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Home My WebLink About09-5794 Mark W. Allshouse, Esquire Attorney ID # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff STEPHANIE J. DEMMY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Tray SHANE R. DEMMY, : CIVIL ACTION -DIVORCE Defendant NOTICE 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 the Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 (800) 990-9108 (717) 249-3116 Date: O I g f n ark W. Allshouse, Es x ttorney I.D. # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff oft Mark W. Allshouse, Esquire Attorney ID # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff STEPHANIE J. DEMMY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0,i- 5'? q It 7? SHANE R. DEMMY, CIVIL ACTION -DIVORCE Defendant COMPLAINT IN DIVORCE AND NOW, comes Stephanie J. Demmy, Plaintiff, by and through her attorney, Mark W. Allshouse, Esquire, respectfully represents: 1. The Plaintiff is Stephanie J. Demmy, an adult individual, who currently resides at 1036 North U.S. Highway 15, Dillsburg, York County, Pennsylvania, 17019, where she has resided since March 2009. 2. The Defendant is Shane R. Demmy, and adult individual, who currently resides at 512 Frey Avenue, Middletown, Dauphin County, Pennsylvania, 17057 where he has resided since July 2009. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 28, 2004 in Linglestown, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. k 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301(c) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: 1 `f W. A lshouse Es irey I.D. # 78014 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff ON VERIFICATION I, Stephanie J. Demmy, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date: *Stepp e J. De y RLE D- CE }F THE ei? i"I I D :- AR 2NA AUG 21 N12: 5 4 $ 338. So p o A TT',f cev a005 Rj* ouq (0o9 Mark W. Allshouse, Esquire Attorney ID # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff STEPHANIE J. DEMMY, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 09-5794 Civil Term SHANE R. DEMMY, :CIVIL ACTION -DIVORCE Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Divorce Complaint filed in the above-captioned matter and return it to my office for service. Respectfully submitted, Date: ~, ~~ ~ ~~ ark .Allshouse, Es ire Attorney I.D. # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff 2~~9 ~~~ ~~ ~~°i U~ Vii.; r ~~ :f~ ,`;;. $1a.oo PQ A'1Y'y CK`" oZ03q a311(o7 Mark W. Allshouse, Esquire Attorney ID # 78014 4833 Spring Road Shermans Dale, PA 17090 (7]7)582-4006 Attorney for Plaintiff STEPHANIE J. DEMMY, v. SHANE R. DEMMY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5794 Civil Term CIVIL ACTION -DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Divorce Complaint filed in the above-captioned matter and return it to my office for service. Respectfully submitted, Date: }~ ~ :~ ~~ --~ ~---- ~ ~ ,, ~k W. Allshouse, esquire ttorney LD. # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff ~., ~ ,--- ~' ~^ -~- Mark W. Allshouse, Esquire - - '.~_ -,- Attorney ID # 78014 - - '-'f. - 4833 Spring Road _ ',_;'' Shermans Dale, PA 17090 - - (717) 582-4006 - ' ~__ Attorney for Plaintiff . - - ~ _, ? _ `-' .`AC STEPHANIE J. DEMMY, IN THE COURT OF COMMON PLEAS ~^. Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA SHANE R. DEMMY, :CIVIL ACTION -DIVORCE Defendant : NOTICE YOU HAVE SEEN 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 the Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 (800) 990-9108 (717) 249-3116 Date. ~,' ~ F .oast :. _.°~°°~"~' _ , Nark W Allshouse, Es uiz ttorney LD. # 78014 ~ ,•4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff Mark W. Allshouse, Esquire Attorney iD # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff STEPHANIE J. DEMMY, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. SHANE R. DEMMY, :CIVIL ACTION -DIVORCE Defendant : COMPLAINT IN DIVORCE AND NOW, comes Stephanie J. Demmy, Plaintiff, by and through her attorney, Mark W. Allshouse, Esquire, respectfully represents: 1. The Plaintiff is Stephanie J. Demmy, an adult individual, who currently resides at .1036 North U.S. Highway 15, Dillsburg, York County, Pennsylvania, 17019, where she has resided since March 2009. 2. The Defendant is Shane R. Demmy, and adult individual, who currently resides at 512 Frey Avenue, Middletown, Dauphin County, Pennsylvania, 17057 where he has resided since July 2009. 3. Tlae Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 28, 2004 in Linglestown, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is izxetrievably broken and Plaintiff is proceeding under Sections 3301(c} of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiffrequests the Court to enter a decree of divorce. Date: F_ ~ ,,`~ '~~ }`,/~~`~; t ~ ~ f ~''~r~ ~'~-' t ~ bark W..Allshouse, Esq~iire A~ttomey I.D. # 78014 433 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff VERIFICATION I, Stephanie J. Demmy, the undersigned, hereby verify that the statements made herein are true and correct. 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: g ~ ~~~ Q ~~ ~ _, ~ Step anie J. Demz~r, y ~i r ' ~li ~. r c , _ {{''~~ u~ ;J •-' y ~i ~~ ~~ `UG L~~L'~ ~IG~~ ~~~ ~ ~ ~ ~~%5' ~~/her-s.~