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Home My WebLink About07-7135 Miranda M. Sheller Plaintiff V. Rodney L. Sheller Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- _71- CIVIL TERM 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 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 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, 1 Courthouse Square, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Miranda M. Sheller Plaintiff V. Rodney L. Sheller Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- '1135' IN DIVORCE CIVIL TERM COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is V li)& l S?-L l 1'Q_ V , who currently resides at Cumberland County, Pennsylvania. 2. Defendant i??R-N a 6 who currently resides at la Nor ?k `-Pa e &5e_, 0?4LJ(L4 P A 1-7o?oS 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on sQ 12Nat 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of 10her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. -44 Date Plaintiff, Pro Se I, Iv?IVQn& ?k . ?J D (P-r , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: AA -CJ A"14'-fi Plaintiff, Pro Se Assisted by: Barbara Sumple-Sullivan, Esq. Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 . i I., I Miranda M. Sheller Plaintiff V. Rodney L. Sheller Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 1[3s' CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING 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 that 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. 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. H rv i L . C 3 rTl 3 C 3 G r) - Miranda M. Sheller Plaintiff V. Rodney L. Sheller Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- ^7/3.S CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Miranda M. Sheller. Plaintiff, to proceed in forma au eris. I, Barbara Sumple-Sullivan, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 a - rt ?T A s' - J iT i C _ e , MIRANDA M. SHELLER, Plaintiff V. RODNEY L. SHELLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 7135 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Certified Mail, Certified No. 7007 0710 0003 2208 5619, Return Receipt Requested, on the above-named Defendant, Mr. Rodney L. Sheller, on November 30, 2007 at Defendant's last known address: 12 N. Baltimore Avenue, Mt. Holly, PA 17065. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: March 20, 2008 Barbara umple-Sullivan, Esquire For Miranda M. Sheller Ab (Domestic Only; Provided) ti n F d li i f t orma o or e n very I OtS a www.usps.comri, rU Postage $ so.fl 4 ru Certified Fee #2.65 r?1 _ J C3 O Retum Receipt Fee (Endorsement Required) $2.15 + ? .- -; Q r3 Restricted Delivery ,Fee (Endorsement Required) X0.00 r? P- Total Postage & Fees $ 65.21 11 /29/2007 C3 r- ` ° L S l l r o r%- r PO 4P? NO.' I or PO Box No, . a ?} nrQ JI ? City State, Z/P+4 - . _. .. -- .C -??' 9.- ¦ CaMI M bm 1, 2, and 3. Also complete item 4 It Restticted 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 mailpiece, or on the front If space permits. A r o Agent Adclivam by (Printed Name) C. Date of DeNvery Article Addressed to: Sl?.l t?Umov LA PR n D. Is delivery address dfffwent from Item 17 ? Yee . If YES, enter delivery address below: ? No 3. Service Type 14 Certified Mail ? Express Mail ? Registered ? Rotum Receipt for Merchwx fas ? Insured Mail ? C.O.D. 4. Restricted Delivery? Pft Fee) ? Yes 2. Article Number (r?aWwfrom senlwmb q - 7007 710 00 3 22x8 5619 PS Form 3811. February 2004 Dornestle Return Rec elpt 102595-M4A-1540 EXHIBIT "A" Miranda M. Sheller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7135 CIVIL TERM Rodney L. Sheller Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. Dater 6010S SignatureL-IT l.t,'LL? Miranda M. Sheller, Plaintiff C-', rv c i o Miranda M. Sheller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7135 CIVIL TERM Rodney L. Sheller Defendant 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 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 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 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. Date: 3 6,0 1o Signaturel?t.Qly???ODD?? Miranda M. Sheller, Plaintiff .> rr,, e.? c., ? t_ i .ti .?? '?.? r ?-/ r?3 ?° _, ; t`r°, ?` `^ ^?;? J_} . „„? ?. , ', ° ;.? ?;:+ ?R ?s Miranda M. Sheller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7135 CIVIL TERM Rodney L. Sheller Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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 ties relating to unsworn falsification to authori Date: Signature: Rodney L. Sheller, Defendant c CZZ dV - a -:` C r Miranda M. Sheller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7135 CIVIL TERM Rodney L. Sheller : Defendant 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 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 is granted. 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 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: 3`/'7-dt3 Signature: Rodney L. Sheller, Defendant FTI Cn J Miranda M. Sheller Plaintiff V. Rodney L. Sheller Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7135 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: Defendant signed Acceptance and Acknowledgment of Service form on November 30, 2007 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, March 20, 2008 ;by Defendant, march 17, 2008 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: March 24, 2008 (c) Date Defendant's Waiver of Notice in Section (c) Divorce was filed with the Prothonotary: March 24, 2008 Dated: March 20, 2008 Barb e-Sullivan, for Miranda M. Sheller Cla e=-c q c.n y C::? IN THE COURT OF COMMON PLEAS + + OF CUMBERLAND COUNTY + STATE OF PEN NA. + MIRANDA M. SHELLER, + 07 - 7135 + + Plaintiff No. + + + VERSUS + RODNEY L. SHELLER, Defendant + + DECREE IN + DIVORCE + + + + 2008 + AND NOW, 2-6 Y , IT IS ORDERED AND + Miranda M. Sheller + DECREED THAT PLAINTIFF, + Rodney L. Sheller + AND 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. + + + + + BY THE COURT: + + + ATT E J PROTHONOTARY + ;?o- -)e -,?- 6,9o - Ir-F