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Home My WebLink About08-3363STACY J. MARSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 33&3 ANDREW J. MARSHALL, Defendant IN DIVORCE NOTICE TO DEFEND 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY SAIDIS, FLOWER LINDSAY 26 West High Street Carlisle, PA Mar o atas, Eire Attorne d. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff STACY J. MARSHALL, Plaintiff v ANDREW J. MARSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. OF - 336 3 Ceu, P 7., IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Stacy J. Marshall, an adult individual residing at 801 North College Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Andrew J. Marshall, an adult individual residing at 541 North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 6, 2005 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in SAMIS, FLOWER & LINDSAY ?nomvetis.,?ruw 26 West High Street Carlisle, PA counseling. 7. The parties' marriage is irretrievably broken. 8. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 9. Plaintiff and Defendant are citizens of the United States of America. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 (c) or (d) of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY tas, Esquire Mary o'LtM Attorney ID #84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: Counsel for Plaintiff SAIDIS, FLOWER & LP-MSAY AMFNM?AMAW 26 West High Street Carlisle, PA 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. §4904, relating to unsworn falsifications to authorities. Stacy J. Mar all Date: 503 W SAIDIS, FLOWER & LP4DS" ?:uW 26 West High Street Carlisle, PA 1? ?J -77 STACY J. MARSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYVANIA V. CIVIL ACTION - LAW : NO. ANDREW J. MARSHALL, Defendant : IN DIVORCE 33( ACCEPTANCE OF SERVICE FLOWER ? LINDSAY MrAT, 26 West High Street Carlisle, PA I, Robert J. Dailey, Esquire, attorney for the Defendant, Andrew J. Marshall, accept service of the Divorce Complaint in the aboyp-captioned matjer:'"? ('& acne Date JUN 1 2 2008 STACY J. MARSHALL, IN THE COURT OF COMMO CLEAM Plaintiff CUMBERLAND COUNTY, P YIMANW V. CIVIL ACTION - LAW "x NO. , 17 ANDREW J. MARSHALL, Defendant IN DIVORCE W N tD PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed May 30, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit 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 falsification to authorities. Date: ' - o 5:z? STACY J. M HALL PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAMIS, FLOWER & LINDSAY ATMENEVS AT uw 26 West High Street Carlisle, PA 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 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 falsification to authorities. Date: I I C-) STACY J. MA STACY J. MARSHALL, Plaintiff V. ANDREW J. MARSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Pg;4N,(gLVANIA J CIVIL ACTION - LAW m NO. a -, r- q IN DIVORCE ?' C_ r- v DEFENDANT'S AFFIDAVIT OF CONSENT CID A Complaint in Divorce under § 3301(c) of the Divorce Code was filed May 30, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. i consent io the entry of a rinai Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit 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 falsification to authorities. Date: 4??-z ANDREW X. MA HALL DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. SAMIS, FLOWER & LEVDSAY ATICIVEWS-AMAW 26 West High Street Carlisle, PA 2. 1 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. 1 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 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 falsification to authorities. Date: a/j ?! 1 y DRE MA HA STACY J. MARSHALL, IN THE COURT OF %E)€S .--- Plaintiff CUMBERLAND COUNTY, P? SYLVAMA ; M V. CIVIL ACTION - LAW NO. 2008-3363 - r ANDREW J. MARSHALL, Defendant IN DIVORCE _ ?- PRAECIPE TO TRANSMIT RECORD ' CC) -c To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on June 6, 2008, via certified mail. Proof of service was filed with the Court on June 13, 2008 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: On January 30, 2010 and filed with the Prothonotary on February 4, 2010. By Defendant: On February 12, 2010 and filed with the Prothonotary on February 18, 2010. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: On January 30, 2010 and filed with the Prothonotary on February 4, 2010. By Defendant: On February 12, 2010 and filed with the Prothonotary on February 18, 2010. SAIDIS, FWAVER & LINDSAY nno?tsauw 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Maryl at , Esquire - Supreme CoUr-t ID No. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF STAGY J. MARSHALL : CUMBERLAND COUNTY, PENNSYLVANIA V. ANDREW J. MARSHALL No. 2008-3363 DIVORCE DECREE AND NOW, a C4 3"" , z0 io , it is ordered and decreed that STACY J. MARSHALL , plaintiff, and ANDREW J. MARSHALL , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, -5,. /e, 6"4- ?elAy, X4"dw a,?r- -ze) cx,-r, m:40, ,- 4 XI-4