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Home My WebLink About03-6394 , ALISHA A. SHOLLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 03 - ~39~ GLENN E. SHOLLY, JR., Defendant 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 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. 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. 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. Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ALISHA A. SHOLLY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. GLENN E. SHOLLY, JR., Defendant : CNIL ACTION - LAW : IN DNORCE COMPLAINT COUNT 1 - DIVORCE AND NOW comes Plaintiff, Alisha A. Sholly, by her attorney, Diane S. Baker, Esquire, and files this Complaint, based upon the following: 1. Plaintiff, Alisha A. Sholly, is an adult who currently resides at 69 Oliver Road, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, GJeIIII E. Sholly, Jr., is an adult individual who currently resides at 105 East Cumberland Road, Enola, Cumberland County, PeIlIlsylvania 17025. 3. Plaintiff and Defendant were married on November 9, 2002, in Cumberland County, PeIlIlsylvania. 4. Plaintiff and Defendant separated on or about November 11, 2003. 5. Plaintiff has been a bona fide resident of this Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 6. Defendant is not presently a member of the Armed Forces on active duty. Plaintiff is not presently a member of the Armed Forces on active duty. 7. There are no pending actions in divorce or annulment in this jurisdiction or in any other jurisdiction brought by either Plaintiff or Defendant above-named. 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 to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken. COUNT NUMBER 2 - CLAIM FOR EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 above are herein incorporated by reference. II. The Plaintiff and Defendant are owners of various items of personal property, furniture and household furnishings acquired during the marriage which are subject to equitable distribution by the Court. 12. The Plaintiff and Defendant are owners of various motor vehicles acquired during the marriage which are subject to equitable distribution by the Court. 13. The Plaintiff and Defendant singly or jointly have interests in various bank accounts acquired during the marriage which are subject to equitable distribution by the Court. 14. The Plaintiff and the Defendant have acquired during the marriage other marital property which is subject to equitable distribution by the Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: (a) (b) (c) Dissolving the marriage between Plaintiff and Defendant; Equitably distributing all marital property owned by the parties hereto; and Such further relief as the Court may determine equitable and just. DATE: rz_1510 ') Respectfully submitted, ~th/~ cZZ:, E~cire Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 VERIFICATION I verify that the statements made in this Complaint 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. ~{0 Q. JlJo-Vy ALISHA A. SHOLLY U ~ ~ ~ ~- ~,~ ~ ~ J D :IF ~n' c.: ~~ iJ1 ~ ~/ ,~ _ 0 f..J t;,;,'. C ..r:. -:::.. 5';~, c:) 'I-) :::.:J :..11 " " (.1) W I:l<J --- ~ 1" , ) , , .! ALISHA A. SHOLLY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03 -l39~ GLENN E. SHOLLY, JR., Defendant : CIVIL ACTION - DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Alisha A. Sholly, in the above- referenced matter. Respectfully submitted, DATE: December 8, 2003 ) \/.. ~?-~-:;;::;:;::. '/-:< .>. ~e S. ~~er, Esquire Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 (') 0 c (,,) ~ C::J -Or: -;-1 ~!; ~-.') Z , 0) t.C -< !< '..J >. z(: S;;C ,,' -' c , -7 en :J,~ :;: '0 :< ALISHA A. SHOLLY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-6251 GLENN E. SHOLLY, JR., Defendant CNIL ACTION - LAW IN CUSTODY ALISHA A, SHOLLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6394 ..... GLENN E. SHOLLY, JR., Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Diane S. Baker, Esquire, hereby certify that a true and correct copy of the Complaint for Custody and Complaint in Divorce was served on the Defendant by certified mail, restricted delivery, return receipt requested, on December 13, 2003, at the Defendant's last known address of: 105 East Cumberland Road Enola, P A 17025 The return receipt card is attached hereto as Exhibit "A" ',' ,,"~''''/_''''_,,_.__~~;/ /" .,/ ~ ~~.?// Diane S. Baker, Esquire Attorney for Plaintiff . Complete ~ems 1, 2, and 3, Also complete item 4 ~ Res1rlcted Delivery is desired, . Print your name and address on the reverse 10 that we can return the card to you. . Altach this card to the back of the mall piece, or on the front nAPace permits, 1. Article Addressed to: GIe.nn'IG.5,.,ol\'1J \J1. \ 05 Sa8'\- Cumber-Ia.rd "RoacL "(ooln. {JA \iOd-b 3. Service Type o Certified Mail 0 Express Mail o Registered 0 Return Receipt for MerchendiIlt o Insured Mall 0 C,Q,D, 4, _ Delivery? (E>1nI-1 ~ --- qc.a !J1M.b\'M..!!J, 2. Articl (7l'am PS Fon ._/:;~r- EXIllBIT "A" (') c s:: -Orn ~,jLCl g~ ::-7 C) ~C) "'."C- ~ l'-3 c::, = <..> = P"l " co f'.) f',) \.;.0 ---4 f11:r:; f--' 1"71 ";7 L L) -T, -,- ,",' ALISHA A, SHOLLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6394 GLENN E. SHOLLY, JR., Defendant CNIL ACTION .. LAW IN DNORCE AFFIDA VlT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on December 9, 2003. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. 4. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Decree being handed down by the Court. 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 of18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: 8-~-{)lf Ill(~h1.) a ,) hd4{f X'LISHA A. SHOLLY PLAINTIFF $:2 "" 2~_:; "4:"~ ('"' ...... .'1/ 0.) (./1 .D'" ALISHA A. SHOLLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6394 GLENN E. SHOLLY, JR., Defendant CIVIL ACTION -, LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE (INDER ~3301 W 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 in 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. S 4904 relating to unsworn falsification to authorities. DATED: g--(P-()Lf Jll,{!Jh ,CLJfJr~ft ALI~;HA A. SHOLLY . PLAINTIFF o c, ....... c:::l ~,;~ ...- OJ en .r.-;" ALISHA A. SHOLLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6394 GLENN E. SHOLLY, JR., Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on December 9, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. 4. 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, I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Decree being handed down by the Court. 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 of18 Pa. C.S. * 4904 relating to unsworn falsification to authorities. DATED: M J!;tr!Ai?'L/ q 1/'S )[ .~ GLENNE. SHOLLY, . DEFENDANT fi_'} 1< ALISHA A. SHOLLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA v, NO. 03-6394 GLENN E. SHOLLY, JR., Defendant CIVIL ACTION - LAW 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 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. S 4904 relating to unsworn falsification to authorities. DATED: I M /0/1/4 tifLAj' { J ~ I GLENN E. S LL Y, J . ! DEFENDANT r~" "; r,j ALlSHA A. SHOLLY, Plaintiff ~ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03-6394 Civil Term GLENN E. SHOLLY, Defendant : 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: I. Grounds'for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and maIlIler of service of the Complaint: The Defendant Accepted Service ofthe Complaint on December 13. 2003. said Affidavit of Service was filed with this Honorable Court on Janna 18.2003. 3. Complete either Paragraph (a) or (b): (a) Date of executioll ofthe Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: November 9. 2005; By Defendant: October 7, 2005. (b) (1) Date of execution ofthe Affidavit required by Section 3301(d) ofthe Divorce Code: ~ (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: ~. , 4. Related claims pending: Defendant is filin a Praeci e to withdraw her Claim for E uitable Distribution this date simultaneousl with the within Praeci e to Transmit the Record. I 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 Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: November 16. 2005; Date Defendant's Waiver of Notice in Section 330l(c) Divorce was filed with the Prothonotary: October 20. 2005. By: Ti~~~1.~re Supreme Court I.D, #77944 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 432-9666 (Attorney for Plaintiff) Date: 3-.? I - 00 ~~,. \,',-:- i':~ f",,) C.:' ALISHA A. SHOLLY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03-6394 Civil Term GLENN E. SHOLLY, Defendant : CIVIL ACTION - LAW : IN DIVORCE WITHDRAWAL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: PLEASE withdraw my appearance as attorney of record for the Plaintiff, ALISHA A. SHOLLY, at the above-captioned docket. Respectfully submitt y: ~ DlaneS. Baker, Esquire 27 South Arlene Street Post Office Box 6443 Harrisburg,PA 17112 Dated: ~ro \0 PLEASE enter my appearance as attorney of record for the Plaintiff, ALISHA A. SHOLLY, at the above-captioned docket. Respectfully submitted by: Timothy J. I , uire 130 West hurch Street Suite lOO Dillsburg, P A 17019 Supreme Court ID# 77944 (717) 432-9666 Dated: l/- 2{ , Qb (') ,..." ~ = C C? -~ o~ ~-, ::;l': --I 'l.Jcr :r:-n rTIr' ~ n'E -:-" -~ ;,X N '-011, ,'Py -~:; (,.fl ' ';:"-\ )~_.-'-- _.V' -0 (') ".;'1 ";?;. - (') . ..,...;;;... -.,. C -::o.-::rn j,> C': r::> '-"> ,-, ~. '- ~ "':0 -( ~ :< 0''> ALISHAA. SHOLLY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03-6394 Civil Term GLENN E. SHOLLY, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO WITHDRAW COUNT 2 OF DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly withdraw Count 2 of Plaintiffs Complaint in Divorce filed at the above-captioned docket, relating to Plaintiff's Request for Equitable Distribution of Marital Property Under s3502(a) of the Divorce Code. Respectfully Submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.C. Date: )-ZY-o,- By: Ti~~uire Supreme Court LD. #77944 130 West Church Street, Suite 100 DiIlsburg, P A 17019 (717) 432-9666 (Attorney for Plaintiff) (') ~ ~ c: c-" :;f:' if' -QtX:1 ::'Jt. :i!.-n me ",. ri1p 7"!" , _<c ~ "crG. (f) :1)0 ;.s , ~ ~~~~\ (~." .c:-" -0 - :i;, " ::t: '~?{~, ~~" ~ J;:" 2:0 <.5; 0::<. , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . . . . ALlSHA A SHOLLY, Plaintiff N 03-6394 CIVIL TERM O. . . VERSj.JS . . GI FNN F ~HOII Y n",f"'nrl~nt . DECREE IN DIVORCE a:1 '(: 'J).f' III ,~, , IT IS ORDERED AND . . . . . . AND NOW, ~~,~ . . DECREED THAT ALlSHA A SHOLLY , PLAINTIFF, . . . AND GLENN E. SHOLLY , 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; . pJl/'f'J<. . . . . . . . . . ATTEST: /l~ J. . . . . . . PROTHONOTARY . . ~r~ ~ ~ 'Jr;-Cc.t?J ~ frP~ 7'~ /4J ?'9 ??- ('e-'/