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HomeMy WebLinkAbout03-5875Ernest L. Shope Plaintiff VS. Letti G. Shope Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA :No. Civil Action - Law 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 without you and a decree in divorce or annulment may be 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 the custody or visitation rights 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 Prothonota~ at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, PA 17013 (717)-249-3166 IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Plaintiff L : Civil Action - Law VS. : : In Divorce Letti G, Shope, : Defendant : COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE Plaintiff is Ernest L. Shope who currently resides at 607 Charles Street, Shippensburg, Cumberland County, Pennsylvania, since October 5, 1995. 2. Defendant is Letti G. Shope who currently resides at 2 Holly Court, Shippensburg, Cumberland County, Pennsylvania, since .luly 21, 2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on August 20, 1983, at Old Mill Road, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 I veri~ that the statements made in this Complaint are true and correct. ! 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: ~/'~///~ Ernest L. Shope IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ernest L. Shope, Plaintiff VS. Letti G. Shope, Defendant : No. ~.0©~ : Civil Action - Law : In Divorce AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Letti G. Shope, of 2 Holly Court, Shippensburg, PennsyJvania, 17257, certified mail, return receipt requested on November /F/ , 2003 and was accepted on delivery by Letti G. Shope. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Swom to and subscribed this /?-~day of November ._ ,,~,~'~_ Notary Public. My Commission Expire ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ernest L. Shope, : No. 03-5875 Plaintiff : : Civil Action - Law VS, : : In Divorce Letti G. Shope, : Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 6, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the decree. ! 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 '~904 relating to unsworn falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ernest L. Shope, Plaintiff VS, Let-ti G. Shope, Defendant : No. 03-5875 : Civil Action - Law : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice· 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 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. Section 4904 relating to unsworn falsification to authorities. I~r~est L. Sh~p~ U Ernest L. Shope, Plaintiff VS. Letti G. Shope, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA : No. 03-5875 : Civil Action - Law : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 6, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Section 4904 relating to unsworn falsification to authorities· Le~t~TG. Shope / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ernest L. Shope, Plaintiff VS. Letti G. Shope, Defendant : No. 03-5875 : Civil Action - Law : In Divorce : WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 ! 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. Section 4904 relating to unsworn falsification to authorities. Letti/G. Shope / Ernest L. Shope, Plaintiff VS, Letti G. Shope, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA No. 03-5875 Civil Action - Law 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; Ground for divorce; irretrievable breakdown under 3301(c) of the Divorce Code. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on November 17, 2003, and was accepted by Letti G. Shope on November 20, 2003. An acceptance of service signed by Defendant acknowledging acceptance was filed of record· Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff, February 23, 2004; by Defendant, February 21,2004. 4. Related claims pending: None. Plaintiff's Waiver of Notice was signed on February 23, 2004 and is filed herewith; and Defendant's Waiver of Notice was signed February 21, 2004 and is filed, herewith. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, Pa. 17257 717-532-3270 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~. PENNA. Ernest L.Shope PlmintiFf VERSUS Letti G. Shope Defendant NO. 03-5875 Civil Term DECREE IN DIVORCE DECREED THAT Ernest L. Shope AND Letti G. Shope , --~0J~L, IT IS OrDErED AND , PlAINTiFF, , 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 the CooR~: X~ /7 / ATTest/ ' (~ /~ ~ PROTHONOTARY 1N THE cOURT OF cOMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff : : FILE NO. VS. ' Defendant : IN DWORCE NOTICE TO RESUME pRIOR SURNAME. Notice is hereby given that the Plaintiff/Defendant in the above matter, having anted a Final Decree in Divorce on the [~ _>dayof_~t., } -s/] ~/., beengr . /, .,, . ~. hereby elects to resume the prior surname of d?~/_¢, ~Q~.f ~ fft~ and gives this written notice pursuant to the provisions of 5,4 P.S. 704. cOMMONWEALTH OF PENNSYLVANIA - / Signature si ,Z5 of,]h;.e being resumea · SS cOUNTY OF CUMBERLAND On ~he _ ~,~ day of~ Notary Public, personally appeared ~he above affiam kn is subscribed ~o the within document and acknowledged tha~ he/she executed the foregoing for the purpose ~herein contained. In Witness Whereof, I have hereunto set my hand and official seal. , 20_Ot~_, before me, a to me to be the person whose name Notary Put~llc t NOTARIAL SEAL I Elaine M. Regi, Notary Public orth Middleton Twp., County of Cumberland My Commission Expires N~ov. 6, 2004