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Home My WebLink About07-5545 HAROLD S. IRwIN, 111.119WIRE ATTORNEY WHO. songs M SONT" NTT STREET CARLISLE PA 17013 (717) 2434141010 ATTORNEY FOR PLAINTIPP DANIEL L. SMEMFEIN : IN THE COURT OF COMMON PEAS OF plaintiff : CUMSERLAND COUNTYv FiNiYLVANIA v. CIVIL ACTION - LAW NO. 2007 - 555' CIVIL TERM ALLISON J. SMEAFFER, on Dohndaet : IN DIVORCE 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 in 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 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, Cumberland County Courthouse, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 4 DANIEL L. SHEAFFM : IN THE COURT OF tNONI10N PLEAS OF Plalntw : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACflON - LA NO. 2007 - 66 y CIVIL TERM ALLISON J. SHEAFFERy : Dahndaet : IN DIVORCE COMPLAINT IN DIVORCE UN SECTION 3=1 c OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is DANIEL L. SHEAFFER, an adult individual residing at 2464 Lobach Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is ALLISON J. SHEAFFER, an adult individual residing at 406 Oak Tree Lane, Easton, Northampton County, Pennsylvania 18040. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on April 7, 2006, in Camp Hill, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. September 14, 2007 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 HAROLD S. IRWIN,1 Attorney for Plaintiff DANIEL L. SMEAFFMo : IN THE COURT OF COMMON PLEAS OF Plainuff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO.5007 - CML TERM ALLISON J. SHEAFFER, : DwfendmM : IN DIVORCE PI.A,INTN F's II ARRI M COUNSL1 "a AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down: I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. September 14, 2007 C.) r-.> .` iZ r' i cn -0 tV t 00 -C (A r" ? Z, 0 i j , 3 - -, # c a -•a HAROLD S. IRININ, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF DANIEL L. SHEAFFER, Plaintiff V. ALLISON J. SHEAFFER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 5545 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on September 26, 2007, addressed to the defendant at 406 Oak Tree Lane, Easton, Pennsylvania 18040, Certified Mail No. 7003 2260 0000 8703 5360. 3. A copy of the sender's and signed receipt are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. October 1, 2007 Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 II C3 t?a.?n??aei?r ?Jr (Domestic Mail Only, I"u7 M C3 i ro Postage $ EZI Certified Fee C3 Postmark C3 Return Reciept Fee (Endorsement Required) Here O Restricted Delivery Fee _a (Endorsement Required) ru ru Total Postage & Fees C3 O Sent To ??. Street Apt. No.; or PO Box No. .. City, State, ZIP+ 3800. June .r I ;ha ¦ Complete items 1, 2, and 3. Also complete A. Si item 4 if Restricted Delivery is desired. X nt ¦ Print your name and address on the reverse Addressee so that we can return the cans to you. Received by (Printed e) very ¦ Attac(ilhis card to the back of the mailpiece, or oa front if space permits. D. Is delivery address different i? ? Yes 1. Articl dressed to: If YES, enter delivery add -k 29W ALltON J SHEAFFER 4 0 6 'OAK TREE LN (iSPS EASTON PA 18040 3. Segice Type jNeZwdftd Mail ? Express Mail ? Registered ? Retum Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7003 2260 0000 8703 5360 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 EXHIBIT °A° ?? ?^a `?? ?_..: ,;. -- --? .-? ..rte",, ?-.: t-j??.. ??"' .__a -r?. -r, t ?- ; t' .. -^-? ???, `_,? (?.? `"-i -+ '..' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DANIEL L. SHEAFFER, Plaintiff VS. ALLISON J. SHEAFFER, Defendant : NO. 2007-5545 : IN DIVORCE NOTICE OF ELECTION TO RETAKE PRIOR NAME Notice is hereby given that the Defendant in the above matter, a Divorce Complaint having been filed at the above term number, hereby elects to retake and hereafter use the prior name of ALLISON J. HARPER, and gives this written Notice avowing her intention pursuant to the provisions of 23 P.S. 702 and 54 P.S. 704. DATE: q'01 STATE OF ????var?`?`" COUNTY OF NLY tut-- ` ALLISON J. S AFFER ALLISON J. H ER SS On the 64""d-ay of 2007, before me a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. P'611, , W C/ " ""aj NOTARY PUBLIC NOTARIAL SEAL COLLEEN M. RAYtOCK, Notary Public EASTON, Northampton County My Commission Expires March 19, 2008 -t C) v gj 9L) ol V1 -v fl c.a CZ) N) C) E5 %JD d -Tj Fri -- -rn :o =1 ? t s Ai DANIEL L. SHEAFFER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALLISON J. SHEAFFER, : NO. 2007 - 5545 CIVIL TERM Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about September 20, 2007. Service of the complaint was made upon defendant as indicated on plaitniff's affidavit of service previously filed. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. -?--- ? I January 1-7_, 2008 NIEL L. SH ER WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (D) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. January P , 2008 ?? 4':-'1 ? ?: I?i .--M G? - ::: ? ?'? r ;-? 3?.. N sv ??,?? t.: n.? -- ._.... r; ; . DANIEL L. SHEAFFER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALLISON J. SHEAFFER, : NO. 2007 - 5545 CIVIL TERM Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about September 20, 2007. Service of the complaint was made upon defendant as indicated on plaitniff's affidavit of service previously filed. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. Jew ! y 2008 ALLISON J. S AFFER WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. l7 a , 2008 ALLISON J. SH AFF R Cc,rt?k lONV nOKI-x L. .r f'_, Y'^,.t ^? i ? , .. .. .., "dl -f ' . <' .,?" ^aJ ??: C?"+ ,' -- HAROLD S. IRIVIN,111, ESQUIRE ATTORNEY ID NO. 29M " SOUTH PITT STREET CARLISLE PA 17013 (717) 24341090 ATTORNEY FOR PLAINTIFF DANIEL L. SHEAFFER, PlalntlA' V. ALLISON J. SHEAFFER, Dahndant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY] PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 5545 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. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about September 26, 2007 defendant was personally served with a copy of the divorce complaint (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: January 17, 2008 By the defendant: April 14, 2008 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 5. Complete 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: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary. April 29, 2008 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 29, 2008 April 29, 2008 HAROLD S. IRWIN, III Attorney for Plaintiff ? < r'r r ? E?i ' CD .? 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Aft STATE OF PENNA. lw- - DANIEL L. SHEAFFER 11 Plaintiff N O. 2007-5545 CIVIL TERM VERSUS ALLISON J. SHEAFFER DECREE IN DIVORCE //"'l044% o? AND NOW, ;bog, IT IS ORDERED AND DECREED THAT DANIEL L SHEAFFER PLAINTIFF, AND ALLISON J. SHEAFFER 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 PROTHONOTARY .,