HomeMy WebLinkAbout08-3295EDWARD E. HERFORD,
Plaintiff
V.
STEPHANIE M. HERFORD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008 - 3,P' ? CIVIL TERM
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,
including custody or visitation of your children.
When the ground for the divorce is inidignities 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, Carlisle, Pennsylvania 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVIES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
EDWARD E. HERFORD,
Plaintiff
V.
STEPHANIE M. HERFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008 - J.2 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
COUNT 1- DIVORCE
1. Plaintiff is Edward E. Herford, an adult individual who currently resides at 118
Big Spring Terrace, Newville, Cumberland County, Pennsylvania, 17241.
2. Defendant is Stephanie M. Herford, an adult individual who currently resides at
29 Mountain Street, Mt. Holly, Cumberland County, Pennsylvania, 17065.
3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth
for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 26, 2006 in Newville,
Pennsylvania.
5. There have been no prior actions of divorce or for 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.
8. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United
States or any of its allies.
WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce in
favor of Plaintiff and against Defendant.
4r
COUNT II - EQUITABLE DISTRIBUTION
9. Plaintiff hereby incorporates by reference paragraphs one (1) through eight (8).
10. During the course of the Parties' marriage, Plaintiff and Defendant have acquired
items of property that is marital property.
WHEREFORE, Plaintiff requests this Honorable Court to enter a decree that effects an
equitable distribution of the Parties' marital property.
Respectfully submitted,
O'BRIEbh BARIC & SCHERER
Robert J. D le Esquire
I.D. 20341
19 West Sou Street
Carlisle, Pennsylvania 17013
Phone: (717) 249-6873
Attorney for Plaintiff
r i
EDWARD E. HERFORD,
Plaintiff
V.
STEPHANIE M. HERFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008 - CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
VERIFICATION
I, Edward E. Herford, verify that the statements made in the foregoing Complaint in
Divorce are true and correct to the best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsifications to authorities.
Date: of April, 2008
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EDWARD E. HERFORD,
Plaintiff
V.
STEPHANIE M. HERFORD,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008 - 3295 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
PRAECIPE TO REINSTATE
Please reinstate the Complaint filed in the above-captioned matter on May 27, 2008.
Respectfully Submitted,
O'BRIEN, BARIC & SCHERER
Robert J. Dailey, Epq ' e
I.D. # 203418 V
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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6
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03295 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HERFORD EDWARD E
VS
HERFORD STEPHANIE M
KENNETH GOSSERT Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - DIVORCE
FiRPPORD STEPHANIE M
was served upon
the
DEFENDANT , at 1856:00 HOURS, on the 24th day of June , 2008
at 224 B STREET
CARLISLE, PA 17013
by handing to
a true and attested copy of COMPLAINT - DIVORCE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.00
Postage .42
Surcharge 10.00
00
38.42
2
(-6016 .
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
06/24/2008
OBRIEN BARIC SCHERER
By:
D ut ri
A.D.
i
EDWARD E. HERFORD,
Plaintiff
V.
STEPHANIE M. HERFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008 - 3295 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO WITHDRAWAL DIVORCE ACTION WITHOUT PREJUDICE
To: The Prothonotary of Cumberland County
Please withdrawal the divorce action without prejudice to the above-captioned docket
number as a result of both parties stipulating and agreeing to withdrawal said divorce,1cin.
RoVrt J. Dailey,W
I.D. No. 203418
19 West South Stre t
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff
EDWARD E. HERFORD,
Plaintiff
V.
STEPHANIE M. HERFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008 - 3295 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
STIPULATION AND AGREEMENT TO WITHDRAWAL THE DIVORCE ACTION
THIS STIPULATION AND AGREEMENT, entered into this day of August
2008, by and between Stephanie M. Herford (hereinafter, "Plaintiff') and Edward E. Herford
(hereinafter, "Defendant") is executed in contemplation of ending the above divorce action.
WHEREAS, Plaintiff and Defendant were married on October 26, 2006 in Newville, PA.;
WHEREAS, the parties separated on or about December 28, 2007;
WHEREAS, Defendant filed for divorce from Plaintiff on May 27, 2008 in this Court to
Docket No. 08-3295;
WHEREAS, the Sheriff served the Defendant on June 24, 2008 with this action;
WHEREAS, the parties have since reconciled their marriage; and
WHEREAS, the parties now wish to enter into this Stipulation and Agreement to
Withdrawal and End the Divorce Action relative to the above-captioned docket number.
NOW THEREFORE, in consideration of the mutual covenants, promises and agreements
as hereinafter set forth, the parties agree that the above-captioned divorce action shall be
withdrawn without prejudice.
WHEREFORE, agreeing to be legally bound, the parties and witnesses thereto, do hereby
affix their respective signatures.
Herford
Edward E. Herford
a
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