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HomeMy WebLinkAbout08-5140, -N' RUTH ANN SHARP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. OS • S•!yd CIVIL TERM CIVIL ACTION -LAW IRA JOHN SHARP, Defendant IN DIVORCE N O T I C E 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 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. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 LAW OFFICES SNELBAKER & BRENNEMAN. P.C. SNELBA R & BRENNEMAN, P.C. r By: is C. Snelbaker Attorney for Plaintiff RUTH ANN SHARP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08 - VA16 CIVIL TERM CIVIL ACTION -LAW IRA JOHN SHARP, Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff RUTH ANN SHARP is an adult individual residing at 14 Pleasant View Drive, Silver Spring Township, Cumberland County, Pennsylvania (Post Office: Mechanicsburg, PA 17050). 2. Defendant IRA JOHN SHARP is an adult individual residing at 11 Raspberry Drive, Silver Spring Township, Cumberland County, Pennsylvania (Post Office: Mechanicsburg, PA 17050). 3.. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The parties were lawfully joined in marriage on September 26, 1980, in Fort Walton Beach, Florida. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage as averred in paragraph 4 above. LAW'S I I 6. Neither party is a member of the armed forces of the United States of America. SNELBAKER a BRENNEMAN. P.C. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the Court to require the parties to participate in counseling. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce divorcing Plaintiff and Defendant from the bonds of matrimony and to order such other relief as the Court deems just and reasonable. SNELBAKER & BRENNEMAN, P.C. By: 14LZ loe Richard C. Snelbaker, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Date: August 26 , 2008 -2- LAW OFFICES SNELBAKER & BRENNEMAN, P.C. L VERIFICATION I verify that the statements made in the foregoing Complaint 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 falsification to authorities. uth Ann Sharp Date: August 26 2008 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. RUTH ANN SHARP, COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL TERM CIVIL ACTION -LAW IRA JOHN SHARP, Defendant IN DIVORCE AFFIDAVIT RUTH ANN SHARP, being duly sworn according to law, deposes and says: 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 Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require 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. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. § 4904 relating to unsworn falsification to authorities. I L - th%AF1%A '?? I r\ __72 V) uth Ann Sharp (Plaintiff) Date: August 26,2008 tie IJ f?.. W N 4?1 l t„ 1 cry ?7 V f'n t .) -jj RUTH ANN SHARP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. Off'" 5'IL1 6 CIVIL TERM CIVIL ACTION -LAW IRA JOHN SHARP, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, IRA JOHN SHARP, Defendant in the above captioned action, hereby accept service of Complaint in Divorce and acknowledge receipt of a certified copy thereof. Date: 2008 Ir J harp (Defendant) LAW OFFICES SNELBAKER & BRENNEMAN, P.C. > - ca co q `13 IT! C-4) m .. cr% ? C co RUTH ANN SHARP, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION -LAW vs. NO: 08-5140 CIVIL TERM IRA JOHN SHARP, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 26, 2008. 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 this 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 falsification to authorities. Ruth Ann Sharp (Plaintiff) Date: 2 (o 32009 LAW 0MCES SNELBAKER & BRENNEMAN, P.C. RUTH ANN SHARP, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION -LAW vs. :NO: 08-5140 CIVIL TERM IRA JOHN SHARP, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 26, 2008. 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 this 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 falsification to authorities. rp ra 4enant) (Date: March 24, 2009 LAW OFFICES SNELBAKER 8( BRENNEMAN, P.C. P`J (,:) .c? H ANN SHARP, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION - LAW VS. NO: 08-5140 CIVIL TERM JOHN SHARP, IN DIVORCE Defendant PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33010 OF THE DIVORCE CODE 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, 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. 4. I verify that the statements made in this affidavit are true and correct. I LAW OFFICES SNELBAKER & BRENNEMAN, P.C. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: At-,,A 26 , 2009 n uth Ann Sharp (Plaintiff) fJ ?? ?i ? • " " : ? 1 t ? r,'ri . ?..-- ? .e??? fly, ?? ?? ? ' -??J . f tti? tom-.- 4?` ' F{^j RUTH ANN SHARP, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION -LAW VS. NO: 08-5140 CIVIL TERM IRA JOHN SHARP, IN DIVORCE Defendant DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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. 4. 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. § 4904 relating to unworn falsification to authorities. Date: March 24, 2009 I J hn Sharp ( efendant) LAW OFFICES SNEL13AKER & BRENNEMAN, P.C. C? ? C? 5c -n cy Z sue.-1_. _?.;`;•n? r* ?' a ANN SHARP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-5140 CIVIL TERM JOHN SHARP, Defendant CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD PTO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of Complaint: on Defendant by Acceptance of Service September 16, 2008. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the ivorce Code: by the Plaintiff: March 26, 2009; by the Defendant: March 24, 2009. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: 26, 2009; by the Defendant: March 24, 2009. 5. Related pending claims: None. SNELBAKER & BRENNEMAN, P. C. March AC. , 2009 By: Attorneys for Plaintiff LAW OFFICES SNELBAKER & BRENNEMAN, P.C. IX3 CFI rte' C71 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTH ANN SHARP V. IRA JOHN SHARP NO 08-5140 DIVORCE DECREE AND NOW, .,r % / 2ao 9 , it is ordered and decreed that RUTH ANN SHARP plaintiff, and , IRA JOHN SHARP , 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, . Z57,wl'l Prothonotary oq t oq L 1 •. ' ? !'stir a