The URL can be used to link to this page

Home My WebLink About09-1786f` AP' KATHLEEN A. McGRATH, Plaintiff V. SAMUEL H. STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01 S1 CIVIL ACTION - LAW IN DIVORCE 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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, PA 17013 (717) 249-3166 or (800) 990-9108 .w AoM & UTULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KATHLEEN A. McGRATH, Plaintiff V. SAMUEL H. STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. AAI'11?? CIVIL ACTION - LAW IN DIVORCE 1. Plaintiff is Kathleen A. McGrath, who currently resides at 221 Carmack Drive, Chambersburg, Franklin County, Pennsylvania. 2. Defendant is Samuel H. Stambaugh, who currently resides at 145 Highland Road, Chambersburg, Franklin County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 5, 1994, in Chambersburg, Franklin County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. There was an initial Divorce Complaint filed May 2002 in Franklin County, docket number 2002-1462. However, the Complaint for Divorce was discontinued by Franklin County in 2005 for lack of action. 7. Divorce is sought pursuant to the provisions of the Divorce Code, ?§ 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. 8. Plaintiff and Defendant have lived separate and apart since August 1, 2004, and continue to do so. 9. 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 such counseling. 10. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, DATE _ 31 mq ABom&KUTUTAKi4 L.L.P. k Michelle L. Sommer, quire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintff I, KATHLEEN A. McGRATH, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. 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 G KATHLEEN A. McGRATH MAR 1 5 1001 ?L-Ju_u_L--3tJ J J ILr ? 0 0 1b ? o N ? -n ':r T'll CIA O -< ?? OM & KUTULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KATHLEEN A. McGRATH, Plaintiff V. SAMUEL H. STAMBAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09-1786 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) and (d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on Samuel Stambaugh, at Carlisle, Pennsylvania, addressed as follows: Samuel H. Stambaugh 145 Highland Road Chambersburg, PA 17202 Return card acknowledging receipt on March 24, 2009 is attached as Exhibit "A". Date: * 5 v 1 ABom & KoTVLAKr,% LLP Michelle L. Somme squire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 93034 4. ¦ CompNts Ferns 1, 2, and 3. Also oomplaim item 4 If F iC6ed Dslkwy Is deeksd. ¦ Print your name mW addrem on the reverse so that we can mtum the cad to you. ¦ Attach ** card to the back of the mailpiece, or on tlont if apace permits. 1. Article Addressed to: Rol" 170-0 a' A. Sipe n - X O Agent 0 Addressee B. sceived Prlrr A#o, C. Dst$of Qih'L _ S t2- D. Is debery address da«erit Imm Poem 1? Yea If YES, enter delivery address below: 0 No 3. Service Type jZ wd W Mom O Bpross Midi 0 Registered 0 Return Rscaipt for Mwthandise 0 insured Mall Cl C.O.D. 4. Restricted Dervery? Pft Fee) -?olbs 2. Article Nufftw Syr 7005 2570 0000 3804 3552 P$ Form 381 T February 2004 Domaatlc Return Receipt 102595.024A-1540 EXHIBIT `A" ?, l . 1 _.. _. ?7 ?C ? 1 ??:. L1" / TMh t 4w M1 L' f?.... ?1 ? 'j ? / E . ? ? +?? 4A " Kathleen A. McGrath IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Samuel H. Stambaugh NO. 09-1786 DIVORCE DECREE AND NOW, ~1 ov ~ ~ , it is ordered and decreed that Kathleen A. McGrath Samuel H. Stambaugh bonds of matrimony. plaintiff, and defendant, are divorced from the 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. Prot onotary By the Court,