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Home My WebLink About08-4987ft D HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF CHRISTOPHER R. SHULTZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2008 - Y1 CIVIL TERM KRISTIN L. SHULTZ, Defendant : 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 in 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 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, 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 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, Pennsylvania 17013 717-249-3166 CHRISTOPHER R. SHULTZ, Plaintiff V. KRISTIN L. SHULTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: The plaintiff is CHRISTOPHER R. SHULTZ, an adult individual residing with the military in Fayetteville, North Carolina, but whose permanent residence address is 378 Creek Road, Shermansdale, Perry County, Pennsylvania 17090. 2. The defendant is KRISTIN L. SHULTZ, an adult individual residing at 621 Willow Grove Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on August 13, 2005, in Carlisle, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. August /r , 2008 CHRISTOPHER It SHUM, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 CHRISTOPHER R. SHULTZ, Plaintiff V. KRISTIN L. SHULTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly swom according to law, deposes and says: 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. 1 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. August 2008 CHRIS PHER R. SHULTZ aintiff C"? c_- cm G7 FTI r n 1 i -cf W p A ?`I CHRISTOPHER R. SHULTZ, Plaintiff v. KRISTIN L. SHULTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - 4987 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, KRISTIN L. SHULTZ, defendant in this matter, hereby certify that I accepted service of a copy of the complaint in this divorce on or about August 22, 2008. I verify that the statements made in this acceptance of service 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. September 11 , 2008 G ??T: Z ?? ? _ ?.. ?._ -cr ??. ? :--- =? -"' ....- CHRISTOPHER R. SHULTZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2008 - 4987CIVIL TERM KRISTIN L. SHULTZ, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 19, 2008. Service of the complaint was made upon defendant on August 22, 2008, as indicated on the affidavit of service filed on September 15, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. November o?6, 2008 4 HRIS OPHER R. SHULT WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. 1 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 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. November a6, 2008 CHRIS OPHER R. SHULf;f 1 ? ., __. ...i ' ? CHRISTOPHER R. SHULTZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2008 - 4987 CIVIL TERM KRISTIN L. SHULTZ, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 2. 3 A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 19, 2008. Set vice- of t~e complaint was made upon defendant or August 22, 200£, as indicated on the affidavit of service filed on September 15, 2008. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. I consent to the entry of a final decree in divorce entry of the divorce. / November _2v2008 of notice of intention to request L. SHUL WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. 1 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 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. November A\$ 2008 ^, t??a ,,:? > . _ ?..? r°-•r ? . ??f c ;.._ z 'i HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF CHRISTOPHER R. SHULTZ, Plaintiff V. KRISTIN L. SHULTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 -4987 CIVIL TERM : 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: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about August 22, 2008 defendant was served with a copy of the divorce complaint (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: November 26, 2008 By the defendant: November 30, 2008 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 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: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: December 1, 2008 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: December 1, 2008 6. There has been no prior action for divorce or annulment between the parties other than this action which commenced on August 19, 2008. December l , 2008 HAROLD S. IRWIN, 111 Attorney for Plaintiff w CHRISTOPHER R. SHULTZ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. KRISTIN L. SHULTZ No. 2008 - 4987 CIVIL TERM DIVORCE DECREE AND NOW, it is ordered and decreed that CHRISTOPHER R. SHULTZ , plaintiff, and KRISTIN L. SHULTZ , 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, Attest: J. ? '?940"?z /rothonotary el AV ?, , , IL