The URL can be used to link to this page

Home My WebLink About09-4116LEE HANSHAW, PLAINTIFF ROBERT R. HANSHAW, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- '4114 0,W1 ? *Term 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 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 (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 17103 (717) 240-6195 LEE HANSHAW, PLAINTIFF V. ROBERT R. HANSAHW, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09. N//4 ?.l /.- DIVORCE ACTION COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Lee Hanshaw, is an adult individual who currently resides at 228 Indian Creek Drive, Mechanicsburg, Pennsylvania 17050. 2. Defendant, Robert R. Hanshaw, is an adult individual who currently resides at 228 Indian Creek Drive, Mechanicsburg, Pennsylvania 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on November 18, 1995, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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 Counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Lee Hanshaw, urges this Honorable Court to enter a Decree of Divorce. Ut L 4e-) i Respectfully s N AL By: James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 i VERIFICATION I, LEE HANSHAW, verify that the statements made in the foregoing DIVORCE COMPLAINT are true and correct'. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Date: Cc:;, g LEE HANSHAW OF THE 2009 jU 4 16 P 1: 5 5 . ? Po A C?,K.? 5t3q . er* ou4p 811 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 LEE HANSHAW, Plaintiff v. ROBERT R. HANSHAW, Defendant IN T E COURT OF COMMON PLEAS CU BERLAND COUNTY, PENNSYLVANIA NO. 09 - 4116 CIV1~L ACTION -LAW Please enter my appearance on behalf of captioned matter. Y Dated: July 16, 2009 Robert R. Hanshaw, in the above- Bf~rb Sumple-Sullivan, Esquire 549 B 'dge Street New umberland, PA 1707() (717) 74-1445 Supr a Court I.D. 32317 Attorn v for Defendant Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 71~ 774-1445 LEE HANSHAW, Plaintiff v. ROBERT R. HANSHAW, Defendant IN T E COURT OF COMMON PLEAS CU BERLAND COUNTY, PENNSYLVANIA NO. 09 - 4116 I, BARBARA SUMPLE-SULLIVAN, served a true and correct copy of the Praecipe to matter upon the following individual(s), by United addressed as follows: DATE: July 16, 2009 ACTION -LAW do hereby certify that on this date, I Appearance, in the above-captioned first-class mail, postage prepaid, James G. Nealon, III, Esqu 2411 North Fr nt Street Harrisburg, P 17110,- Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Defendant Fii..~i. _ ~j:_=~:c 2~t19 ,~~;~. i 7 P~ 2~ Q i ,_{.~ u~_r~r~:. ~~.,. ~ .r~~ 3 }-~..~vi ~~~ LEE HANSHAW, IN THE COURT OF COMMON PLEAS PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-4116 Civil Action ROBERT R. HANSIIAW, :DIVORCE ACTION DEFENDANT AFFIDAVIT OF SERVICE I, James G. Nealon, III, Esquire, verify that on the 8th day of July, 2009, I served the Defendant with a true and correct copy of the Complaint for Divorce; Interrogatories and Request for Production of Documents by one of the following methods: (CHECK ONE) (X ) Service was made by United States Postal Service, first class mail, postage prepaid, certified, restricted delivery, return receipt requested to the Defendant, on the 8th day of July, 2009. The return receipt signed by the Defendant is attached hereto. ( ) The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant. Personal service was made at following location and time: on the • _ day of , 2009 at I verify that the statements made in this affidavit are true correct. I understand that false statements herein are made subject to the penalties of 18~ S.A. §4904 relating to unsworn falsification to authorities. ~ J /~ James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Dated: ~/! 3 f d~ • Complete items 1, 2, and 3. Also complete Nam 4 if Restricted Delivery Is_desired. A Print yourname and address on the reverse p 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. cie Addressed to: ' ~~" ~ ~~ SI-,~~ a~ ~ -~~ i GL1''1 ~~~ ~Y '~ a ^ Agent 1L- ^ Addrwr+ar+ 8. PifrKedlJa C. De1vwY uFG pq r . Is delivery adds Efferent from itemq~ H YES, eater 2 address `r u ~~ ~ 3 Type Cerdfled Mail Express Mall istered ~Fietum Receipt for Merckrer~ D Insured Mall. ^ 6.O.D 4. Restricted Delivery? (Eadra Feel z: ~Numt,er 7006 2150 ^001 X115 7055 f 1-rrr*rr ArrAr°sRMrrrr PS Foam X11, February 2004 fbrn~AiC Rralurn R.o.lpe ,a~0eo2-ter-,sao . .. , . ~~ ZN9 AUG ! 4 PM 2~ 51 G~~YLA -LEE HANSHAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. . ROBERT R. HANSHAW NO 09 - 4118 DIVORCE DECREE ~ NSW, ~j , it is ordered and decreed that LEE HANSHAW plaintiff, and ROBERT R. HANSHAW ,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. All matters have been resolved between the parties pursuant to the Marital Settlement Agreement dated May 11, 2010 and incorporated, but not merged, into this Decree. '~_~--_ " the Court, J. Prothonotary C~ ~~~~~ o C~-~-• c~ ~n,~;, tee ~, • .~. • ~ a ~ °-~~ csz- .,tea; le d -i~o -4-0 ~ S~'vo,'1 ~~~