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Home My WebLink About99-04045 Z t ,Z L ,a O a c? • . 01. :? ce• , o • :?, c. • ce• c?• •:r.• :? • :r :? • <r.• •:c• c? • :?> :? • :?: •:?: <s. :? •:? •::•yx c•:?>: ;?. .?x..?:;.?r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF s PENNA. I v GREGORY SHAW 99 4045 CIVIL TERM c . Plaintiff Versus DEBORAH L., $HANfC r Defendant DECREE IN DI VORCE r. .. . . AND NOW . ........... 19 99.. it is ordered and :? . . . .......... . .. , t: decreed that ......... M.EWRX..SHA.rac ............................... plaintiff, and ................... D RAr. .. .SHAN ...c...................... defendant, are divorced from the bonds of matrimony. fi 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 is been entered; •' None. ............................................................ By The Attest: J f . i' t lv r. 0 rothonolary 0 I !Or. ryi. { •A:• •A• •'A:• ;t• •3i• <? •?:• :ti {c?> :?>?c?} <i: •:?:.. c?> ;e• :?:• •c?••ti•?t?>•<e: {e:•`t?:L?: a:ti •:?> {?• 3.99 A,7 ??? ? Zee GREGORY SHANK, Plaintiff V. DEBORAH L. SHANK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4045 CIVIL TERM 1999 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: Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: July 9, 1999, BY PERSONAL ACCEPTANCE OF SERVICE BY THE DEFENDANT. DEBORAH L. SHANK. 3. (Complete either Paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code; by Plaintiff, Gregory Shank - November 3, 1999; by the Defendant, Deborah L. Shank - November 5, 1999. (b)(1) Date of execution of tire Affidavit, equi, ed by § 3301 (d) of tire Bivo. c eode. (2) Date of filing, and be, vice of tire Plaintiffs Affidavit upon, tire jespondent. 4. Related claims pending: None. 5. (Complete either (a) or (b).) (a) t, ansinit , ecord, a copy of which is attached: (b) Date plaintiff s Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: November 17 , 1999 Date defendant's Waiver of Notice in § 3310(c) Divorce was filed with the Prothonotary: November 1 I1999 LANDIS & BLACK t ? /) C) ? )ffeu LGkC j Date: November 1999 By: obert R. Black, Esquire Attorney for Plaintiff ,' :? - _ ??: GREGORY SHANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DEBORAH L. SHANK, NO SIDS CIVIL 199 Defendant 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 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 with your children. When die 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, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 17013. 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 Association Two Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 GREGORY SHANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DEBORAH L. SHANK, NO. qc) 45 CIVIL 1999 7e(-M Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, GREGORY SHANK, by his attorneys, Landis & Black and makes the following Complaint in Divorce: 1. The Plaintiff is GREGORY SHANK, an adult individual who currently resides at 505 Calvary Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is DEBORAH L. SHANK, an adult individual who currently resides at 16 Big Spring Terrace, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 20, 1992, at the First Presbyterian Church, Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I. 8. The Plaintiff requests the Court to enter a Decree of Divorce in this matter pursuant to Section 3301(c) or 3301(d) of the Divorce Code. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to Section 3301(c) or 3301(d) of the Divorce Code. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are made subject to the penalties of 18 Pa. C.S. § 4904 (unswom falsification to authorities). Date: C% - Cl Gregory Sh LANDIS & BLACK By: Robert R. Black, Esquire Attorney for Plaintiff -2- 4 - c? m W kJ W a U S z u U 1 to u O N 14 _ r? o 5 z 1 8 O ,7 M H O C7 GREGORY SHANK, Plaintiff V. DEBORAH L. SHANK, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4045 CIVIL TERM 1999 IN DIVORCE ACCEPTANCE OF SERVICE I acknowledge receipt of the complaint in divorce as captioned above and hereby accept service of said complaint. ??FrXL ?a11L Deborah L. Shank 16 Big Spring Terrace Newville, PA 17241 Date: ' t"h9`I w O 4 Q\ ?- )% w JCl .J . liaU O ON U h z U ? 5 ai v w y U _ ? O p ? Z ?5 ? 5 ? a ? N ?a ao H W? GREGORY SHANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DEBORAH L. SHANK, NO. 99-4045 CIVIL TERM 1999 Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 2, 1999. I acknowledge receiving a true and correct copy of the Divorce Complaint and accept service of the Divorce Complaint on July 9, 1999. 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. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. 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, lawyers 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 and waiver 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. i Date: I1-F? A Deborah L. Shank, Defendant \ ?) (' ` ? ?.. ?. 1 GREGORY SHANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DEBORAH L. SHANK, NO. 99-4045 CIVIL TERM 1999 Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 2, 1999. 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. 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. 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, lawyers 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 and waiver 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: 11 N. - )- ` Greg ank, Plaintiff Ci; _? t i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW -C -)Fy 0"f1)OIC Plaintiff File No. qn `l - L} OL{ 5 VS. IN DIVORCE DF.6?RAN L SHPnK Defendant 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 _G day of Dp ?CIC?Cj hereby elects to resume the prior surname of :5U Llfk S and gives this written notice pursuant to the provisions of 54 P_S. S 704. DATE: q' I9_ Oa -"-??S.Lm 1 r, ? Signature 1 L \ Signature of name being1resumed COMMONWEALTH OF PENNSYLVANIA: . SS. COUNTY OF CUMBERLAND On the day of _0 Notar Public, `? °?Q? before me, a y 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 and official seal. Noea arv Publ c Nolanal Seal Chnstine J. Bray. Notary Pudic Meroersburg Boro. Franklin County my commission Expres Mar. 26, 2006 ;- ?> _ ? .? `;, ? .. ?_ ,? _ - %_ - _.? ?„ J r ?'° ?' ,lei t'> v -.a _? - ?.? u -? ?-