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Home My WebLink About09-4566WENDY SWAB, Plaintiff V. SHAWN SWAB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL TERM 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 OM & &U ULAKIs Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 WENDY SWAB, Plaintiff V. SHAWN SWAB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Wendy Swab, who currently resides at 455 Shed Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Shawn Swab, who currently resides at 1365 West Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 2, 2001 at Camp Hill, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since June 1, 2009, and continue to do so. 8. 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 such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, DATE A BOM & KUTULAKi4 L.L.P. Kara W. Haggerty, Attorney ID No. 81 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff P VERIFICATION I, WENDY SWAB, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date 3 ??? % WEN AB r PLF ?f3?1S jU" _.3 1112: ? t C?,'Pv a 46-*- s& Ay Cr W 93 (I I aa77L17 WENDY SWAB, Plaintiff V. SHAWN SWAB, Defendant To: Prothonotary IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. Q ?-K46 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO REINSTATE Please reinstate the above-captioned divorce action. ABOM & KUTULAKIS, L.L.P. By: Kara W. Haggerty, q ? e ? Attorney ID# 8 1 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff „-ram 20tn,9 fXU' II Fill 1:L:6 Ag. od ho? ?/? # 17 33 iv- ow7i WENDY SWAB, Plaintiff V. SHAWN SWAB, Defendant To: Prothonotary IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09-Yj_k6 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO REINSTATE Please reinstate the above-captioned divorce action. ABOM & KUTULAKIS, L.L.P. Dated: September 15, 2009 By: Kara W. Haggerty, Es Attorney ID# 8691, 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff OF ?H 2H9 SEP 15 Pr ?, * I I & KMom uLAKls Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 WENDY SWAB, Plaintiff v. SHAWN SWAB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 09-4566 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ? day of Sfr'? , 2009, I, SHAWN SWAB, hereby certify that I did receive and accept service of the Complaint in Divorce in the above captioned matter. e?0 ;? SHAWN SWAB F{4.{..i.l tJl. OP THE PP' ;`-!f `,,'N JTARY 2009 OCT -o Phi 3. S2 GiJM JA-'y PE S Jig SYLVAN {ip 1t??? d { '..J L?aB OM ~' T'L~]LAKIS Kara W. Haggerty, Esquire Attorney I,D. #: 86914 2 West High Street Carlisle, PA 17013 (717)249-0900 WENDY SWAB, Plaintiff v. SHAWN SWAB, Defendant t~F TH~C TARY 2QIQ JllN 2t~ PP! 3: t 2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA N0.09-4566 CNIL ACTION -LAW IN DNORCE Notice is hereby given that the Plaintiff in the above matter, WENDY SWAB, pursuant to the divorce action filed at the above term and number, hereby elects to resume the prior surname of Stuber, thereby changing her legal name to Wendy Stuber, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. § 704. Date: `~ WE Y SWAB Date: ~0 WE Y STUBER ,~d ~~~~a ~ ~~~ C~/C,~a y5`l ~~Y ~1~asa p ~r~nnr~, ~I JUN 2 4 201U ~iLSU""u u COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On the ,2Z day of ..,~w-JE , 2010, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA (,~~ ~,YU~C~ Notarial Seal Tabitha N. Krrxnich, Notary Public No Public Camp HMI f3oro, Currrberland Cotmty MY ~rrwni~ion E~ires pec.13, 2011 Member, Pennsvivania Assoriatinn of Notaries 0 _______..__~.._e__________ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WENDY SWAB V. SHAWN SWAB N O. 09-4566 DIVORCE DECREE AND NOW, ~ d ~ ~ , it is ordered and decreed that WENDY SWAB plaintiff, and SHAWN SWAB ,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 otary By the Court, tY~; (mod -k~ {i~u U md„~ec~ -~o `~