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Home My WebLink About09-2843JENNY L. SPORAY, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE GEORGE F. SPORAY, Defendant :NO. Oq- caag3 C?v11 ?"ie 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 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: Office of the Prothonotary Cumberland County Court House I Courthouse Square 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 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 (800) 990-9108 lob JENNY L. SPORAY, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE GEORGE F. SPORAY, Defendant :NO. 0 5- At 13 a_?;a COMPLAINT AND NOW comes the Plaintiff, Jenny L. Sporay, who, by and through her attorneys, Elizabeth S. Beckley, Esquire, Charles O. Beckley, II, and Beckley & Madden, of Counsel, files this Complaint, in which she avers that: 1. Plaintiff, Jenny L. Sporat, is an adult individual residing at 1712 Lincoln Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, George F. Sporay, is an adult individual with a mailing address of P.O. Box 99, Windber, Somerset County, Pennsylvania 15963. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on June 2, 2001 and separated on April 13, 2007. 5. There was a previous action for divorce filed in Cameron County at Docket No. 2007 - 2417 which has been discontinued without prejudice. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. §§3301(c) or (d), Plaintiff, Jenny L. Sporay, respectfully requests the Court to enter a Decree of Divorce. COUNT II EQUITABLE DISTRIBUTION UNDER SECTION 3502 OF THE DIVORCE CODE 11. The averments contained in Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as though set forth in full. 12. Plaintiff and Defendant have acquired property, both real and personal, during the marriage which constitutes marital property subject to equitable distribution under the Divorce Code. 13. Plaintiff and Defendant each owned, prior to the marriage, both real and personal property which has increased in value during the marriage, and/or which has been exchanged for other property which has increased in value during the marriage, all of which property is marital property, subject to equitable distribution under the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. 2 J WHEREFORE, pursuant to 23 Pa.C.S.A. §3502, Plaintiff, Jenny L. Sporay, respectfully requests the Court to divide all marital property equitably between the parties. DATED: 5 (p of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 Respectfully submitted, f 3 harles O. Beckley, I 05/06/2009 12:18 5703235820 MANORCARE NORTH PAGE 02/02 VERMCATION Jdmy L. Spomy,: hdIaby verify *9 the statemeats madc in the faregoin8 doa ment are true and correct to the best of my knowledge, Wrmation and belief. I uadcrstamd that false statements herein are made subject to the penalties 18 Pa. C_ S. Section 4904, relad g to unworn falsification to authorities. DATED: 5?4?pq J L. S 1"1?ICE OF T PROTHONOTARY 2009 MAY -7 AM 8.22 CUM&`.r Li iD C:'-", .INTY PEWYLVAN1A * 3(0+. so pa A't'rY c x* 131o4 RTC ami ll(o add"' et _1 IL JENNY L. SPORAY, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE GEORGE F. SPORAY, Defendant :NO. 09-02843 AFFIDAVIT OF SERVICE I, Elizabeth S. Beckley, being duly sworn according to law, do depose and say: 1. I am an adult individual over eighteen years of age. 2. I served the Divorce Complaint of Jenny L. Sporay upon George F. Sporay, at P.O. Box 99, Windber, PA 15963, on or about May 11, 2009, by certified mail, parcel number 7007 0220 0001 4376 5839, return receipt requested. Attached hereto is the return receipt (areen card) signed by the Defendant. Sworn and subscribed to before me this 14 day of , 2009. AN otary Public (SEAL) =SCRBAACIO, ONWEALTH OF PENNSYLVANIA SEAL IC, Notary Public luphln County s Nov. 20, 2010 ¦ Complete items 1. 2, and 3. Also complete Item 4 If Restricted Delivery 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 mailPiscs, or on the front If space permits. 1. Article Addressed to: 6?dRge F SI(VoROJ 1?IA?.D$?R CA 1? 9?3 -r 2. Article Number (fwww from swvlce bw _ P3 Form 3811, Febnwy 2004 ? ? A. S AOI ? do PeWd B. Rt C. ? e o1,De D= J Item iT ? a? `_ ? No .e RY 104 9. Service Type CsCwtllled Mail ? EWM Mall ? Repiatered ? Return Receipt for Merchandise ? insured Mail ? C.O.D. 4. RMegipMd Df*Very? (1D*BFSW 7007 0220 0001 4376 5839 102506-024A-1640 AW FILED-C'ICE OF ThE- 2004 JU 16 r"ail ! ! : 0 c ?.y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNY L. SPORAY, PLAINTIFF VS. No. 2009 GN 2843 GEORGE SPORAY, DIVORCE DEFENDANT ENTRY OF APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of the DEFENDANT in the above action. Jqffin F. Peters, Jr., 1 1 Eleventh Ave t ona, PA 16601 ( 4)941-1116 PA ID # 50065 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNY L. SPORAY, PLAINTIFF VS. No. 2009 GN 2843 GEORGE SPORAY, DIVORCE DEFENDANT 1?(CERTIFICATE of SERVICE On this I Iday of June, 2009, I, John C. Peters, Jr., Esquire, hereby certify that I sent a true and correct copy of the foregoing ENTRY OF APPEARANCE via US Mail, postage prepaid, to: Elizabeth S. Beckley, Esquire P.O. Box 11998 Harrisburg, PA 17108 Jo . Peters, Jr., Esqui 12 1 th Avenue Al a, PA 16601 (8 ) 941-1116 PA ID # 50065 2009 JLIH 19 PM 12 ' l ??Jitif`t `"f4,r