Hill, PA 17011
September 18, 2000
conczzr.w.Judge Quigle of Perry Co.
Boot Camp Elig
Ct. IA to pay $25.OOf:ne plzzs cost.
?CIJfING ATCORNEY ' DISPOSmO\ OF NO:1-L~CaRCERATION OFFENSE(S)
Curcillo
SSE ATCOR.YEY
Robinson
i REPORTER
Rigby (TERS BLOCK NOT i0 BE OSED FOR INCARCERATION OFFENSE)
In witness, whereof I have hereunto set my hand and seal of said
Certified: A Ttne Cop9 court, this 18th day of September 2000
,SEAL) n
MAR 2 2 2001 / - ~l, .
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SUPPLEMENTAL IlVFORMATION ~, ~ , `
(For apRanalpu as iretit sheet and Rat o[addlRenal SentEnego[Detaioen.)
The aentenee o[this~de&adtat.was~.compdteQastd~ain:.~..
Datero[
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All Detainers Must Be Attached Ta This Form. (Total Yumber Of Detainers attached:
Dater- Indict-1Varrant Nos. Rzrnarks
e Following Additional Reports are Attached: The Following Additional Reports will be Forthcomins:
Con[inuztion Shezt ~ Arrest Report ~ FB! ~ Arrest Report ~ Presentence or
(UC-1008, Part Iq Posozntence Investie_ation
Presentenre or ~ Behavior Clinic ~ PSP
Postszntence Im~estieatiun
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BAMBIE R. LOWER,
vs.
SHANE M. LOWER,
-
* IN THE COURT OF COMMON PLEAS
Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA
*
* NO. 01-5485
*
* CIVIL ACTION -LAW
Defendant * IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty (20) days after this affidavit has been served on you or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(sl~
OF THE DIVORCE CODE
1. The parties to this action separated on January 5, 2000 and have
continued to live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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 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.
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Dated: ~ ~~ `~ , ~ ~C~ii' rj,-~ Cam,
Ba bie R. L 'w ~ lai tiff
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BAMBIE R. LOWER,
vs.
SHANE M. LOWER,
Plaintiff
* IN THE COURT OF COMMON PLEAS
* CUMBERLAND COUNTY, PENNSYLVANIA
*
* NO. 01-5485
*
* CIVIL ACTION -LAW
Defendant * IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF §3301(d) DIVORCE DECREE
TO: SHANE M. LOWER
You have been sued in an action for divorce. You have failed to answer the
Complaint orfile acounter-affidavit to the §3301 (d) affidavit. Therefore, on or after, July
5, 2002, the other party can request the Court to enter a final decree in divorce.
If you do not file with the Prothonotary of the court an answer with your signature
notarized or verified or acounter-affidavit by the above date, the court can enter a final
decree in divorce. Acounter-affidavit which you may file with the Prothonotary of the court
is attached to this notice.
Unless you have;already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever
the right to ask for economic relief. The filing of the form counter-affidavit alone does not
protect your economic claims.
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.
DAUPHIN COUNTY LEGAL REFERRAL SERVICE
213-A NORTH FRONT STREET
HARRISBURG, PA 17101
(717)232-0581
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BAMBIE R. LOWER,
Plaintiff
v.
SHANE M. LOWER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN DIVORCE
NO. 01-5485 CIVIL TERM
PRAECIPE TO WITHDRAW APPEARANCE
k
AND NOW, this LAS day of February 2002, the Farnily Law Clinic withdraws its
appearance on behalf of the Plaintiff, Bambie R. Lower.
February~t, 2002
Certified Legal Intem
~~
Resp~tfully sub e ,
~~ ~~ ~~~
CA O VE SH
RT E. RAINS
THOMAS M. PLACE
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
PRAECIPE TO ENTER APPEARANCE
AND NOW, this ~t~~ day of February, 2002, Heather Harbaugh, Esquire, hereby enters her
appearance on behalf of the Plaintiff, Bambie R. Lower.
February ~~ , 2002
Respectfully submitted,
C%~~
Heather Harbaugh, Esquire
Edward Weintraub & Associates
2650 North 3rd Street
Harrisburg, PA 17110
717/238-2200
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BAMBIE R. LOWER,
Plaintiff
v.
SHANE M. LOWER,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN DIVORCE
NO. O1- j y$S CIVIL TERM
PRAECII'E TO PROCEED IN
FORMA PAUPERIS
Kindly allow Bambie R. Lower, Plaintiff, to proceed in forma pauperis.
I, Matthew P. Hughson, of the Family Law Clinic, Certified Legal Intern, for the party
proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that
I am providing free legal service to the party.
Date: q..~_o ~ ~~.sa '~. ~~-~'
Mat ew P. Hughson
Certified Legal Intern
L
S M. PL
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Attorneys for Plaintiff
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BAMBIE R. LOWER, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. CNIL ACTION- LAW
IN DNORCE
SHANE M. LOWER,
Defendant : N0. 01-5485 CNIL TERM
CERTIFICATE OF SERVICE
I, Matthew P. Hughson, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and correct copy of the Complaint for Divorce on Shane M. Lower, residing at 218
Locust Street, Halifax, Pennsylvania, by depositing a copy of the same in the United States mail,
certified, restricted delivery, return receipt requested. Service was complete upon receipt by
Shane M. Lower on the 5~` day of November, 2001, as evidenced by the attached green card.
Matthew P. Hughson
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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BAMBIE R. LOWER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION- LAW
IN DIVORCE
SHANE M. LOWER
Defendant NO. 01-5485
CERTIFICATE OF SERVICE
I, Carol Verish, Certified Legal Intem, Family Law Clinic, hereby certify that I served a
true and correct copy of the Praecipe to Withdraw/ Enter Appeazance by depositing a copy of the
same in the United States mail, first class, postage prepaid, on the 21s` day of February, 2002 to
the following:
Heather Hazbaugh
Edward Weintraub & Associates
2650 North 3rd Street
Hamsburg, PA 17110
Shane M. Lower
218 Locust Street
Halifax, PA 17032
FAMILY LAW CLINIC
45 North Pitt Street
Cazlisle, PA 17013
(717) 243-2968
~.
BAMBIE R. LOWER,
Plaintiff
v.
SHANE M. LOWER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN DIVORCE
NO. OI-5485 CIVIL TERM
PRAECII'E TO REINSTATE THE COMPLAINT
To the Prothonotary:
Please reinstate the complaint in the above-captioned case.
Date Matthew P. Hughson
Certified Legal Intern
2
T AS M. PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Attorneys for Plaintiff
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BAMBIE R. LOWER,
Plaintiff
vs.
SHANE M. LOWER,
Defenc0ant
* IN THE COURT OF COMMON PLEAS
* CUMBERLAND COUNTY, PENNSYLVANIA
*
* NO. 01-5485
* CIVIL ACTION -LAW
* IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
ss.
AND NOW, this 3rd day of May, 2002 personally appeared before me, a Notary Public in and for
the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according to law,
deposes and says that on Apri126, 2002, she mailed a certified copy Plaintiff's Affidavit under
Section 3301(d) of the Divorce Code and Counter Affidavit, by certified mail, return receipt
requested, to Shane Lower, Defendant, 218 Locust Street, Halifax, PA 17032, and the same was
received by him on Apri130, 2002 as indicated by the return receipt card which is attached hereto.
1
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Wendy hive
Sworn to and subscribed before me
on this _ Y~~ day off,
zoez.
Notary Public
Notarial Seal
Misty D. Lehman, Notary Public
Harrisburg, Dauphin County
My Commission Expires Aug. 2, 2004
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item 4 if Restricted Delivery is desired.
^ Rrint your name and address on the reverse
w that we ran return the card to you.
^ pouch this card to the back of the mailpiece,
or on the front if space permits.
1. Art~~ic~lennAddresse'd/n~to//:
l)rW"~ r~~ ~L(~.~
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B. Recepived by (Pr/fnted Name) C. p to of Del'
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D. Ia delivery address different from item t ^ Yes
If YES, enter delivery atldrass below: ^ No
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BAMBIE R. LOWER, IN THE COURT OF COMMON PLEAS
Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA
*
vs. * NO. 01-5485
*
SHANE M. LOWER, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
ss.
AND NOW, this 24th day of June, 2002 personally appeared before me, a Notary Public in and for
the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according to law,
deposes and says that on June 18, 2002, she mailed a certified copy of the Notice of Intent to
Request Entry of a Divorce Decree and Counter Affidavit, by certified mail, return receipt
requested, to Shane Lower, Defendant, 218 Locust Street, Halifax, PA 17032, and the same was
received by him on June 21, 2002 as indicated by the return receipt card which is attached hereto.
~ ~~ 1
Wendy hive
Sworn to and subscribed before me
cn this ~~day of~ ~p ,
2002.
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I~o'tary Public
Notarial $eai
Misty D. Lehr{ian, Notary Public
Harrisburg, Dauphin County
My Commission Expires Aug. 2, 2004
._
item4 if.Restricted Delivery is desired.
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so that we can return the card to you.
^ ,attach this card to the back of the mailpiece,
er on the front if space permits.
t. Article Addressed to:
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B. Received 6y
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Date~of Delivery
2. Article Number
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D. Is tlel'wery address different from item 12 V Yes
If YES, enter delivery address below: ^ No
3. Service Type
,Certified Mail ^ Ezpreas Mafl
^Registered ~Retum Receipt ler•Ms+ehetM~Y~
insured Mail ^ C.O.D.
4. Restricted Delivery? (Extra Fee) (yea
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BAMBIE R. LOWER, * IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
*
vs. NO. 01-5485
SHANE M. LOWER, CIVIL ACTION -LAW
Defendant IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF §3301 (d) DIVORCE DECREE
TO: SHANE M. LOWER
You have been sued in an action for divorce. You have failed to answer the
Complaint orfile acounter-affidavit to the §3301(d) affidavit. Therefore, on or after, July
5, 2002, the other party can request the Court to enter a final decree in divorce.
If you do not file with the Prothonotary of the court an answer with your signature
notarized or verified or acounter-affidavit by the above date, the court can enter a final
decree in divorce. Acounter-affidavit which you may file with the Prothonotary of the court
is attached to this notice.
Unless you have;already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever
the right to ask for economic relief. The filing of the form counter-affidavit alone does not
protect your economic claims.
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.
DAUPHIN COUNTY LEGAL REFERRAL SERVICE
213-A NORTH FRONT STREET
HARRISBURG, PA 17101 ~, t
(717) 232-0581 ~
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IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff f 1 c
Vs File No. O ~ ~ 5i--! 0
_ ~ ~ l ~~~ IN DIVORCE
~~~(`'`~ Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /defendant in the above matter,
[select one by marking `~"]
prior to the entry of a Final Decree in Divorce,
n
or ,~ after the entry of a Final Decree in Divorce,~~davvted ~' ~ ~Z.
hereby elects to resume the prior surname of ~~ 4 nl~ and gives this
written notice avowing his !her intention pursuant to the provisions pf 4 P.S. 704.
Date: (~9~.It
<~~
of name
COMMO TH OF PENNSYLVANIA )
COUNTY OF ~ cd
On the ~ day of , 200`7 , 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. n~ ^, /~~ ~ C~~
C ' ~~+'~--x`(-'71
NOTARIAL SEAL Notary Public
CLAUDIA A. BREWBAKER; NOTARY PUBLIC
Carlis{e Boro, Cumberland County
My Commission Expires April 4, 2005
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