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Home My WebLink About01-6087STEPHEN C. ANDERSON, Plaintiff SHANNON M. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS To.' Shannon M. Anderson 18450 S:W. 87~a Avenue Miami, Florida 33157 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 ease 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. 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, One Courthouse Square, 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 Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Document #: 218282.1 STEPHEN C. ANDERSON, Plaintiff SHANNON M. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE COUNT I -DIVORCE Mechaulcsburg, Cumberland County, Pennsylvania 17055. 465-89-6673. 2. Defendant is Shannon M. Anderson, Plaintiff is Stephen C. Anderson, who currently resides at 421 Cherokee Drive, Plaintiff's social security number who currently resides at 18450 S. W. 87th Avenue, Miami, Florida 33157. Defendant's social security number is 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 3, 1998, in North Carolina. The parties separated on January 20, 2001. 5. There have been no prior actions of Divorce or for annulment between the parties. 6. 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. 7. The marriage is irretrievably broken. Document #: 218282.1 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff, Stephen C. Anderson, requests the Court to enter a Decree in Divorce and such other orders as may be just and appropriate. Dated: Steven C. Courtney, Esquire Attorney I.D. No. 74669 3211 North From Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 218282.1 VERIFICATION I, Stephen C. Anderson, do hereby verify that the facts set forth in the foregoing Complaim are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsificationto authorities. ,ate: !D'I-I'O I S{e~h& C ,~derson Document #: 218282.1 RECORD OF DIVORCE OR ANNULMENT [] (CHECK ONE) HUSBAND 1, NAME (F;rst) (M/d~ (LaS~ 12. DATE (Mon~ (By) (yen Stephen C. Anderson I OF 06 01 1977 BIRTH 421 Cherokee Drive Mechanicsburg Cumberland PA EIRTH Arizona OFMARR(AGENUMBERTHIS I 6. RACE WHtTE[] 8LACK[] OTHER (Spec~y)[] WIFE Independent Contractor Olsen Shannon 18450 S.W. 87th Avenue Miami (County) 17A. Nt.~MBEROF ~17B. NUMBEROFDEPENDENT C~LDREN THIS / CHILDREN UNDER 18. MARRIAGE 2 2 CHffJ~)REN TO [] [] (Middle) (Last) 19. DATE (Mo~gl) (Dey) (Year) M. Anderson I OF 09 20 1978 MIRTH Florida 33157 OF Utah 14. USUAL OCCUPA~lcH BLACK[] OTHER (Specie) [] Waitress North Carolina M~RmGE O1 03 1998 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN C. ANDERSON, Plaintiff SHANNON M. ANDERSON, Defendant No. 01-6087 Civil Term CIVIL ACTION- In Divorce PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint with regard to Shannon M. Anderson in the above captioned matter. Respectfully submitted, Dated: November 28, 2001 By: Steven ~~ METZOI~R '0~ICKER~S~AM 3211 N. Fo~ Street P.O. Box 5300 Harrisburg, PA 17110 (717) 238-8187 I.D. #74669 Attorney for Plaintiff Document #: 221544.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN C. ANDERSON, Plaintiff SHANNON M. ANDERSON, Defendant NO. 01-6087 CIVIL ACTION - LAW PROOF OF SERVICE BY MAll. I, Steven C. Courtney, Esquire, do hereby certify that on December 6, 2001, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon the following person(s) by certified mail, as is evidenced by the Certified Mail Return Receipt attached hereto. SHANNON M. ANDERSON 18450 S.W. 87th Avenue Miami, Florida 33157 Dated: January 14, 2002 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Harrisburg, PA 17110 Telephone No. (717) 238-8187 I.D. No. 74669 Attorney for Plaintiff Document #: 224770.1 · COmplete items 1, 2, and 3. 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