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Home My WebLink About04-0063 MICHELLE L. SUNDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW Defendant NO. D'-/ - ~3 IN DIVORCE CIVIL TERM SHANE R. SUNDY, 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 MICHELLE L. SUNDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW Defendant NO. C>LJ - W IN DIVORCE CIVIL TERM SHANE R. SUNDY, COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Michelle L. Sundy, an adult individual currently residing at 349 East Louther Street, Carlisle, Cumberland County, Pennsylvania, 2, Defendant is Shane R. Sundy, an adult individual currently residing at 71 Regency South, Carlisle, Cumberland County, Pennsylvania, 3, Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on March 22, 2002, in Loysville, Perry County, Pennsylvania, 5, There have been no other prior actions for divorce or annulment between the parties, 6, Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies, 7, Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling, Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling, 8, Plaintiff and Defendant are citizens ofthe United States of America, 9, The parties' marriage is irretrievably broken, 10, Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce, WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P,S, Section 3301 (c) of the Domestic Relations Code, Respectfully submitted, ~, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I 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 falsifications to authorities, DATE: / - J- at./- r;tl)'LLlU.-l~"d Slnd~ MICHELLE 1. SUNDY, Plaintiff {/ ~ "" ~ (} ~ ~ ~\ ~ ~ f: ~ [] C) I"~..) ;-- ~~~? c) , ~'~- -q ,("- ---j ~ ffi,;,~ rf:) ;+',) C +.; j,.) MICHELLE L. SUNDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL ACTION -- LAW SHANE R. SUNDY, Defendant : NO, 04-63 CIVIL TERM : IN DIVORCE TO THE PROTHONOTARY: PRAECIPE Please reinstate the Divorce Complaint previously filed in the above-captioned matter. Respectfully submitted, qJ/~/Dl1 Date' , ~.YZe, Esquire o;.,(ey for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 c) c; ~ - , ( ~ c: Co" /-:" _.i ~~ ~ "'" <;;;:;;;:1 ~ (I) ',1 ~{.J c~ u" " ::\~: c..-? r--.) MICHELLE L. SUNDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. SHANE R. SUNDY, Defendant : NO,04-63 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this Z. "8 n.. day of September, 2004, comes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, Michelle L. Sundy, and states that a true and attested copy of Plaintiffs Complaint in Divorce, was sent to Defendant, Shane R. Sundy, at 71 Regency South, Carlisle, P A 17013, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on September 25, 2004, W B '1 squire ifor Jkaintiff GRIFFIE-&" ASSOCIATES 200 North HarlOver Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscrib before me this of BLIC le"~1 a- .-'l CI .-'l Postage $ . ./"~'" ". , ( /Mm'\ !?-.,. '~ark\ ! ar'.' \. d}/j )." _c/."':"/ , "':. :~~:<~;;/ .-'l ,." CI CI Certified Fee a- CI CI CI Return Receipt Fee oc-- (Endorsement Required) _ 7 J Restricted Delivery Fee m (Endorsement Required) :5~ \,} ........ Total postage & Fees $ CI .-'l Ll1 nJ .-'l CI CI l'" -__4" """ VunnDn iii:!!!!JI UNITED STI.ITEs CiiI POsrI.lL SERvICE~ Page 1 of1 Track & Confirm Shipment Details You entered 70012510000910190031 Track & Confirm Enter label number: r Your item was delivered at 9:18 am on September 25,2004 in CARLISLE, PA 17013, Here is what happened earlier: · NOTICE LEFT, September 21,2004,12:32 pm, CARLISLE, PA 17013 Track & Confirm FAQs Notification Options 8 ~ Track & Confirm bYemal/ What is this? co> POSTAL INSPECTORS PreServing the Trust site map Contact us government services Copyright@ '999'2002 USPS, All Rights Reserved. T"ms ot Use Privacy Poticy :P://lrkCnfnJ11,Smi,USpS,COmlnetdata_Cgildb2WWW/Cbd_ 243.d2w/detail 9/28/2004 o ~; " -('\J' !'fir:' L";"'i ~7i: '(15: ::z r;~. :/;;c:' "':-:::::C! ):;;>C-: -";1" :'3 -. ~ = ",.. (/) en -0 N ...0 -c ::M: 0, -, .-\ :J:-r. {11r -ern ~~~ ~~ 1.")r~ ~::~i ..~:;>' "p '~..: -.' ., o 0' MICHELLE L. SUNDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs, : CIVIL ACTION - LAW Defendant : NO. 04-63 CIVIL TERM : IN DIVORCE SHANE R, SUNDY, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on January 6, 2004, reinstated on September 16, 2004, and service was made on September 25, 2004. 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, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S. 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES, DATE: l. / J J rx;- ,"",.5 y:~-, t ~ . ~~~, ;:: V;): ~'::.. L ~(:, ;:;(-- .;;.;,(_/ '::PC: ~ ./.. n <;; -:-.'.'" ~ ~ ~ .".~. ""- I .....J ~ ~~ ~rn :r.l,? 'S?tC) :c:!ri Q-- :;~._Q 0'" "-\ .~ :..c -'0 ::t: .- ., ;;:" v:> MICHELLE L. SUNDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL ACTION - LAW SHANE R, SUNDY, Defendant : NO, 04-63 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 THE FOREGOING 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 F ALSIFICA nON TO AUTHORITIES, DATE: & II I OS . . '"'C('.. ':t~\,;: (/ -- "",, ~~~\) ':7~. :1 ~ ~ -- .' Q, *~~ -"~ -0 ~'5;\ q~ ':2- "V' 'a. s:' c;> C) ~..:; ~ ~ '--- ~ ~ MICHELLE L. SUNDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA 'IS. : CIVIL ACTION - LAW SHANE R, SUNDY, Defendant : NO, 04-63 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301 (c) of the Divorce Code was filed on January 6, 2004, reinstated on September 16, 2004, and service was made on September 25, 2004, 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S, S4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, DATE: (0 -:15 ~O.:5 .Qke ~ ~~~ SHANE R, UNTIY, De ndant - -0 _'or ......... Q. '-\ -rc 4~ ClC 4",)8 ?2\(l, ~-.~:) -:.~::., "'~~{'\ \?~ ~~. n c., ~ """ Cf' S::-:. ,?-': - <..:> - .' s::- r-:> MICHELLE L. SUNDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL ACTION - LAW Defendant : NO. 04-63 CIVIL TERM : IN DIVORCE SHANE R. SUNDY, WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE IlECREE UNDER &3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: (; ,- p..5 ~ 05 ~~---<'-~(~ SHANE R, SUNDY, Defendant ..,' ~" ~-'\ '" (..-.r:'". c<. f <P (~\ A...-l"" .~, C,"'C,';" ... \.;.., '-9)'~~. "?~~,'^ ^~:c;.:,r;?\ .:~:~\ ~~9- -:;~;> ~ # . .~c 1:'" MICHELLE L. SUNDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW SHANE R, SUNDY, Defendant : NO, 04-63 : IN DIVORCE CIVIL TERM 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 ~330 I (c) 3301(d)(I) of the Divoree Code, (Strike out inapplicable section), 2, Date and manner of service of the Complaint: certified mail/restricted delivery on September 25,2004, 3, Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by S3301 (c) of the Divorce Code: by Plaintiff: June 1, 2005 by Defendant: June 25, 2005 (b) (I) Date of execution of the affidavit required by ~330] (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: none 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 of plaintiff's Waiver of Notice In ~3301 (c) Divorce was filed with the Prothonotary: June 7,2005 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: July 13,2005 ~~re GRIFFIE & ASSOCIATES Attorneyfor Plaintiff - tc, .,:::,.. 'c: q \.})"-c.. c~. t.~ (.....-:~ '('J'() c.>%",.. 'tt~~ '8 N -en ;.:.. ~ 0-- ..... \ ~ .:;;e. ~ ~ z:;, '~/~~h <~. ,\:\ fC\ \~'o... ~'2:. ,~ 1..:> -- +++.+++.++++++.+++.+.++++++++++++.++ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + ++ :f. + +. + + + + + + + + + + + + + +++++,..,++ ++++.+++++++.++++.+++++++ ++++++:+i IN THE COURT OF COMMON OF CUMBERLAND COUNTY + + + + + + + + + + + + MICHELLE L. SUNDY, PENNA, + + + + + STATE OF PLEAS Plaintiff No, 04-63 CIVIL TERM VERSUS SHANE R. SUNDY, Defendant DECREE IN DIVORCE AND NOW, tJo~ t:(~ , ZeUs , IT IS ORDERED AND DECREED THAT Michelle L. Sundy Shane R. Sundy AND ARE DIVORCED FROM THE BONDS OF MATRIMONY, , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None. B~E COu;J + + + + + + + + + + + + + + + . + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . ~ J?- ~;?M/ 7i?J:'1t.. 5(J' ql;; ~ frr/ 7- /rw ~7rV) 9:' Of, I; ~ 'II . ~'. j . :.... ..,.