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Home My WebLink About10-0244 JACQUELYN L. SCHUBERT Plaintiff, V. DANIEL L. SCHUBERT, Defendant. OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ?"'C"uCIVIL ACTION - LAW 2010- DIVORCE IN NOTICE CIVIL TERM 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. IFJOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR T PRDNI? THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN LEGAL . HELP. ` a ? M-n t-- r' Cumberland County Bar Association: „! -p ftf J 32 South Bedford Street' -? c Carlisle, Pennsylvania 17013 67: 717-249-3166 G? 1-800-990-9108 w c.a -c 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. 1a 00 W5- JACQUELYN L. SCHUBERT : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2010 - )-Vq CIVIL TERM DANIEL L. SCHUBERT, Defendant. IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND (D) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Jacquelyn L. Schubert, by and through her attorneys, Irwin, & McKnight, P.C., and files this Complaint in Divorce against the Defendant, Daniel L. Schubert, representing as follows: 1. The Plaintiff is Jacquelyn L. Schubert, an adult individual residing at 9 South Chestnut Street, Dillsburg, York County, Pennsylvania 17019. 2. The Defendant is Daniel L. Schubert, an adult individual currently residing at 418 7t' Street, New Cumberland, Cumberland County, Pennsylvania 17070. 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 July 29, 2006 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. vr'' By: k Marc A. , , squire supre ourt I.D. No. 2547 West Pom ssional Buildi 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Dated: January 7, 2010 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. 44?V??L. EL CHUBERT G Date: January 7, 2010 YrN L. bU"UnhKF : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2010- CIVIL TERM DANIEL L. SCHUBERT, Defendant. 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. TEL L. HUBERT ;l s Date: January 7, 2010 JAUt2UL'LYN L. SCHUBERT Plaintiff, V. DANIEL L. SCHUBERT, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2010 - R q 4 CIVIL TERM Defendant. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME I, JACQUELYN L. SCHUBERT, hereby give notice, avowing my intention to resume and hereafter use my prior surname, to wit: JACQUELYN L. METZGER, in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704(a) (54 Pa. C.S.A. 704(a). My divorce is docketed to 2010 - 044 Civil Term. I verify that the statements made in this document 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. IN WITNESS WHEREOF, I have hereunto set my hand and seal this day of January 2010. WITNESSED: EAL) J L L. S UBERT T KNOWN AS: %C J-1 12, b (SEAL) 'A7 ?ELY?4 L. TZ COMMONWEALTH OF PENNSYLVANIA . . SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this fida y of January 2010, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, JACQUELYN L. SCHUBERT, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Notice to Resume Prior Surname, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my han7and i eal r MW= A. MdWW* W M WY PWIC Oct FILED-OFFICE OF THE PROTHONOTARY 2010 JAN -7 PM 3: 35 CUMBE-.#?*. Jliv WUNTY PENNSYLVANIA lpe ells y& r C?ll? 3y?? ,yell JACQUELYN L. SCHUBERT Plaintiff, V. DANIEL L. SCHUBERT, Defendant. CIVIL ACTION - LAW 2010- 244 CIVIL TFt2M N IN DIVORCE xC r,?: l!? AFFIDAVIT OF SERVICE OF COMPLAINT -v PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) o COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: -?i .r r, T! "'C: fTl t,)f?i ? .may jrn z NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Daniel L. Schubert, on January 16, 2010, by certified, restricted delivery mail, addressed to him at 418 7th Street, New Cumberland, Pennsylvania 17070, with Return Receipt Number 7007 2680 0003 0345 1604. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalti f 18 Pa. C.(S?n 4904, relating to unsworn falsification to authorities. Date: January 19, 2010 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MARCNS A. McKNIGHT, III, ESQUIRE Attorney for Plaintiff On this, the 19th of January 2010, before me, the undersigned officer, personally appeared Marcus A. McKnight, III, Esq., known to me to be the person whose name is subscribed to the above instrument and acknowledge that he executed same for the p se er -co ine . C.O WKWASALTH OF PENNSYLVANY? Notarial Seal ota Publ' Mar" 1. Noel, Nolan Public r y carmeb Moro, cumbedend county My Canntssion Expkm Sept 16, 2011 Member, penns*wm Assockwon of Notaries p -0 For delivery information visi t our website at „n l 1/8/2010 MAM - JE N So' VAAAMC M Postage $ D o C3 UNIT 0 rrl Certified Fee Q m ?\ S> PoBTk Y E3 Return Receipt Fee Q p rn ?1 ere C3 (Endorsement Required) V ?' C3 Restricted wary Fee ! ? C3 (Endorseme -0 Total Postage & Fees $ v A. r n Q - I Z i ? N 6 Sent To M 00 %MR .4MR DANIEL L SCHUBERT ;,-p? L1-o --------------------------- p -----f-'?--------------- Nfi" STREET S P H 2 2 Q f m r- d2° °vsa°s"aaraanvw-,&u??- v#---1-:;a741 ----------- Agent B. Received by (Printed Name) I Q. ?? 1JAn1t? L-S6P,L,it 1 D. Is delivery address differen from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type IX Certified Mail O Express Mail ? Registered ;N Retum Receipt for Merchandise ? Insured Mail ? O -n Delhrary? (Extra Fes) ¦ Oomplets items 1, 2, and 3. Also complete Mom 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mallplece, or on the front if space permits. 1. Article Addressed to: MR DANIEL L SCHUBERT 418 7TH STREET NEW CUMBERLAND PA 17070 2. Article Number 7007 2680 0003 0345 1604 (rrer?sfer horn servke /abelJ PS Form 3811, February 2004 Domestic Rob" Receipt 102595-02-M-1 540