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Home My WebLink About08-6035- A% Stephanie A. Shambaugh Plaintiff V. Robert L. Shambaugh, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- (oo35 CIVEL TERM 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 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, 1 Courthouse Square, Carlisle, Pennsylvania. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 V ? a. Stephanie A. Shambaugh Plaintiff V. Robert L. Shambaugh, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- G D 3? CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ctillWl?t A .Shorn I , who currently resides at lent 1j Cumberland County, Pennsylvania. 2. Defendant is RkCrt L • %dP*d Ir. , who currently resides at IloS VYcrfzyillc Rood Carl& Pk 17013 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on T11 1 ?i !! Qq q at n i. 1 f]¦ 5. The marriage is irretrievably broken, and the parties separated on (fu IV zz"d . X008 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. F '. !? ?l + y f `1 r ? ? ? ? ? ? 1, h114 1 f t ? ? M * ' , - .. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 1-a6-09 Date Plaintiff, Pro Se I, , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. qr Date: Plaintiff, Pro Se Assisted by: Michael A. Hynum, Esq. Hynum Law Office 2608 North 3rd St. .Harrisburg, PA 17110 (717) 774-1357 ,l i S ? s r ' ` C? '??"? J Fl-, Stephanie A. Shambaugh Plaintiff V. Robert L. Shambaugh, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- (Po35 CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Stephanie A. Shambaugh, Plaintiff, to proceed in forma 12ggoris. I, Michael A. Hynum, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Michael A. Hynutn, `Esq ire Attorney for Plaintiff Hvnum Law Office 2608 North 3rd St. 11arrisburg, PA 17110 (717) 774-1357 cD co ? S?T1 ?y Stephanie A. Shambaugh IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- W 3 Lr CIVIL TERM Robert L. Shambaugh, Jr. Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, _ Robert L. Shambaugh Jr. (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. / 08 ` Date Robert L. Zbaugh ,Defendant `J C") Yq k , Stephanie A. Shambaugh Plaintiff V. Robert L. Shambaugh, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 6035 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on October 17,2008 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 to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. 0? /J Date: 4" -5-N, 0 1 Signature: .? ..pk. ?C`. Robert L. Shamba , Jr., Defendant I Stephanie A. Shambaugh IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08- 6035 CIVIL TERM Robert L. Shambaugh, Jr. Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on October 1 7, 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 to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. Date: 4° ??? ° 9 Signature--?ZJ Z JLL-1-1- Robert L. Shamba , Jr., Defendant r-3 ?s n C it Stephanie A. Shambaugh Plaintiff V. Robert L. Shambaugh, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08- 6 0 3 5 CIVIL TERM 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 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. Date: Signature<J „ Robert L. Shamba h, Jr., Defendant ?? ? ? -.? ; :.g .., ,_, y+ :? ? ,?- c? -.? Stephanie A. Shambaugh, Plaintiff V. Robert L. Shambaugh, Jr., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6035 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 3301(c) of the Divorce Code was filed on October 17, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of the Complaint. 3. 1 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 contained herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: %4&am- - tephan A. Sham augh S9", ?7 _? _ ?^w ".'4? ?. ? ." Stephanie A. Shambaugh, Plaintiff V. Robert L. Shambaugh, Jr., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6035 CIVIL ACTION - LAW IN DIVORCE 1. I consent to the entry of a final Decree of Divorce without any 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 contained herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: -? adaKL - Stephani A. Sham augh -; -- `?- c__ ? . '•'! r- _-? r it ._ -.:.! '? ?.?. ..,...._ : i ir'i . _ :_,. ,?,sr ?? ?? Vii. yy ..??.y1 •"+w.. Stephanie A. Shambaugh, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-6035 Robert L. Shambaugh, Jr., CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court or entry of a divorce decree: Ground for divorce: irretrievable breakdown under §3301(c) of the divorce code. 2. Date and manner of service of the complaint: October 8, 2008, served by regular mail, on or about October 17, 2008, acceptance of service signed by Defendant on October 17, 2008 and filed on October 27, 2008. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff: 1/17/09 by Defendant: 1/20/09 4. Date Plaintiffs Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: January 27, 2009. Date Defendant's Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: January 27, 2009. t , Date: February 2, 2009 Michael A. Hynun),'Es Attorney ID No. 8569'9 HYNUM LAW 2608 North 3rd Street Harrisburg, PA 17110 Attorney for Plaintiff -r %wo -n a C' Q C Stephanie A. Shambaugh V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robert L. Shambaugh, Jr. NO. 08-6035 DIVORCE DECREE AND NOW, ,.._.11 Z 6 fl -, it is ordered and decreed that Stephanie A. Shambaugh , plaintiff, and Robert L. Shambaugh, Jr. , 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, ?o•-,