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Home My WebLink About09-6348 Jessica L. Shaw Plaintiff V. Roger J. Shaw Defendant N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- L3yg CIVIL TERM 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, 1 Courthouse Square, Carlisle, Pennsylvania. 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 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 17013 (717) 249-3166 V,. Jessica L. Shaw IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- G 3 W? CIVIL TERM Roger J. Shaw Defendant IN DIVORCE COMPLAINT UNDER &3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ?j e.5 S t c o, L . S 00 , who currently resides at 15q-7 ?.c% Qn c ks I .e CA I -7o 1 3 , Cumberland County, Pennsylvania. fttA6L 2. Defendant is P? , who currently resides at Lau2? tbg kl d ?a 6 Gr t a-J1, ? 1 0 ?oK Ce I S v n1 was e se ?- ??} I S? 6 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ?)y 66 3 at Ga(LA(s1e. aurAoptkr?hA 5. The marriage is irretrievably broken, and the parties separated on -?y i\-.e- ?-QbLA 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. a o _ Date Plai f, Pro Se I, eS S' G C.. „S d A 0 , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. &7 a a? Date: Plainti , Pro Se Assisted by: Jacqueline M. Verney, Esq. Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 A? RILE-D--ir*HGE _ OF THE ; , .. 1 - - 'n f Y 2009 SLE? 24 All 0: z I CtIIS?! SY ,P =FP Jessica L. Shaw IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 6348 CIVIL TERM Roger J. Shaw Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jessica L. Shaw, Plaintiff, to proceed in forma ap uperis. I, Jacqueline M. Verney, attorney for the party proceeding in forma ap, uneris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jac eline M. Verney, Esquire Attorney for Plaintiff Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 FILED-Cll: rICE OF THE _IT 2009 SEIP 24 AN 10: 2 Jessica L. Shaw IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- CIVIL TERM Roger J. Shaw Defendant IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that Plaintiff in the above matter filed a Complaint in Divorce filed on Jessica Lea Shaw hereby intends to resume and hereafter use her previous name of Jessica Lea Mow and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. gosT4-r-rE4- ?, ?? La?'-A-A -V- Jessica a Shaw C ?-?oS?e.?e,6Z) Jessi Lea SAw .?4 o &-r F- TT F-rZ- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS On this, the day of bX? ,2009, before me, the undersigned officer personally appeared OW&- ke.s- SK" , also known as .lesscca, lt4 #Ailtdi y' known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set'' my hand and official seal. Title of Officer COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL VALERIE F. GSELL, Notary Public Carlisle 13M., Cumberland County COf1MnISSi0f1 Expires Octobe'9,2010 Vii" i i it i ,!y t, t?Y 2009 SEP 2 F`i'b 2: M Jessica L. Shaw IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- Cf 3 `1 S CIVIL TERM Roger J. Shaw Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Roger J. Shaw (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. 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 Roger J. Itlaw, Defendant fUD-tXTU OF THE PROTHO C" 2009 OCT -2 Aft 11: 19 CU,'VbEhL,",,, till C?'JU TY w`ENNS`r'C ANPA JESSICA L. SHAW, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION -LAW ROGER J. SHAW, Defendant N0.09-6348 CIVIL TERM ORDER OF COURT AND NOW, this 21St day of January, 2010, upon consideration of Plaintiff's praecipe to transmit the record in the above-captioned matter, and it appearing that Plaintiff's affidavit of consent lacks a date of signing at least 90 days after the service of the complaint, a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiency and file a new praecipe to transmit the record. / Jessica L. Shaw 1547 Spring Road Apt. B Carlisle, PA 17013 Plaintiff / Jacqueline M. Verney, Esq. 44 S. Hanover Street Carlisle, PA 17013 me ~.y ~ L ~~a~.~iv `~-~ c7 ^~ ._ ~ ~' ~ T _ ~~~ N -Tc~ .;y ,/ ~, (fit BY THE COURT,