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Home My WebLink About08-0923 KRISTIN L. SAYERS, Plaintiff V. STEVEN L. SAYERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2008-qZ CIVIL TERM IN DIVORCE NOTICE 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 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 Court House, High and Hanover Street, Carlisle. 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. Court Administrator Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 ?. /9, 20 a 8 JO A J. K ECKY, IRE Supreme Court ID #53147 300 North Second Street, 8`h Floor Harrisburg, PA 17101 (717)221-1111 Attorney for Plaintiff U KRISTIN L. SAYERS, Plaintiff V. STEVEN L. SAYERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :2008- qd3 CIVIL TERM : IN DIVORCE AND NOW, comes the Plaintiff, Kristin L. Sayers, by and through her attorneys The Shagin Law Group LLC, and respectfully avers the following: COUNT NO. 1: COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE Plaintiff is Kristin L. Sayers, an adult individual, who currently resides at 455 Hollowbrook Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Steven L. Sayers, an adult individual who currently resides at 455 Hollowbrook Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 15, 1994, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling, as evidenced by the Affidavit as attached hereto and made a part hereof marked as "Exhibit A." 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. AK COUNT NO.2:EQUITABLE DISTRIBUTION 8. Paragraphs 1 through 7 are incorporated herein by reference. 9. The parties have acquired certain property, real, personal and mixed, during their marriage. 10. Plaintiff requests Your Honorable Court to enter an order equitably dividing said property. COUNT NO. 3: COMPLAINT FOR CUSTODY 11. Paragraphs 1 through 10 are incorporated herein by reference. 12. The parties are the natural parents of two minor children, Makenzie Sayers, d.o.b. 09- 04-1999, and Morgan Sayers, d.o.b. 04-17-2002. 13. Plaintiff is the natural mother of said children, Defendant is the natural father. 14. Since birth, the minor children have resided with both parents at 455 Hollowbrook Drive, Carlisle, Cumberland County, Pennsylvania. 15. Plaintiff believes it is in the best interests of the children to grant she and Defendant shared legal custody of the children and her primary physical custody subject to periods of partial physical custody in Defendant as the parties may agree. WHEREFORE, Plaintiff requests Your Honorable Court to grant the parties shared legal custody and she primary physical custody of the minor children. Respectfully submitted, Johnn opeck , Esquir Supr e Court ID #53147 300 North Second Street, 8`h Floor Harrisburg, PA 17101 (717) 221-1111 KRISTIN L. SAYERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2008- CIVIL TERM STEVEN L. SAYERS, : IN DIVORCE Defendant AFFIDAVIT I, Kristin L. Sayers, Plaintiff, being duly sworn according to law, depose and say: (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 Prothonotary's 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. Section 4904 relating to unsworn falsification to authorities. Date: N4? ?a Kris in L. Sayers, P ainti VERIFICATION COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND :SS 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. DATED: stm L. ay s, Plai 'ff ' M C t7 9-1 Cc r I Ci w CA ' 0 93 _ (a- - KRISTIN L. SAYERS, Plaintiff V. STEVEN L. SAYERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2008- 923 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT TO DIVORCE (1) A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 8, 2008. (2) Defendant acknowledges that service of the Complaint on February 15, 2008. (3) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (4) 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. (5) I consent to the entry of a final decree of divorce. (6) I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. (7) 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. 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 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. DATED: Steve . Sayers, Defendant t? ?s ?, _y ?-? ?" -? -? z., 9 °4} f _ .-` j.?_. ?, ?F am ...... h . 1 Y?j " "_ fi v?F -nA KRISTIN L. SAYERS, Plaintiff V. STEVEN L. SAYERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2008- 923 CIVIL TERM IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE (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. Section 4904 relating to unsworn falsification to authorities. Date: Steven L. ayers, Defendant C3 +?a 4, 1 7 ? '-gym KRISTIN L. SAYERS, Plaintiff V. STEVEN L. SAYERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2008- 923 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT (1) A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 8, 2008. (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (3) I consent to the entry of a final decree of divorce. (4) 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 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. Date: Ki n r L. Sayers,P aintiff ^ - y n't i ?' KRISTIN L. SAYERS, Plaintiff V. STEVEN L. SAYERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2008- 923 CIVIL TERM IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE (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. Section 4904 relating to unsworn falsification to authorities. Date: 5// 4/d Si C3 r 7- = ? _ ca KRISTIN L. SAYERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2008- 923 CIVIL TERM STEVEN L. SAYERS, Defendant : IN DIVORCE PRAECIPF 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) or 3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail, on February 15, 2008), attached as "Exhibit A" 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent and Waiver of Notice required by Section 33010) of the Divorce Code: By the Plaintiff. By Defendant: May 16,2008 May 16, 2008 (b )(1) Date of Execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: Not applicable. (2) Date of Service of the Plaintiffs Affidavit upon the Defendant: Not applicable other. Related claims pending: The parties have no further issues or claims against each .:; rJ. -- A -i?-OF Respectfully submitted, Jo . Kopeck , squire Attorney for Plaintiff The Shagin Law Group LLC 120 South Street Harrisburg, PA 17101 (717) 221-1111 c? t._ =3 r r iai':' QD c D'8- 9013 AR-ota. +op ze iae, - DIVoree. ¦ °oni + ,, 2, and 3 Also complete the rovwm EE;? Or on the card to the back of ?lpleft, . front N space penults. ,. Made gdd?eeesd to: STe?eN L . 5? ?,?s y X55 ?ollowL?i2o??? !?? a r D. Is dOM addMft Miumt fmm itam 17 N YES, enter "vsiy ed"w bloW, lie a a«vlce,ym Asle,Pig 3 1 -wwlrlmummw o ?l 0 bmnd ? 0 C.O.D. 'a A?enaWkfte 2. N?u 4. R.etrided DSNVy? rasa Fee) ?'t+es e«?,e.wa.p 7006 OZ00 ?005 1037 2319 PS Form 3811, Febn,y 2ooa Domestic Realm Rooso 0 C. Dace of ?' -/e C7 -V M rTi JJ s. , 4 ?,r e, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. kRISTtN L. S.4fFR-S, Plain4i-' N 0. 2Oo $ q23 VERSUS DECREE 1N DIVORCE AND NOW, IV Am Zq Zoog, IT IS ORDERED AND DECREED THAT IGR-IC7IN L- C->ME.2-S PLAINTIFF, AND STeV-N L- SPt"fey" ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; BY THE COURiT: ATTES U ? J. s PROTHONOTARY a M