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Home My WebLink About07-4140 TARA SHRAUDER, Plaintiff, vs. SAMUEL SHRAUDER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D7' ~ 14~D Ci vi 11ern~- CIVIL ACTION -LAW IN DIVORCE N O T I C E 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 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 Domestic Relations Office, 13 North Hanover Street, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TARA SHRAUDER, Plaintiff, vs. SAMUEL SHRAUDER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam(a~kopelaw.com Attorney for Plaintiff TARA SHRAUDER, IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07, ~1/y0 ~l ~,.~ SAMUEL SHRAUDER, :CIVIL ACTION -LAW Defendant. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, TARA SHRAUDER, by and through her attorney, LESLEY J. BEAM, ESQ., and makes the following Complaint in Divorce. 1. The Plaintiff is TARA SHRAUDER, an adult individual who currently resides at 337 W. Green Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is SAMUEL SHRAUDER, an adult individual who currently resides at 115 E. Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 2, 2002 in York, York County, Pennsylvania, 5. The Parties separated in September 2005. 6. Neither the Plaintiff nor Defendant is in the military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 12. The marriage of the parties is irretrievably broken. 13. The parties are living separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two (2) years as Specified in Section 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. Respectfully Submitted, KOP & ASSOCIATES, LLC Dated: ~ J ~ ,7 Les J. am, Esq. d Jul 11 07 02:56p '^P~2"""' f l!- f f] 1- f :J f L n V I L.. Ot MJJ V t~ N 1 L J ~ urr tir tour la.~o VERIFICATION 1, Tara Shrauder, the Plaintiff in this matter, have read the foregoing Complaint. I verify that my avemaents in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalges of 18 Pa. C.S_ 4904 relating to unsworn 'falsifications to authorities. ~= -' / / `~ r:. Dated: - < Tara Shrauder c~ ~ c:.~, ~..,~ c~ . n ?'t' c_ W i ^ ~ ^ ~ ' ~ ~ w - ~ y o e ~ ; c.,~ ~_ °a~ cra •< KOPE ~ ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 IbeamCa~kopelaw.com TARA SHRAUDER, Plaintiff, vs. SAMUEL SHRAUDER, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4140 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT AND RETURN OF SERVICE AND NOW comes Kope & Associates, LLC by LESLEY J. BEAM, attorney for Tara Shrauder, Plaintiff, and states that service of the Divorce Complaint in this matter was made by her upon Defendant, Samuel Shrauder, by posting the same in the U.S. Mail, postage prepaid, at Camp Hill, PA by Certified Mail No. 7004 2510 0007 6450 1356, Return Receipt Requested on July 17, 2007, to his mailing address, at 115 E. Simpson Street, Mechanicsburg, PA 17055 which mail was received by Defendant on July 21, 2007, all in accordance with PA.R.C.P. 412 and 403. The mailing receipt and the return receipt or true copies thereof of the acceptance of service bearing the signature of the Defendant are attached hereto and made part hereof, together with the cover letter mailed to Defendant. 1! f,,- LES EAM, Esq. Atto y r Plaintiff Qa ^ ~I r 0 (U a d 1C t ~z° ~ ^^ ~ ` o r ~ F Y ~ ~ ~ ~ ' .,,,,,.., .moss- ,,~ ~ I 1 1 m ~ ~ < d t~ U a '~ ~ ~ - ~ - W ~ '~ ~ 2 ~ vW ~, Zc~¢ ~ D ~ .~ ~ ~ } ~` V chi^^^ ¢ 0 0 '~'"- ri v rl ul ~ N ~ ~ m m / O m ~ m v ~ a m m 'a --p 0 r- ~_~ ~m ~ ~~°1 oY ~ ~ S ~p , , c > ~«~o, ~ ~ '~ ~ p ~ ^ ~ C ~ ~Uy y T ~ ~~~~~~ ~ .'mC C U U ~ ` m m~ J ., f. m m 'c o' 3 Y .mc ~ ~ ~ W ,• EEcymo ~ 0~ ~ am., Una ~,¢ o , ~ ~ c ~ ^ ^ ^ E ,~ ~~ z m rd N -- o I, I, E e Q ~ .S ~ I S o N ~tl m ~"- 4 ~ ` tLL ~ '. a e S ~~ ~ a • ¢v H 95E~ os+-9 Zoo ~'[S2 +,OOZ K O P E ASSOCIATES LAW OCFICES LLC July 17,2007 VIA REGULAR AND CERTIFIED MAIL Samuel Shrauder 115 E. Simpson Street Mechanicsburg, PA 17055 Re: Shrauder v. Shrauder No. 2007-4140 Dear Mr. Shrauder, I represent Tara Shrauder in the above referenced matter for divorce. Enclosed and served upon you is the Divorce Complaint filed with the Cumberland County Court of Common Pleas. I am sending these papers to you directly because I have no information that you are represented by an attorney. I am also enclosing an Acceptance of Service for this Complaint Please sign and return in the enclosed self-addressed stamped envelope. If you do not either return the Acceptance of Service or sign the receipt for the certified letter, this office will have to officially serve this Complaint by Sheriff at your place of residence. If you have any questions, please feel free to contact me. But, please be aware that I cannot give you legal advice because I represent Ms. Shrauder. Thank-you for your kind attention to this matter. Sincerely, Kope Associates, LLC Lesley J m, ESq. Enclosure Cc: Tara Shrauder Smart Representation 466o Trindle Road ^ Suite 2oi ^ Camp Hill, PA i7ou P 7i7.~6i.7573 ^ F 7i7.76i•757z ^ kopelaw.com a ?~ ~ '~ n ~=' ~T`` ~~,. i , ~, ~ C= T ,~=; . n5 w . _ ~ ~ Ott ~ , r-~. `^~~)1 ti`s L "S ~~~I,--d;Jr;ri~y:r ~r r?~ ~ „t,, , ,..,` CRY 2oiaF~~ i~ r~~ E= z~ LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 KOPE & ASSOCIATES, LLC 395 St. Johns Church Road, Suite 101 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com ., , ~ Attorney for Plaintiff TARA SHRAUDER, IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-4140 SAMUEL SHRAUDER, :CIVIL ACTION -LAW Defendant. IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please enter the Plaintiff's voluntary discontinuance of the within action pursuant to Pennsylvania Rule of Civil Procedure 229. Date: a. 7 0~1( VERIFICATION I, Tara Shrauder, the Plaintiff in this matter, have read the foregoing Praecipe to Discontinue. I verify that the statements made in this Praecipe are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. Dated: ~ ~ ~ ~` Tara Shrauder ~~~ 1 i Cu~l~