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HomeMy WebLinkAbout07-7314a. KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff MICHAEL SHIREY, Plaintiff V. MARYLENA SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 67- 7.3/t/ 6.4'Ta-pyl CIVIL ACTION - LAW 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 at the Cumberland County Courthouse, Hanover and High Streets, Carlisle, PA 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 0- MICHAEL SHIREY, Plaintiff V. MARYLENA SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW DIVORCE 67- COMPLAINT FOR DIVORCE COUNT I Request for a No-fault Divorce Under S3301(c) of the Domestic Relations Code 1. Plaintiff is MICHAEL SHIREY, who currently resides at 1098 Grandia Flora Drive, Mechanicsburg, Cumberland County, PA 17055. 2. Defendant is MARYLENA SHIREY, who currently resides at 1098 Grandia Flora Drive, Mechanicsburg, Cumberland County, PA 17055. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 2, 1986 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. 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. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(c) of the Domestic Relations Code. COUNT II Request for a Fault Divorce under S 3301(a) of the Domestic Relations Code 8. Plaintiff hereby incorporates Paragraphs 1 through 7 of his Complaint as if fully set forth herein. 9. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(a) of the Domestic Relations Code. COUNT III Recruest for Equitable Distribution of Marital Property Under 53502 of the Domestic Relations Code 10. Plaintiff hereby incorporates Paragraphs 1 through 9 of his Complaint as if fully set forth herein. 11. The parties are owners of marital property subject to equitable distribution. ... 12. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties and the marital debts of the parties without regard to marital misconduct in such proportions as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order of Equitable Distribution of marital property and marital debts pursuant to §3502 of the Domestic Relations Code. DATED: 11/28/07 KEN ET F. LEWIS, ESQUIRE Att rney for Plaintiff I.D. #69383 1101 N. Front St. Harrisburg, PA 17102 (717) 234-3136 VERIFICATION I hereby verify that the statements made in the foregoing document 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. 11 Dated: 11/28/07 MI HAEL SHIRE fi p ? e -4s LIQ W OD a r Q n i? N C7? c. ?s X7 W 1. MICHAEL SHIREY, Plaintiff V. MARYLENA SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-7314 CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF SERVICE I certify I served the Divorce Complaint upon the defendant, Marylena Shirey by certified mail, addressed to 1098 Grandia Flora Drive, Mechanicsburg, PA 17055 and that Ms. Shirey received, and signed for, the Complaint on December 24, 2007, as evidenced by the receipt attached below. DATED: 12/26/07 ¦ Compleb Items 1, 2. and 3. Also complete Item 4 If FleeMcted Delivery is dnW. ¦ Print your name and addran an the reverse so that we can return the card to you. ¦ Attach this card to the back of the ffm0plece, or are the front If space permits. 1. Aftls Addreeed to: (yW1 Sena Ai'e 10g9 brand a a D? PR Moss ,& KEINETH/F. LEWIS, ESQUIRE I.. #9++9383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff Agent Received by ( C. Dab of Dativery Gr Ian(,, S ?r D. Is ddvery adds dW&u feom kwn 13 yea ff iRk bebw. ? No G ,? i DEC 2 4 20W ?1 r 3. O Return Reosipt for IMafCTWW" 13 ka mW Md O C.O.D. 4. Reakfcbd DsNvery? Oft Fire) 2• Article Nrnrbw 7006 2150 0003 8543 6 617 ( WWW Sym SW%be Ps Form 381 1, febnieuy 2W4 nm NNUc Fb" itAOW ,a lit-IM e-3 c t- f it MICHAEL SHIREY, Plaintiff v. MARYLENA SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-7314 CIVIL ACTION - LAW DIVORCE PRAECIPE TO DISCONTINUE CASE TO THE PROTHONOTARY: On behalf of the Plaintiff, please discontinue the above matter. 'N DATE: 1/28/08 KE ETH F LEWIS, ESQUIRE I.D. #69383 1101 N. Front St. Harrisburg, PA 17102 (717) 234-3136 ?. a ?" 4? 3 ?.