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Home My WebLink About10-1007JON A. SHEFFIELD, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ,D V. LISA A. SHEFFIELD, Defendant :CIVIL ACTION - LAW :IN DIVORCE :NO. Jp SOD 7 ?M F? N 0 b M Q n Fri v C? (15 C7 Um --c NOTICE TO DEFEND AND CLAIM RIGHTS co TJ 7 ru .r- 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 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 ?? a3 7,39 JON A. SHEFFIELD, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE LISA A. SHEFFIELD, Defendant :NO. /6 6 7 C COMPLAINT AND NOW comes the Plaintiff, Jon A. Sheffield, who, by and through his attorneys, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which he avers that: 1. Plaintiff, Jon A. Sheffield, is an adult individual residing at 1900 High Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Lisa A. Sheffield, is an adult individual residing at 1900 High Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on August 14, 1993. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. §§3301(c) or (d), Plaintiff, Jon A. Sheffield, respectfully requests the Court to enter a Decree of Divorce. DATED: Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 i 1za th S. 2 VERIFICATION I, Jon A. Sheffield, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: ? .. n A. She d J _ ~ Tr!~' !_ r ~1`t~Y Luther E. Milspaw, Jr., Esquire ~ :~ Attorney ID No. 19226 130 State Street, P.O. Box 946 r•?o CL~Ff 3~7 e Harrisburg, PA 17108-0946 r ~ ~ ':. ~d ~~? (717) 236-3141 FAX (717) 236-0791 Email: Luthermilsoaw(a,milsnawlawfirm.com JON A. SHEFFIELD, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 10-1007 Civil LISA A. SHEFFIELD, :CIVIL ACTION -LAW Defendant IN DIVORCE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Luther E. Milspaw, Jr., Esquire, as counsel for the Defendant in the above-captioned matter. su Attorney ID No.v19226 ~~' 130 State Street P.O. Box 946 Harrisburg, PA 17108-0946 (717) 236-3141 Dated: May 4, 2010 JON A. SHEFFIELD, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 10-1007 Civil LISA A. SHEFFIELD, :CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the above Entry of Appearance upon all counsel/parties of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, on the 4`h day of May 2010, addressed as follows: Elizabeth S. Beckley, Esquire Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 submitted, ~~-'~~-- TARA BRIGH ,Paralegal ffice of Luther E. Milspaw, Jr. 130 State Street P.O. Box 946 Harrisburg, PA 17108-0946 (717) 236-3141 JON A. SHEFFIELD, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW ,y :IN DIVORCE n = LISA A. SHEFFIELD, ~? ` - -=! Defendant :NO. 10-1007 Civil = - _ =-~ ' ` ~ _ , ,-, u, - ---~ ; . _~ , _ -~ .,_ ACCEPTANCE OF SERVICE ''~ ~:~ v _, o ,~ I, Lisa A. Sheffield, hereby accept service of the Divorce complaint filed in the above-captioned action. DATED: ~/' • a Lisa A. Sheffield JON A. SHEFFIELD iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LISA A. SHEFFIELD NO. 10 - 1007 DIVORCE DECREE AND NOW, (.~ G-~ .~ Z o ~ CJ, it is ordered and decreed that JON A. SHEFFIELD ,plaintiff, and LISA A. SHEFFIELD ,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: (If no claims remain indicate "None.") None. The Property Settlement Agreement between the parties shall be incorporated into the final decree for purposes of enforcement, but shall not merge with the final Decree in Divorce. By the Court, 0 Atte • ~ J ~ Q~;~ ~ mil) ~ Prot onotary iD - ~-iD /D ~~~ iD ~~ ~.~ ~ ~