HomeMy WebLinkAbout04-2159FRANKLIN M. HERSHEY, JR.,
Plaintiff
NOTICE T: IN THE COURT OF COMMON PLEAS OF
V.
NICOLE J. HERSHEY,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO.O q -? 16Q 1 CIVIL TERM
IN DIVORCE
D 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
will proceed without you and a decree of divorce or annulment may be entered against you for
any 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 Cumberland County Courthouse, Carlisle, Cumberland County,
Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
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 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
FRANKLIN M. HERSHEY, JR.,
Plaintiff
V.
NICOLE J. HERSHEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. Dq -Al 9 CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
1. Plaintiff is Franklin M. Hershey, Jr., an adult individual currently residing at 93
Hershey Road, Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Nicole J. Hershey, an adult individual currently residing at 27
Independence Drive, Shippensburg, Cumberland County, Pennsylvania.
3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on May 6, 1995, in Oakville, Cumberland
County, Pennsylvania.
5. There have been no other prior actions for divorce or annulment between the parties.
6. Neither the Plaintiff nor the Defendant are members of the United States Armed
Forces or its Allies.
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling. Knowing this, Plaintiff does
not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90)
days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301 (c) of the Domestic Relations Code.
Respectfully submitted,
s ire
ttorn
f
4WorPlalin
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document 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 unswom falsifications to authorities.
DATE: pf/j St
FRANKLIN M. HERS , J . laintiff
d
_rt Or o7
FRANKLIN M. HERSHEY, JR. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
: NO. 04-2159 CIVIL TERM
NICOLE J. HERSHEY,
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE
this day of June, 2004, comes Bradley L. Griffie, Esquire,
AND NOW,
d attested
counsel of record for Plaintiff, Franklin M. Hershey, Jr., and states that a true an copy
of a Complaint in Divorce was sent to Defendant, Nicole J. Shershey, 27 Independence Drive,
Shippensburg, PA 17257, by certified mail, restricted delivery, return receipt requested. A copy
of said receipt is attached hereto indicating that service was made on June 2, 2004
B PPI e,Es ire
rrney inti
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
Sworn and subscribed to
before t e this -V2L- d2004
of
TARY LIC
Wo-
MI NCO' Wn?
0lL?
Curtis R. Long
Prothonotary
(Office of the Protbonotarp
uCumberranb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
y - 021 9 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573