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Home My WebLink About10-0703IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNTT. AC''TTON - LAW EDWARD JOHN BLUST„ PLAINTIFF VS. SHELIA ANN BLUST, DEFENDANT TO: Shelia Ann. Blust : N NO. 16- 703 • (j', CV i1Ci tr l' - 77 F- :7 ACTION 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, if any. When the grounds 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 $35a, co pp AT1Y (717)249-3166 ft'* " 0*,2 3 (o9a'7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW EDWARD JOHN BLUST, : Plaintiff No. vs. SHELIA ANN BLUST, Action in Divorce Defendant COMPLAINT IN DIVORCE AND NOW, this 2 day of , 2010, comes the above-named plaintiff, through his attorney, Jeffery M. Cook, and files this complaint seeking a decree in divorce from the above-named defendant under Section 3301(c) of the Divorce Code and, in support thereof avers as follows: 1. The plaintiff, Edward John Blust, is an adult individual who is sui juris and whose address is 339 Gettysburg Pike, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The defendant, Shelia Ann Blust, is an adult individual who is sui juris and whose address is 339 Gettysburg Pike, Mechanicsburg, Cumberland County, Pennsylvania. 17055. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 19, 1989, in Camp Hill, Pennsylvania. 5. There are no prior actions in divorce or for annulment between the parties to this action pending with the Court. 6. The marriage is irretrievably broken. 7. Neither the Plaintiff nor Defendant is in the military or Naval Service of the United States or its allies within the provisions of the Soldiers and Sailors Civil Relief Act of the Congress of 1940, and its amendments. 8. Plaintiff has been advised of the availability of counseling and is aware of the right to request that the Court require the parties to participate in counseling. Count I Reauest for a No-fault Divorce Under Section 3301(c) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, if both parties file Affidavits consenting to a divorce after 90 days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, %44,4 Al - a4, JeftYry WCook Attorney for Plaintiff 234 Baltimore Street Gettysburg, PA 17325 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: o e p io Edward Jo in Blust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ~ °- z, EDWARD BLUST, --~ Plaintiff No. 10-703 ~' ~ ~" r vs. u r i u~ -~~c~ ~. ~ '~ ; , G ~ ~~ i SHELIA ANN BLUST, Action in Divorce : ~ ~' - i `~ ? £• Defendant ~ c rv ~rn ~, ~,, -< AFFIDAVIT OF SERVICE AND NOW, comes Jeffery M. Cook, who upon his solemn oath, doth depose and say he did make service of the Divorce Complaint filed January 28, 2010, in the above-referenced matter on Shelia Ann Blust, defendant herein, by certified mail No. 7003 1010 0004 3073 1222 on February 8, 2010, evidenced by the return receipt card which is attached hereto as Exhibit "A." By: ~ ~'~- effer .Cook Attorne for Plaintiff 234 Baltimore Street Gettysburg, PA 17325 ^ Complete items 1, 2, and 3. Also complete ~..- Jam 4 ff 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 mailpiece, or on the front ff space permfts. 1. Article Addressed to: ~h~~~ ~,~„~~~ ~3~ ~'~ ~~ p Ke ~, ; c ~ 05 ~, ~~a~ S~ ~~ ~ 11 5 t A Signature ~ X ~ ~ Addressee B. Ret~ived by (Pilttted Na-r-e) C. Date of DeNvery ,` o,, ~ f 13/u ~~ ~ D. b rase differerrtfrom item 1? D Yes K YES, enter del(very address below: ^ No 3 ice Type CertHiea Malt D Express Mau D Registered D Return Receipt for Meroharrdiee ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (F~ctta Fee) ^ Yes 2. Art~le Number (Tiatrsfer from service rebel) 7 D 0~ 1010 ~ ~ ~ 4 3 Q 7 3 12 2 2 PS Form 3811, February 2004 Domestic Return Receipt 1172595-02-M-1540 ~ - ~ r . - ~ ~. • ra m ~ i X155 "~ N ° $11.44 0325 R'7 Postage $ ~ Centfied Fee $2.8+~ 1g _ ° P ark ~ Return Reciept Fee e ~ (Endorsement Required) f2.3G ~ ~?j ~ ° Restricted Delivery Fee $~~~~ ~ ( ';, ~ (Endorsement Required) y ~ Total Postage & Fees $ $5.54 '051201 :~ ~ Sent To i ° ---------------- - ~~! ~=------ ---- ---- -- --5-- - - -------------------------- [~- Street, Apt. No.; Z q ~' rrrnl ', o or PO Box No. 3,J 1 ~~~vr ~-_- ~1 ~.J~----------°--- -- - ------------------------------- ----- -__TTT _ __r City, State, Z/P+4 ~ (,S t,~• ~ ~ 0 c~ EXHIBIT "A" ,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ° ~, EDWARD JOHN BLUST, NO. 10-703 ~ 0 c_ ~ PLAINTIFF ~ ~ ~ ~ ~' ` ~' . ~- ~ i w c~ ~ ~ -, ,~ -o SHELIA ANN BLUST, -; `a DEFENDANT ~~ TO: DAVID D. BUELL, PROTHONOTARY PRAECIPE Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for Divorce: Section 3301(c) 2. Date and manner of service of the Complaint: A copy of the complaint was mailed, via certified mail, return receipt requested, and received by defendant on February 8, 2010. An affidavit of service was filed on March 9, 2010. 3. Date of execution of Affidavit of Consent required by §3301 (c) of the Divorce Code; by Plaintiff: June 1, 2010, and filed June 3, 2010; by Defendant: June 1, 2010, and filed June 3, 2010. 4. Date plaintiff s Waiver of Notice in §3301 (c) of the Divorce Code was filed with the Prothonotary: June 3, 2010; Date defendant's Waiver of Notice in §3301 (c) of the Divorce Code was filed with the Prothonotary: June 3, 2010. 5. Related claims pending: Marriage Settlement Agreement to be incorporated into the Divorce Decree as per paragraph 18 of said agreement. DATE: ~ ~ 2'D i ~ n~ . Je ery IVY/ Cook Attorney for Edward John Blust 234 Baltimore Street Gettysburg, PA 17325 (717) 334-8516 .. _ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSY~VAA~I A v CIVIL ACTION -LAW c ~ -n ---~ EDWARD BLUST ~ ~~ `-"r~ , Plaintiff No. 10-703 ~r- -~? ~ 'w ;~ ~si~ ~ ;- . ~~ ~~~ i'l SHELIA ANN BLUST, Action in Divorce ~~ t`•' Defendant : ~ ~ AFFIDAVIT OF SERVICE AND NOW, comes Jeffery M. Cook, who upon his solemn oath, doth depose and say he did .make service of the Divorce Complaint filed January 28, 2010, in the above-referenced matter on Shelia Ann Blust, defendant herein, by certified mail No. 7003 1010 0004 3073 1222 on February 8, 2010, evidenced by the return receipt card which is attached hereto as Exhibit "A." By: 1 `~ ' ~v. effe .Cook Attorne for Plaintiff 234 Baltimore Street .Gettysburg, PA 17325 ^ Complete Rams 1, 2, and 3. Also complete .~ . item 4 K Reshicted Delhreq- is desired. ^ Print your name ahd address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mallpiece, or on the front ff space permits. 1. Article Addressed to: ~5~ ~~5~~~- ~Ke ~~~,~~~; ~ ti ~ ~~- i~o5 S wry S X slg ~U~ ~~j B. Received by ~ Punted na7me) c. Date a Delivery r GL I ~ ~.7~Gi 5~' ^- D. is rasa different Irom Item 1? ^ Yes H YES, enter delivery address bebw: ^ No ! ! 3~ Service type { ~~ _j CerttBed Mall ^ E Mail ! ^ Registered O Return Receipt for Merchandise ! ^ Insured Mail ^ C.O.D. 4. Restrk`ted Deliveryl(Fxtra Feel p Yes 2. Article Number frratsrerrrnm service ~ 7 0 0~ 1010 0 0 0 4 3 0 7 3 12 2 2 , Ps Form 3811, February 2004 Domestic Return Receipt to~oz_~n-tsao ~ '. ti ~ N i. • .• .- rl ~I . , #4.44 4325 m Pos~ge $ { ~' ce~mied Fee #2.84 19 - 0 P o (ErMoMP~m d #2.34 .__ r ~j~ p ResMcted Delhrery Fee ,~ (EntlorsemeM RequMed) #4.44 Ui `er ~ ~. ~ a Total Postage & Fees $ #5. S4 '45/241 -~ ~ i m ro . o i ~ ------ - - -- - -- - N -s`~e4 ~ No - - - or Po Box No -- -- 33~ - -- -~~, - '^''~- Q`------- --------- ----- City State ZIP+4 ~, (-, ~ ~ ~ Q . . ~ .~ _ .. EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW EDWARD JOHN BLUST, NO. 10-703 PLAINTIFF - a 0 c~'J ~, i ` ' ~ 7 SHELIA ANN BLUST, ACTION IN DIVORCE ~ ~~ ' m. ', , -- DEFENDANT "~ ,.-.~ ~ ~ •~ _~. ~ c,i , f. ~"i AFFIDAVIT OF CONSENT Shelia Ann Blurt, Defendant, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on January 28, 2010. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of decree. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. I also waive any request for marriage counseling. 5. I verify that the statements made in this Affidavit are true and correct. I understand that statements herein are made subject to the penalties of 18 Pa. C.S.A. §4909 relating to unsworn falsification to authorities. DATE: ~ 20 1 ~ Shelia Ann Blurt, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW EDWARD JOHN BLUST, PLAINTIFF vs. SHELIA ANN BLUST, DEFENDANT NO. 10-703 _ r.,, o ~'~ -~-. ~ ~ t ~' ~ .~{ r,„ Action in Divorce W i. „? .! ` ~, ~: ~- .. R;, _-~ . ~ WAIVER OFNOTICE OFINTENTION TD RE UEST ENTRYOFA DIVORCEDECREE UNDER SECTION 3301 /cl F THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer=s fees or expenses if I do not claim then 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 are made subject to the penalties of 18 Pa..C.S. Section 4904 relating to unsworn falsification to authorities. DATE: ~ ~ Z~ 1 ° Shelia Ann Blust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW EDWARD JOHN BLUST, NO. 10-'l03 PLAINTIFF ~ vs. .,c* -, , c.._ ~ ---' . ~~ ~ ~~~ SHELIA ANN BLUST, ACTION IN DIVORCE t- ~ ~- ' ~~ DEFENDANT ~ c ; -~'' x ~;.::~ ~" j;"; .. ~` -~ ~' AFFIDAVIT OF CONSENT ~ c~:r -c Edward John Blust, Plaintiff, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on January 28, 2010. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of decree. 4. I understand that if a claim for alimony, alimony pendente life, marital property or counsel fees or expenses has not been filed with the court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. I also waive any request for marriage counseling. 5. I verify that the statements made in this Affidavit are true and correct. I understand that statements herein are made subject to the penalties of 18 Pa. C.S.A. §4909 relating to unsworn falsification to authorities. DATE: ~ ~ Zo ~ ~ Edward John B ust, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW EDWARD JOHN BLUST, PLAINTIFF vs. SHELIA ANN BLUST, DEFENDANT ~ N O "' 1 .r, ~ . NO. 10-703 r,.3<<_~ ~ ~ --~ x~ ~~ - ~ C ~ -- ~ c.~y~_ . -, w_ ` c.,~ ~, ~~' ' ~' Action in Divorce ~ ~~} -..~s '~ ~ r ;~ WAIVER OFNOTICE OFINTENTION TO RE VEST ENTRY OFA DIVORCE DECREE UNDER SECTION 3301(c)OF HE D ORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer-s fees or expenses if I do not claim then 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 are made subject to the penalties of 18 Pa..C.S. Section 4904 relating to unsworn falsification to authorities. DATE: 1 20 I ~ sa~~%~'/' Edward John lust EDWARD JOHN BLUST IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SHELIA ANN BLUST NO, 10-703 DIVORCE DECREE ~- ~ a: 3s- ,~~ . AND NOW, ~~~ ~ , ~~~ , it is ordered and decreed that Edward John Blust plaintiff, and Shelia Ann Biust ,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: None. Please incorporate the Marriage Settlement Agreement dated January 8, 2010. By ourt, Attest: ~,