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HomeMy WebLinkAbout09-3891LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Sandra Lynn Shamansky SANDRA LYNN SHAMANSKY Plaintiff vs. JOSEPH P. SHAMANSKY Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . No. Q 9 3 9-9 / c N' l `-f a-^ : CIVIL ACTION -LAW : 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's at: Cumberland County Courthouse, 1 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Sandra Lynn Shamansky SANDRA LYNN SHAMANSKY Plaintiff VS. JOSEPH P. SHAMANSKY Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. p CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is Sandra Lynn Shamansky, an adult individual who currently resides at764 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011 and whose social security number is 201-50-0279. 2. The Defendant is Joseph P. Shamansky, an adult individual, whose has a last known mailing address of P. O. Box 184, Elmer, Louisiana 71424 and whose social security number is 191-46-3000. 3. Plaintiff and Defendant were married on December 22, 1984 in Camp Hill, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. There are no minor children born of the marriage. 9. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 10. Plaintiff avers that the grounds on which this action is based are as follows: (a.) That the parties have lived separate and apart for a period of at least two years, said date of separation being September of 1998, and (b.) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, 4iane M. Dils, Esquire 1400 North Second Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: June 11, 2009 ' r VERIFICATION I verify that the statements made in this Complaint in Divorce 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 farsification to authorities. SANDRA LYNN SHAMANSKY Date: June 11. 2009 =; FLED-a !u OF THE P- "0T+ 2969 JUNI 12 All 1: 4 2 C° }k a .r?Y'... X331- SU ado-, ?fG# ? i- S? Alit d x66 Z-A SANDRA LYNN SHAMANSKY, Plaintiff VS. JOSEPH P. SHAMANSKY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2009 -30/ Civil Term CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served upon you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on September of 1998, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. Section 4904 relating to unsworn falsification to authorities. Date: RLED-OWI OF THE PROTH)NIOTARY: 2099 JUN 12 AM 9: 4 2 .?t S 1 culkF p i i s t?A LAW OFFICES OF DILS &DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 233-8743 Attorney for Plaintiff, Sandra Lynn Shamansky SANDRA LYNN SHAMANSKY, Plaintiff vs. JOSEPH P. SHAMANSKY, Defendant TO THE PROTHONOTARY: 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-3891 CIVIL ACTION -LAW IN DIVORCE PRAECIPE Please reinstate the Complaint in Divorce Under Section 3301(d) of the Divorce Code and the Affidavit of Plaintiff Under Section 3301(d) of the Divorce Code for service upon the Defendant, Joseph P. Shamansky oae:g~slo°l Respect,~xrlly submitted, Diane M. Dils, Esquire 1400 North Second Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 ~. T~~~ _ ,.,~~v. L ~ ~ ~'' W GUi~>>-_ '+!_ , , '~ ~lo.oo P~ At~l CIC.'~ 3 3a-1 ~x* aa~sgo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANDRA LYNN SHAMANSKY V. JOSEPH P. SHAMANSKY NO. 09-3891 Civil Term DIVORCE DECREE AND NOW, ~pV ~-=, Z do~l , it is ordered and decreed that SANDRA LYNN SHAMANSKY JOSEPH P. SHAMANSKY 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. By the Court, P U ~. Attest: ~ l J.