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Home My WebLink About07-6822Andrew C. Sheely, Esquire 'OF 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CRAIG A. NOVINGER, JR., 07 - G P? a C Lc??-? 71 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 against 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 with 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 Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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 41&) BY Andrew C. Sheely, Es u PA. I.D. No. 624 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff ` Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CRAIG A. NOVINGER, JR., 07 - 6,P-22 Defendant IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - to P.z.Z C?2c'a ?? ?... IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is ALLISON L. NOVINGER, an adult individual who currently resides at 303 Fulton Street, Enola, Cumberland County, Pennsylvania. 2. Defendant is CRAIG A. NOVINGER, JR., an adult individual who currently resides at 28 South Market Street, Apartment 1, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 21, 2005 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about September 7, 2007. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT 2 - DIVORCE - 3301(d) 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. 2 WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. Date: November 1 , 2007 Respectfully s ed, Andrew C. Shee , Esquire Attorney for Ifflaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 3 f VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. 1 Date: November , 2007 Allison L. Novinger Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 0 7 - G F .ZZ Cct ??... IN DIVORCE AFFIDAVIT Allison L. Novinger, being duly sworn according to law, deposes and says: (1) I 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) I understand that the Court maintains a list of marriage counselors in the Domestic Relations 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 by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Allison L . No nger I C? ?^?- ? :P.; ate C> ! Ct• + ( 3r ? c Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 6822 IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon CRAIG A. NOVINGER, JR., Defendant, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt card, on November 20 ANDREW C. SHEELY SWORN to and subscribed before me this /'Yr"day of November, 2007. - 2 Notary ublic My Commission Expires : WTAIM SEAL BECKY W. IMEV, Rloty I?t "c ?? ExOea Nov. 19 19, 2010 W ¦ Complete items 1, 2, and 3. Also complete A. eived by (Please Print Clearly) B. Date of Delivery item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. C. Signat ¦ Attach this card to the back of the mailpiece, ? A ant or on the front if space permits. ? Addressee D. Isdeliv different from item 1? ? Yes 1. Article Addressed to: ",(Y ??? No Craig A. Novinger, J?DELIVER , RESTRICTED DELIVERY Y FOR ADDRESSEE ONLY r \ - *3 ice Type 28 South Market Stre p- ertified Mail 1:1 Express Mail Apartment 1 Iv egistered ?ReturnReceiptforMerchandise ? Insured Mail ? C.O.D. Mechanicsburg, PA 17055 4. Restricted Delivery? (Extra Fee) X Yes 2. Article Number (Copy from service label) 7001 2 510 0000 3029 3421 PS Form 381 1 , July 1999 Domestic Return Receipt 102595-00-M-0952 r=1 ru -- rn Ir Postage ru O Certified Fee m Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Totsl pootsgs & Foss ru Sent To Craig r-q Street, Apt. No., C3 e s p or PC Box No. - C3 Clry State, ZIP+4 2$ r Mechanic .? .00 ? -.00 n c?. mss.. !771 ..-r TT r a O -n J _ C ? C7 n m w ? p Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 6822 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 9, 2007. 2. The marriage of Plaintiff and 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: -2 c; 0 1 r ?? , t L Allison L. nger qp ? .3-y (. ,,?, Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID 140. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 6822 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301 (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, lawyer's fees or expenses if I do not claim them before a divorce decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: Allison L. Novinger C3 C ° C= ? i4?' ' f'?7 3"tZ > Na ern C7 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 6822 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(x.) of the Divorce Code was filed on November 9, 2007. I acknowledge accepting service of the divorce complaint on November 13, 2007. 2. The marriage of Plaintiff and 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: 2- 21-0 i A. winger, Jr. C= Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 6822 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301 (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, lawyer's fees or expenses if I do not claim them before a divorce decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : .?. ' 2-' O -T) OT L K' C-n f t S v ALLISON L. NOVINGER, Plaintiff VS. CRAIG A. NOVINGER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 6822 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 3301(c) 2. Date and manner of service of the complaint: Acceptance by Defendant on November 13, 2007. 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit required by 3301(c) of the Divorce Code: by plaintiff 02/05/09; by defendant 02/02/09. b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code N/A (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: b. Date of plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 02/05/09 Date defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 02/05/09 061 cs, Andrew C. Sheely, Es it Attorney for Plain f 127 South Market Street Mechanicsburg, PA 17055 (717) 697-7050 ? a G .c+ - r7 r N ALLISON L. NOVINGER. IN THE COURT OF C CUMBERLAND COU V. CRAIG A. NOVINGER, JR., : NO. 07 - DIVORCE DECREE AND NOW, Zoa , it is o ALLISON L. NOVINGER , plaintiff, am CRAIG A. NOVINGER, JR. defendant, bonds of matrimony. LION PLEAS OF , PENNSYLVANIA ered and decreed that divorced from the Any existing spousal support order shall hereafter be eemed an order for alimony pendente lite if any economic claims remain pendi g. The court retains jurisdiction of any claims raised by th parties to this action for which a final order has not yet been entered. Those clai s areas follows: (If no claims remain indicate "None.") None By the Court, , q J. ?_ 1- Prothonotary 69 I,? o.????r h ?y w ALLISON L. NOVINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CRAIG A. NOVINGER, JR., NO. 07 - 6822 Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, (select one by marking "x") prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated February 10, 2009, hereby elects to resume the prior surname of Allison L. Schwillel and gives this written notice avowing her intention pursuant to the provision of 54 P.S. 704. f Date: February 19, 2009 - V_ Allison L. Novin er Allison L. Schwa e COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the 17?k day of February 2009, 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 purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public < t'2zu)e--, My Commission Expires: /111 a -/Q-0 c0 NOTARIAL SEN. lbd ?PubC ?, Em N. Dow, NI? Carunbdon wo"I a Nov. 19, 2010 r-a r Sy ti ? - -, -_.. ?> .may t ? -; `. ._.- .: _; ? ? ?•... $+J ? w ?, ?-