HomeMy WebLinkAbout99-04041
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IN THE COURT OF COMMON FLEAS
'r OF CUMBERLAND COUNTY
STATE OF 4rh PENN A.
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WENDELL. E. PENNABAKER,_
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Plaintiff
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SHANNON L. PENNABAKER, _
Defendant
DECREE IN
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AND NOW, .
.......... ......0, , 19..99. , it is ordered and
decreed that ......... WENDELL. E,,PENNA]BAKER. ............. .. Plaintiff,
and ..................SHANNON. L_..PENNABAKER.......... ... , defendant, -
are divorced from the bonds of matrimony. i
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; I •••
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WENDELL E. PENNABAKER,
Plaintiff
VS.
SHANNON L. PENNABAKER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 99-4041 CIVIL TERM
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)
as0xf?)<P?K of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint:
July 2, 1999 by certified, restricted mailing
3. Complete either paragraph (a) or (b).
(a) Datp_ of execution of the affidavit of consent required
by S3301(c) of the Divorce Code: by plaintiff 10/14/99
by defendant 10/14/99
(b)(1) Date of execution of the affidavit required by S3301(d)
of the Divorce Code: (2) Date of filing and
service of the plaintiff's affidavit upon the respondent:
4. Related claims pending:
:i. COn'Plet:e 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 53301(c) Divorce was
filed with the Prothonotary: 10/19/99
Date defendant's Waiver of Notice in 53301(c) Divorce was
filed with the Prothonotary: 10/19/99
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Attorney for ( Plaintiff) fX6g Widrde0W
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WENDELL E. PENNABAKER,
PLAINTIFF
V.
SHANNON L. PENNABAKER,
DEFENDANT
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99- 11,I)gl CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
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 lake 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 visitation of your children.
When the ground for 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, I Courthouse Square, First Floor, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OR 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 Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
WENDELL E. PENNABAKER,
PLAINTIFF
V.
SHANNON L. PENNABAKER,
DEFENDANT
: IN THE COURT OF COMMON PLEAS FOR
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- Alt ),11 CIVIL TERM
: CIVIL ACTION -LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
GROUNDS FOR NO-FAULT DIVORCE
UNDER SECTION 3301(c) or 3301(d) OR DIVORCE CODE
1. Plaintiff is Wendell E. Pennabaker, who currently resides at 656 Hilltop Road,
Newburg, Cumberland County, Pennsylvania, since approximately 1978 or 1979.
2. Defendant is Shannon L. Pennabaker, who currently resides at 1743 Orchard Road,
Chambersburg, Franklin County, Pennsylvania, since November 22, 1998.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant are citizens of the United States of America.
5. The Plaintiff and Defendant were married on July 5, 1997 at Memorial Park,
Shippensburg, Cumberland County, Pennsylvania.
6. The parties resided at 656 Hilltop Road, Newburg, Cumberland County, Pennsylvania,
from the date of the marriage to the date of separation.
7. There have been no prior actions of divorce or for annulment between the parties.
8. The marriage is irretrievably broken.
9. 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. Knowing this,
Plaintiff does not desire that the Court require the parties to participate in counseling.
10. Neither Plaintiff nor Defendant is in the military or naval service or the United States
or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
11. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff respectfully requests that your Honorable Court grant a Decree
in Divorce to him, plus any other appropriate relief.
K;,.pectfully submitted,
Richard L. Webber, Jr.
Attorney for Plaintiff
366 Green Spring Road
P.O. Box 40
Newville, PA 17241-0040
(717) 776-6566
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.A. Section 4904, relating to
unswom falsification to authorities.
Date: r.???9!11????nt.?C?2<dl?-?'
Wendell E. Pennabaker, Plaintiff
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WENDELL E. PENNABAKER,
PLAINTIFF
V.
SHANNON L. PENNABAKER,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4041 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA .
: SS
COUNTY OF CUMBERLAND
Richard L. Webber, Jr., being duly sworn according to law, deposes and says that he
mailed the Complaint in Divorce in this matter by certified mail, return receipt requested,
addressee only, to the Defendant, Shannon L. Pennabaker, of 1743 Orchard Road,
Chambersburg, Pennsylvania 17201 on July 2, 1999. The return receipt signed by the Defendant
is evidence of delivery to her and is attached hereto as Exhibit "A".
Sworn to and subscribed before
me this _13* day of , I,A?,
1999.
Richard L. Webber, Jr., Attorney for Plaintiff
366 Green Spring Road
P.O. Box 40
Newville, PA 17241
(717) 776-6566
Not Public
NOTARIILLS;.;
IEANYEwAn(ER NOAYPIIBLIC
NOATN NEwtON TNI?, BERlAND C0.
YCOMMISSIONEI(PIAAACH3t 2003
WENDELL E. PENNABAKER,
PLAINTIFF
V.
SHANNON L. PENNABAKER,
DEFENDANT
Z 515 606 732
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
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Sent to
Shannon L.
Pemabaker
Street 8 Number
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Postage f $ 5555
Certified Fee 1.40
Special Delivery Fee
Restricted Delivery Fee 2.75
Return Receipt a
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SENDER: I also wish to receive the
• Complete items 1 and/or 2 for addilional sarvlces.
• Complete items 3,4a , and 4b. following services (for an
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• Print your name and address on the reverse at this term so that we can return this extra fee):
card to yOU.
• Attach this lolm to the heat of the maifpioce, or on the back if space does not
1. ? Addressee's Address 8 1
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permit. Recapt R
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Return Receipt will will show tshow 1o whom the maids
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and the date
• The delivered,
onsult postmaster for lee.
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$
Shannon L. Pennabaker
1743 orchard Road
Chambersburg, PA 17201
PS Fdr* 3811, Decembir 1994
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4041 CIVIL TERM
IN DIVORCE
4a. Article N umber Qg
Z 515 606 732 t!I
4b. Service Type E i
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? Registered 9p Certified ¢
? Express Mail ? Insured
? Return Receipt for Merchandise ? COD
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7. Date of Deliwe-?
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8. Addressee's Address (Only i requested Y
and fee is paid) r
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WENDELL E. PENNABAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4041 CIVIL TERM
SHANNON L. PENNABAKER, : CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on July 1, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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 unworn falsification to authorities.
Date:
WENDELL E. PENNABAKER,
Plaintiff
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WENDELL E. PENNABAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-4041 CIVIL TERM
SHANNON L. PENNABAKER, :
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1 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.
1 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:
WENDELL E. PENNABAKER
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WENDELL E. PENNABAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4041 CIVIL TERM
SHANNON L. PENNABAKER, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on July 1, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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: ! -f
ANNON ABAKER,
Defendant
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WENDELL E. PENNABAKER,
Plaintiff,
V.
SHANNON L. PENNABAKER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4041 CIVIL TERM
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that 1 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. 1
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:
/SliANNON 66ABAKER
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