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Home My WebLink About03-4368ANGELA J. SHANK, Plaintiff HARRY D. SHANK, .IR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.: 0.~' t~.3~ g CIVIL ACTION LAW : : 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 Streets, 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 Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans 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 least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ANGELA J. SHANK, Plaintiff HARRY D. SHANK,JR., Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION LAW : No. c/3'b - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaimiffis Angela J. Shank, who currently resides at P.O. Box 284, 79 Ridge Drive, Shemaansdale, Perry County, Pennsylvania, since August 8, 2003. 2. Defendant is Harry D. Shank, Jr., who currently resides at 128 Beetem Hollow Road, Newville, Cumberland County, Pennsylvania, since 1991. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on April 20, 1991, in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiffrequests the Court to enter a Decree in Divorce. WHEREFORE,, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. By: Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #81924 (717) 241-6070 VERIFICATION I verify that the statements made in this Complaint are tree and correct. ! understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. ANGELA J. SHANK, Plaintiff HARRY D. SHANK, JR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION .. LAW : :NO. 03-4368 CIVILTERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divome Code was filed on September 5, 2003. 2. The marriage of Plaintiffand 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. § 4904, relating to unswom falsification to authorities. Angela J?Shank [J ANGELA J. SHANK, Plaintiff HARRY D. SHANK, JR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-4368 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. 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: /'~ (~- 0'~ I~/efendant Paul J Esposito, Esquire ID. #25454 GOLDBERG, KATZMAN &SHlPMAN. P.C. 320 Market Srreel P O Box I268 Harrisburg. PA 17108-1268 (717) 234-4161; (717) 234-4161 (facsimile) Counsel for Dyendat ANGELA J. SHANK, 1N THE COURT OF COMMON PLEAS HARRY D. SHANK, JR., Plaintiff Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4368 CIVIL ACTION - LAW IN DWORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELINC 1. A Complairit in Divorce under § 3301(c) of the Divorce Code was filed on September 5, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint m Divorce on or about September 9, 2003, via certified mail, restricted delivery. 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: J~C, ~1 ,2003 ' HARLRY D. SHANK, JR. v Paul J Esposito, Esquire I.D. #25454 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P O. BOX 1268 Harrisburg, PA 17108-1268 (7 7) 234 4161' (717) 234 4161 (facsimile) Counsel for Defendant ANGELA J. SHANK, 1N THE COURT OF COMMON PLEAS HARRY D. SHANK, JR., Plaintiff Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4368 CWIL ACTION - LAW IN DWORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE, DECREE UNDER SECTION 3301(c) OF THE DIYORCE 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, lawyer's fees or expenses ifI 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 tree 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: Rlt_, ch I ~2003 HARRY D. SHANK, JR. · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpieca, o~ on the front if space permits. 1. A~tlcle Addressed to: B. Received by ( Printed Name) C. Date ~f O. Is deiive~y addreas diffemnt from item l? [] Ye~ If YES, enter dellve~ a~dress below: ice Type j~e,~ified Mail i--I Registered [~ Insured Mail [] C.O.D. 2. A~ticle Number (Transfer from service label) PS Form 3811, Aught 2001 Don'~tic Return Receipt ANOELA J. SHANK, Plaintiff HARRY D. SHANK, JR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 03-4368 CIVIL TERM : 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail/restricted delivery, September 9, 2003. 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff, January 9, 2004; by the Defendant, December 21,2003. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 12, 2004. Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: January 12, 2004. Date: January 15, 2004 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court 1D No. 81924 IN THE COURT OF COMMON ANGELA J. SHANK Plaintiff OF CUMBERLAND COUNTY STATE OF PENNA. N O. 03-4368 PLEAS CIVIL TERM HARRY D. SHANK JR. Defendant AND NOW, DECREED THAT AND DECREE IN DIVORCE Angela J. Shank , PLAINTIFF, Harry D. Shank, Jr. , 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 ATT E s T¢~~ PROTHONOTARY