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
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OF THE P- "0T+
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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
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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
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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.