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HomeMy WebLinkAbout09-7118ROBERT W. SHIELDS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009 - Ali CIVIL TERM GRETCHEN E. SHIELDS, Defendant. IN DIVORCE 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 in 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, Carlisle, Pennsylvania 17013. 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 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ROBERT W. SHIELDS, JR., Plaintiff, V. GRETCHEN E. SHIELDS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009 -711P CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND (D OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Robert W. Shields, Jr., by and through his attorneys, Irwin, & McKnight, P.C. and files this Complaint in Divorce against the Defendant, Gretchen E. Sheilds, representing as follows: 1. The Plaintiff is Robert W. Shields, Jr., an adult individual residing at 89 Channel Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Gretchen E. Shields, an adult individual currently residing at 1640 Spring Road, Apartment #2, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on December 30, 2001 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. 8. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are: (a) §3301(c). The marriage of the parties is irretrievably broken; and (b) §3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time, Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN & McKNIGHT, P.C. Dated: October 16, 2009 By: MarcusK. Mc ight, I, Esquire _ 5476 Supreme Court I. No- West Pomfret Proessional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ROBERT W. SHIELDS, JR Date: October 16, 2009 ROBERT W. SHIELDS, JR., Plaintiff, V. GRETCHEN E. SHIELDS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009- CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: October 16, 2009 A&-? A - J ROBERT W. SHIELD, JR. nFILE TH- L 2009 OC T 16 Pi 4: 0 4 YLIV14 fi # #0. 5-6 AOJ Cry V3 plem y& ROBERT W. SHIELDS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM GRETCHEN E. SHIELDS, IN DIVORCE Defendant. 2009 -7119 CIVIL TERM IN CUSTODY AFFIDAVIT OF SERVICE I, ROBERT W. SHIELDS, JR., a competent adult, being duly sworn according to law, depose and say that at approximately on October 20 i 2009, I personally served by hand delivery to Gretchen E. Shields the Complaint in Divorce in reference to the above- captioned case as well as the Complaint for Custody: To: Gretchen E. Shields 1640 Spring Road, Apartment #2 Carlisle, PA 17013 I verify that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Date: QCt'p,{ `P?? 0D q Sworn and subscribed before me this a f J" day of October.,M. _ ROBERT W. SHIELDS, Notarial Se* is L. Noel, Notary public ItOro, Cumberland County latbn MO N Sept. 18. 2011 OF THE F- ; ,TARY 2009 OCT 21 PH 3: 19 Phi 'tin 1_ fr ! ROBERT W. SHIELDS, JR., Plaintiff, V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009- 7118 GRETCHEN E. SHIELDS, Defendant. IN DIVORCE CIVIL TERN co M ...., (,Or- NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE To: GRETCHEN E. SHIELDS r-0 v , You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after March 5, 2012, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect your economic claims. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 ROBERT W. SHIELDS, JR., Plaintiff, V. GRETCHEN E. SHIELDS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM IN DIVORCE ?~. :X NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about September 12, 2009, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. of 4904 relating to unsworn falsification to authorities. Date: / _ 7 L /kz?-OBERT W. SHIELDS, . Plaintiff ROBERT W. SHIELDS, JR., Plaintiff, V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM GRETCHEN E. SHIELDS, Defendant. 1. Check either (a) or (b): IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not with to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. GRETCHEN E. SHIELDS Defendant Date: NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ROBERT W. SHIELDS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM GRETCHEN E. SHIELDS, lT Defendant. IN DIVORCE -a =rrI 3%- NOTICE OF INTENTION TO REQUEST x? ma `r' ENTRY OF 3301(d) DIVORCE DECREE E? To: GRETCHEN E. SHIELDS J- You have been sued in an action for divorce. You have failed to answer the Complain t or fi le a Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after A pril 16. 2012, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect your economic claims. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 '.1 ?i'??7f:.t1?6?!i? PENNSY1 WAwA ROBERT W. SHIELDS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM GRETCHEN E. SHIELDS, Defendant. IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed on October 16. 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. >. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: May 21, 2012 ROBERT W. SHIELDS, JR. Plaintiff 6a { I j' 22 ROBERT W. SHIELDS, JR., Plaintiff, v. GRETCHEN E. SHIELDS, Defendant. : IN THE CO? : CUMBERLAND CO NION PLEAS OF , PENNSYLVANIA CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. i Date: MAY 21 , 2012 ROBERT W. SHIELDS, JR. Plaintiff f: ROBERT W. SHIELDS, JR., IN, K&@V q O VIMON PLEAS OF Plaintiff, : CUMBMAND/COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM GRETCHEN E. SHIELDS, Defendant. IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Gretchen E. Shields, on or about December 20, 2009, by personal service at her address of 1640 Spring Road, Apartment 42, Carlisle, Pennsylvania, 17015, a copy of the Affidavit of Service was filed on October 2 I, 2009. 3 Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by plaintiff: May 21, 2012 by defendant: --- (b)(1) Date of execution or- the affidavit required by Section 3301(d) of the Divorce Code: January 27, 2012. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: Filed February 9, 2012 and served on or about Apri17, 2012. 4. Related claims pending: NONE. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: Service was attempted on March 21, 2012 by Certified Mail but was unclaimed. Service was by Regular Mail on or about April 6, 2012 by Regular Mail. Said mailing was not returned to sender. May 22, 2012. Date defendant's Waiver of Notice in Section 3,?61(c) Divorce was filed with the Prothonotary: A. NlWinight, III, Esquire Atto ey for Plaintiff (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date: May 22, 2012 LAW OFFICES IRWIN & McKNIGHT, P. C. ROGER B. IRWIN MARCUS A. MCKNIGHT 111 DOUGLAS G. MILLER STEPHEN L, BLOOM .WATTHEW A. McKNIGHT WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013-3222 (717) 249-2353 FAX (717) 249-6354 WWW IRWINMCKNIGHT COM HAROLD S. IRWIN (1925-1977) HAROLD S. IRWIN. JR. (1951-1986) IRWIN. IRWIN & IRWIN (1956-1986) IRWIN. IRWIN & McKNIGHT (1986-1994) IRWIN. A&KNIGHT & HUGHES (1994-2003) IRWIN & U, KNIGHT (2003-2008) March 21, 2012 Via Certified Mail 7010 0290 0000 6471 3127 Ms. Gretchen E. Shields 5550 State Route 209 Lykens, PA 17048 Re: Robert W. Shields,,Jr. Plaintiff v. Gretchen E. Shields, Defendant No. 2009 - 7118 Dear Ms. Shields: This letter is to advise you that I have filed Plaintiff s Affidavit Under Section 3301(d) of the Divorce Code as well as the Notice of Intention to Request Entry of 3301(d) Divorce Decree. Also enclosed with this letter is the Counter-Affidavit Under Section 3301(d) of the Divorce Code. If you do not respond by filing all of your economic claims with the Prothonotary in writing on or before April 16, 2012, 1 will proceed with finalizing the above-captioned divorce. &McKNIGHT, P.C. Y' III, Esquire MAM/min Enclosures cc: Mr. Robert W. Shields, Jr. 5Z q, 2ft*'m'n=, T 02 10 °001678412 MAItaFROY 7fo 2°1 2b 12 D$ 17713 M1M1N?, rn 40 wa • % p ` rn 0 a 11 m „ ` Li LiV1' I 0 0 a° m m H E cr1 CE m¢ ? Edo O N 0 2m mm a°? m? zo ti Q0 mD R c c Z2TE TiL fi9 0000 0620 0TU. o aw?? P - ru m r C3 Q C C3 Q Er ru a O C3 Q r-3 El, P- ~a ^y d . I., f7 nil ? •t,, •L 41 ??m co ir . es Lti: ??C C ? y ? tAtl n) VVVVVV rn ? Il L!ar ''L f"I tin s.. c,'Ss ti 0 N W 00 woo VA CA o LM 4 !vim 05 D C? W ? -v e? Ila n fa, ?L ?" C3+ [:.Z-- fd :T ry fa, i- i ROBERT W. SHIELDS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW = V -? . C ° 2009 - 7118 CIVIL TERM ?,-- GRETCHEN E. SHIELDS, Defendant. IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about September 12, 2009, and have continued to live separate and apart for a period of at least two years. The marriage is irretrievably broken. 2. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. of 4904 relating t? unsworn falsification to authorities. Date: ?'" 02 7 r L ROBERT W. SHIELDS, Plaintiff ROBERT W. SHIELDS, JR., Plaintiff, V. GRETCHEN E. SHIELDS, Defendant. 1. Check either (a) or (b): : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009 - 7118 CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): __ (a) I do not with to make any claims for economic relief. I understand that I may lose rights concerning alimony., division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. __ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. ROBERT W. SHIELDS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYL VANIA V. CIVIL ACTION - LAW 2009 - 7118 CIVIL TER MUD ZZ GRETCHEN E. SHIELDS, -n. ? n -;-: Defendant. IN DIVORCE `?'?? r`' NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE " _j r To: GRETCHEN E. SHIELDS You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after April 16, 2012, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect your economic claims. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. GRETCHEN E. SHIELDS Defendant Date: NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. S-,b ROBERT W. SHEILDS, JR. V. GRETCHEN E. SHIELDS DIVORCE DECREE AND NOW, ?., (Z- , it is ordered and decreed that ROBERT W. SHEILDS, JR. GRETCHEN E. SHIELDS bonds of matrimony. , plaintiff, and defendant, are divorced from the 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. Court, Thomas A. Placey common Pleas Judg IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 7118 Attest: J. ViD T> uFlG, Prothonot lo{x-e tdP y ywadto o/ r4?