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HomeMy WebLinkAbout08-5932Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Todd R. Shumaker, NO. 08 - 5g5A O'Ni I erm Defendant 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 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, 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 Y 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Todd R. Shumaker, NO. Defendant IN DIVORCE COMPLAINT AND NOW COMES the above-named Plaintiff, by her attorney, Susan J. Hartman, Esquire, and makes the following Complaint in Divorce: 1. Plaintiff, Tammy M. Shumaker, is an adult individual currently residing at 23 E. Main Street, Plainfield, Cumberland County, Pennsylvania.. 2. Defendant, Todd R. Shumaker, is an adult individual currently residing at 2472 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 19, 1984 at Carlisle, Cumberland County, Pennsylvania.. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divorce Code, the marriage between the parties 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. Defendant herein is not a member of the armed forces of the United States of America. WHEREFORE, Plaintiff prays this Honorable Court enter a decree dissolving the marriage between the parties. Respectfully Submitted, usan J. H squire Attorney for PI ntiff Duncan & Hartman, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904, relating to unsworn falsification to authorities. Date: 0 Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Todd R. Shumaker, NO. Defendant : IN DIVORCE AFFIDAVIT Tammy M. Shumaker, Plaintiff, 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 my spouse and I participate in counseling. 2. 1 understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (J$1DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 4. I realize that if the divorce is brought under section 3301(c) of the Divorce Code, then counseling must be completed within ninety days after the filing of the complaint. If the divorce is brought under section 3301(d) of the Divorce Code, then counseling must be completed within one hundred and twenty days after the filing of the complaint. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.4904 relating to unworn falsification to authorities. Tammy humaker Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Todd R. Shumaker, NO. Defendant : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with section 3301(c) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that from the list. All arrangements and you and you are not bound to choose a counselor the cost off counseling sessions are to be born by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. P C- rv <=5 c --? F7n YY tl 4 w ? ? 0 Cz CO CA 'p V, Cil D n SHERIFF'S RETURN - REGULAR CASE NO: 2008-05932 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHUMAKER TAMMY M VS SHUMAKER TODD R MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE SHUMAKER TODD R DEFENDANT was served upon the , at 0021:00 HOURS, on the 13th day of October , 2008 at 2472 RITNER HIGHWAY CARLISLE, PA 17015 by handing to TODD SHUMAKER DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.00 Affidavit .00 Surcharge 10.00 Postage 42 10116104- 34.42 Sworn and Subscibed to before me this day So Answer ;ry R. Thomas Kline 10/14/2008 DUNCAN & HARTMAN By. Deputy Sheriff of A. D. Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Todd R.. Shumaker, NO. 08-5932 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301c) of the Divorce Code was filed on October 3, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. . 4. 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. 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. sec. 49904 relating to unsworn falsification to authorities. Date: l Z6 r G 1 s Todd R. Shumaker r' ._ ,? ? ..,? c ? ? ?.. ?;? ?;-' ?.? r _ ? ? ?3 << 5. -? t ?? . ? , Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW Todd R. Shumaker, NO. 08-5932 Civil Term Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 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. 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. sec. 49904 relating to unsworn falsification to authorities. Date: Todd R. Shumaker t-0 C : r; .. co Gil L1.- y "'7 LJ C `.F Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Todd R.. Shumaker, NO. 08-5932 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301c) of the Divorce Code was filed on October 3, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. sec. 49904 relating to unsworn falsification to authorities. Date: Ca In cy, 'A&ammy .. Shumaker 'i f `? _ T { CS't Tammy M. Shumaker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Todd R. Shumaker, NO. 08-5932 Civil Term Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 C) OF THE DIVORCE CODE 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. 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. sec. 49904 relating to unsworn falsification to authorities. Date: X0 a,,, ammy M umaker A? i -- l J - CO '?; i a 1 Tammy M. Shumaker, Plaintiff V. Todd R.. Shumaker, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 08-5932 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 the service of the complaint: Service by Sheriff on October 13, 2008. 3. (1) Date of execution of the affidavit of consent required by Section 3301 ( c ) of the Divorce Code: by plaintiff January 26, 2009 by defendant January 20, 2009. 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice in 3301 ( c) Divorce was filed with the Prothonotary: January 28, 2009. 6. Date Defendants Waiver of Notice in 3301 ( c ) Divorce was filed with the Prothonotary: January 28, 2009. Susan J. Hartsquire Attorney for Pl ' tiff ra c-?,. ...? .--? t c,.,. ?? -rs :,-,. _ .?:- ?? } } t }? ::5, -. - " .. ? t _ ? ?? `i?='i ' ? `, "? ?1 Z'? '? TAMMY M. SHUMAKER V. TODD R. SHUMAKER DIVORCE DECREE AND NOW, it is ordered and decreed that TAMMY M. SHUMAKER , plaintiff, and TODD R. SHUMAKER , 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, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5932 -I*k I "? Attest: J. Prothonotary ? ??? ??,?._ ?w???'? .. '?; ,e???,? f ... ??? ?4 ? ? ? ? ?'. ?- ?'