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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V
STATE OF 'PENNA.
TONIA SHUGHART
II
Plaintiff II N O. 99-3218
VERSUS
RONALD A. SHUGHART.
Defendant
DECREE IN
DIVORCE
AND NOW,_ \ VINMI %A , 2000 , IT IS ORDERED AND
DECREED THAT TOnia Chnghart , PLAINTIFF,
AND Ronald A. 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
BY THt COU
ATTEST:
/? PP. OTHONOTARY
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TONIA SHUGHART, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3218 Civil Term
RONALD A. 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
Section 3301(c).
2. Date and manner of service of the Complaint:
Certified mail dated 7/30/99 as attached.
3. (Complete either paragraph (a) or (b):
(A) Date of execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code:
By the Plaintiff: 3/20/00;
By Defendant: 3/19/00
(B) (1) Date of Execution of the Plaintiff's Affidavit
required by Section 3301(d) of the Divorce Code:
(2) Date of Service of the Plaintiff's Affidavit upon
the Defendant:
9. Related claims pending: No claims were raised.
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of
intention to file praecipe to transmit record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of Notice in section
3301(c) Divorce was filed with the Prothonotary: Even date
herewith
Date Defendant's Waiver of Notice in Section 3301(c)
Divorce was filed with the Prothonotary: Even date herewith.
John a J. D it Esq.
Attorney for aintiff
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TONIA SHUGIIAR.T, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 'K/.3J/I CIVIL 199
RONALD A. SHUGHART,
Defendant IN DIVORCE
NOTICE
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 at the Cumberland County Court
House, High and Hanover Street, Carlisle.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT 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 Assn.
2 Liberty Avenue
Carlisle, PA 17013
(717) 299-3166
Joh a ily, q.
Es
Att6 ney fe6r Plaintiff
TONIA SHUGHART : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. CIVIL 19911• 31 /b' Cc ,. f T
RONALD A. SHUGHART
Defendant
COMPLAINT
1. Plaintiff is TON IA SHUGHART, who currently resides at 149 A Street, Apt.
2, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is RONALD A. SHUGHART, who currentiy resides at 120 N.
East Street, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on August 23, 1996 in Carlisle,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The Plaintiff has been advised of the availability of marriage counseling
SAIDIS,
SNUFF &
MASLAND
AWORM6`ALIAW
26 W. Hlsh stmt)
WHO, PA
and the Plaintiff may have the right to request that the Court require the parties to
participate in counseling. Having been so advised Plaintiff does not desire the Court
to order counseling.
7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in
divorce.
Johnny .Deily,
Attori for PI ntif
26 High Street
Carlisle, PA 17013
SAIDIS,
SHUFF &
MASLAND
ATIMMSTVS-ANAW
26 W. NI'h Street
Carlisle, PA
COMMONWEALTH OF EN YLV NIA:
COUNTY OF CU??I ?? ! :SS
i verify that the statements made in this Complaint 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.
DATED: L
Plaintiff
SAID{S,
SHUFF &
MASLAND
ATRIRN WATMW
26 W. High Street
Carlisle, PA
TONIA SHUGHART, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 9 9.3?/PCIVIL 199
RONALD A. SHUGHART,
Defendant IN DIVORCE
AFFIDAVIT
I, Tonia Shughart, being duly sworn according to law,
depose and say:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling.
(2) I understand that the court maintains a list of
marriage counselors in the Prothonotary's Office, which list is
available to me upon request.
(3) Being so advised, I do not request that the court
require that my spouse and I participate in counselling prior
to a divorce decree being handed down by the court.
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: C? ?0 ?
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TONIA SHUGHART,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. 4S• 3.z id'
RONALD A. SHUGHART, NO. 30- CIVIL TERM
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERTS
To the Prothonotary:
Kindly allow, nnia Shnghari• , to
proceed in forma aauneris.
I, Johnna J. Deny , attorney for the party proceeding
in forma nauueris, certify that I believe the party is unable to
pay the costs and that I am providing free legal services to the
party. The party's affidavit showing inability to pay the costs
of litigation is attached hereto.
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TONIA SHUGHART,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. 99.
i z!!'
RONALD A. SHUGHART, NO. Si- CIVIL TERM
Defendant
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am the plaintiff/defendant in the above matter and
because of my financial condition am unable to pay the fees and
costs of prosecuting, defending, or appealing the action or
proceeding.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct.
(a) Name:
Address:
O,OL. \ %SL 9a,. 1'l C11
Social Security Number: 1DtS Go -4nR n
(b) If you are presently employed, state
Employer: , J)?,x n
Address:
Salary or wages per month: --30-. - wk (n. p c hauf,-
Type of work:
If you are presently unemployed, state
Date of last employment:
A'
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
Business or profession:
Other self-employment:
Interest:
Dividends: /
Pension and annuities:
Social Security benefits:
Support payments:
Disability payments:
Unemployment compensation and
supplemental benefits:
Workman's compensation:
Public Assistance:
Other:
(d) Other contributions to household support
(Wife)(Husband) Name: 1tVIQ
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
(e) Property owned
Cash: V1
Checking Account: 1'
Savings Account:
Certificates of Deposit:
Real Estate (including home):
Motor vehicle: Make - lA Year 1 `3
Cost Amount owed
Stocks; bonds:
other:
(f) Debts and obligations
Mortgage:
Rent: y-3j I)io(Y??c
Loans:
Monthly Expense/s: G'IL5y e.?c?t 2oc??n.5A1 ,lQc
(g) Persons dependent upon you for support
4.
(Wife) (Husband) Name:
Children, if any:4/
fkh(ry l?aNl-x.t.e
Name,
`i
I understand-t? ai`Lt- ave a continuing obligation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein.
5. 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: k /q. 1?9 xn ?cr;,`ll'
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TONIA SHUGHART, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3218 Civil
V.
RONALD A. SHUGHART, IN DIVORCE
Defendant
PLAINTIFF'S
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on May 27, 1999.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date
of the filing of the Complaint.
3. I consent to the entry of a final decree of divorce
without notice.
4. 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.
5. 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.
DATED : - Arnti?
Tonia Shughart „ laintfff
SAIDIS,
SHUFF &
MASLAND
ATIMMYPATNAW
26 W. High Street
Carlisle, PA
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TONIA SHUGHART,
Plaintiff
V.
RONALD A. SHUGHART,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3218
IN DIVORCE
DEFENDANT'S
AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
SAIDIS, GUIDO,
SHUFF &
MASLAND
26 W. High Seat
Culide. PA
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on May 27, 1999.
2. Defendant acknowledges and accepts service of the
Complaint on August 2, 1999.
3. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of the filing
of the Complaint.
4. I consent to the entry of a final decree of divorce
without notice.
5. 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.
6. 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.
7. I have been advised of the availability of marriage
counselling and understand that I may request that the court
require counselling. I do not request that the court require
covnnsel ]. i.ng.
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.
DATED: U 3` ????t
Ronald A. Shughart
Defendant
" CV U
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
vs.
ph e ( Lai
I Defendant
File No. - S'-1
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
day of C C h ,-r9 QMQ hereby elects to resume the
prior surname of P\? C,k , and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE:
as wm
51'Qn"*tuY?pr I?name UI'?l ei? resumed
COMMONWEALTH OF PENNSYLVANIA: J1 •e
SS.
COUNTY OF CUMBERLAND
On the day of before me, a
Notary Public, personally appeared a 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.
seal.
In Witness Whereof, I have hereunto set my hand and official
??-?kZdGa3eu?
Notary Public
t?01ARIA(. SEA!
PATRICIA A .SttA'Tp Mn1 ry Public
Carfislq [itvu. Cumberland Ceunty
My Commiss'oii frpu9t ^ece rbcr 17, 700t
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TONIA SHUGHART, IN THE COURT OF COMMON PLEAS
Plainiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3218
RONALD A. SHUGHART,
Defendant IN DIVORCE
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above
matter, having been granted a Final Decree in divorce from the
bonds of matrimony on the 9th day of April, 2000, hereby elects
to retake and hereafter use her previous name of Tonia Bonawitz.
cL?- /C. i
Tunid aildghuL?
TO BE KNOWN AS:
f TToonia Bonawitz
COUNTY OF CUM?BE?RLAWD
On the day of 2000, before
me, a Notary ublic, persf appeared Tonia 3hughart to be
known as Tonia Bonawitz, kme to be the person whose name
is subscribed to the withient, and acknowledged that she
executed the foregoing for the purpose therein contained.
COMMONWEALTH OF PENNSYLVANIA .
. SS.
IN WITNESS WHEREOF, I have hereunto set my hand and
notarial seal.
Notary
SAIDIS,
SNUFF &
MASLAND
AMPUM5MTAA W
26 W. High Sued
Carlisle, PA
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