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Home My WebLink About08-6750 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. BRIAN S. SCHREINER, CIVIL ACTION -LAW 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 2 LIBERTY AVENUE 4 Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. D P G 7 So BRIAN S. SCHREINER, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Heather L. Schreiner, an adult individual residing at 1005 Chelmsford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Brian S. Schreiner, an adult individual residing at 480 Big Spring Road, New Cumberland, York County, Pennsylvania 17070. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on September 4, 2004 in Enola, Cumberland County, Pennsylvania. 5. There is one (1) minor child born of this marriage, being Reyna Lynn Schreiner (born February 21, 2006). 6. The parties separated on December 15, 2006. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 (c) and §3301(d) of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Heather L. Schreiner, prays this Honorable Court to enter judgment awarding Plaintiff a decree in divorce. Dated: November 7, 2008 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 2 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. D e 4,'7_;_6 Cu; -7;:, BRIAN S. SCHREINER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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 Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that 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.A Section 4904 relating to unsworn falsification to authorities. Dated: 2008 E THER L. SC ER ID& Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER, Defendant NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, HEATHER L. SCHREINER, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: , 2008 bAAA- &k? HER L. Sc R 04 V oo ? ? ? `? CID Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-6750 BRIAN S. SCHREINER, Defendant CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint in Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7008 0150 0002 5289 7507, Return Receipt Requested, on Mr. Brian S. Schreiner, on November 21, 2008 at his last known address: 480 Big Spring Road, New Cumberland, Pennsylvania 17070. The original receipt and return receipt card are attached hereto as Exhibit "A" I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false st tements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn si figatirap to authorities. Dated: December 2, 2008 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff a GERTIFIED M AIL, RE CEIPT C3 (Domestic Mail Only; No Insurance Coverage Provided) Ln . , Q- €11tIRliO FUJU CD Postage $ $2.02 0 nj r certified Fee $2.70 u O t7 Return Receipt Fee (Endorsement Required) $2.20 y C3 f ') Restricted Delivery Fee (Endorsement Required) X4"0 _ V. -A l • o Total Postage $ Fees $ =U1 \? ? ?JA .. M f3? I S• S?VI . I' t t CU1J1 O 3Yreet,CNo:; . r or PO Box No. 0 [?j l .y S P( City l ..............•------• ....... ...., State, P+4 --------------------------- ZI \jo Cu "oA ti. Fedt ._T j 17 0 7? ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted DWK*q is desired, ¦ Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: ?Z r3 rtay) S. Sc-h r?-i uj) 4M 3Lr SPf'rj 0-. Nel,j RESTRICTED 1-1010 e_ _ ? Agent Tived by,(Printed lame) C. of I 'ID I M & D. Is delivery address ditent from item 1 Yes ff YES, enter delivery address below: ? No 3. Service Type IRCeffled Mail ? Egress Mail ? Registered ? Return Receipt for Meroharxiiin ? Insured Mail ? C.O.D. 2. Article Number 7008 0150 0002 5289 7507 mamfer from servks label) P8 Form 3811. February 2004 n m s tic I1hPk rn Nsceipt 102e11154W t,. W EXHIBIT "A" C g NO z ?r (1d r.? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER, Defendant : NO. 08-6750 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 13, 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. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: JF' o?O q D? ?, J- 640 X llmzyL? E THER L. ?fftENER ?- ?i 4j ?, t ?` ' _ E '?? ?? !'+ ??i.. s .. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff V. BRIAN S. SCHREINER, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6750 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: 5 c dq HE THER L. kItIfEINER i t?.?'...? ,..'? ; ?? LF '. .o ..., ? i- f 1-# ?t Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, : IN THE COURT OF COMMON PLEAS Plaintiff V. BRIAN S. SCHREINER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6750 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 13, 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. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: Z? - B . SCHREINER J COMMONWEALTH OF PENNSYLVANIA) C-WL66T Vim' ?d ) SS. COUNTY OF Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Brian S. Schreiner, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing AFFIDAVIT OF CONSENT are true and correct to the best of his knowledge, information and belief. Affirmed and subscribed to before me this0 day o 2009. -A f-A P Il+ NOT RY PUBLIC My commission expires:'` d (SEAL) MOOR" Moray h" Mr eww"M bpbw Mat 30. wo 2 fF-?Y ? 1 ? Y ?i n r` owo-- i Mme" clog T- s Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER, Defendant : NO. 08-6750 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: BRLkR S. SCHREINER P, '' COMMONWEALTH OF PENNSYLVANIA) e) SS. COUNTY OF Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Brian S. Schreiner, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE are true and correct to the best of his knowledge, information and belief. Affirmed and subscribed to before me this of day of , 2009. NOT Y PUBLIC NoWWIt 16At Nord? ? My commission expires: 3I W )aM (SEAL) t=wt0 D0N AVft WAMC0UW Mj? ConMnMNon wa MW 30.2010 2 AIL !A? J?IMWOM YIAMi?OH ! AwOMi NadN woom YIOIMI?JIW?MlM?YI Of1n .09 IOTA n+icjA nab* mo* VM . Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN S. SCHREINER, Defendant NO. 08-6750 CIVIL ACTION -LAW 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail Restricted Delivery on November 21, 2008. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff May 20, 2009; by Defendant May 28, 2009. 4. Related claims pending: NONE. 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with Prothonotary: June 3, 2009. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with Prothonotary: June 3, 2009. ,,---? Dated: June 2, 2009 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff w • Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Counsel for Petitioner HEATHER L. SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-6750 BRIAN S. SCHREINER, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Mr. Brian S. Schreiner 480 Big Spring Road New Cumberland, PA 17( DATED: June 2, 2009 r3mu a awnpie-3uinvan, nsqulre 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff 2 -ii r;.. ?r.?;, ? r? ? , . t., v?'.; . ?? ?.., , . ' ?.? ? ? J 3 :. i n? ?. 4.' i,.. .. ... _ . ' +,. .. HEATHER L. SCHREINER, V. BRIAN S. SCHREINER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 6750 DIVORCE DECREE AND NOW, '? wV'` mo` , it is ordered and decreed that HEATHER L. SCHREINER, , plaintiff, and BRIAN S. SCHREINER, , 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. the Court, r Attest: J. Prothonotary dl? cz?? ?, - II