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Home My WebLink About10-1649IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, N PENNSYLVANIA c CIVIL ACTION-LAW Joshua Lee Shelly n` z7a 4 Plaintiff Pro Se, ?t 7 c ai r ? c_? 1 d ? gym NO. vs { . Kristy Lynn Shelly 00 -< Defendant Pro Se. 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 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 Cumberland County Courthouse, S. Hanover St., 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 ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYERS REFERRAL SERVICE -72 foyA ReAi,/ i7rryT Coe- 111de POK 170 Telephone: 717 - 2 (fl- JW 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 Notice to Defend and Claim Rights f3<a.00 /(P/#. tq Q l y -ne7J b?- Pagel of 2 '??_3 Fr (? y3 disabled individuals having business before the Court, please contact the Court Administrator at (717) 240-6195. All arrangements must bemade at least 72 hours prior to any hearing or business before the Court. Notice to Defend and Claim Rights Page 2 of 2 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Joshua Lee Shelly 120 East Locust Street Mechanicsburg, PA 17055 Plaintiff Pro Se, - VS. NO. l0 - /mot c ?^,? Kristy Lynn Shelly 9 Buttonwood Lane Carlisle, PA 17015 Defendant Pro Se. COMPLAINT IN DIVORCE UNDER §3301(c) OF THE DOMESTIC RELATIONS CODE Count I-Divorce Plaintiff, Joshua Lee Shelly, pro se, respectfully represents: 1. Plaintiff, Joshua Lee Shelly, currently resides at 120 East Locust Street, Mechanicsburg, PA 17055. 2. Defendant, Kristy Lynn Shelly, currently resides at 9 Buttonwood Lane, Carlisle, PA 17015. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have has/have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 06/26/1999, in Mechanicsburg, PA. 5. The parties were separated on 03/01/2003. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 7. The following children were born to the parties: Name AAee Sex Kayla Lynn Shelly 11 Joshua Lee Shelly Jr Tyler Lee Shelly 7 Complaint in Divorce Date of Birth Residence female 09/27/1998 Father 9 male 05/31/2000 Father male 06/14/2002 Father Pagel of 2 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, spousal support, child support, custody, visitation, fees and costs. 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff waives the right to request that the court require the parties to participate in counseling. 12. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. If a divorce based on consent cannot be granted, Plaintiff further alleges in the alternative that the marriage is irretrievably broken and the parties will have been separated for two years or more at the time of final disposition of this case. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. J4 '& 4V Jo ua Lee Shelly, Plaintiff Pro Se VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. A je?? J shua Lee S y, Plaintiff Pro Se Date: 3' q-10 Complaint in Divorce Page 2 of 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ ~ ~~ CIVIL ACTION-LAW .. Joshua Lee Shelly Plaintiff Pro Se, vs. Kristy Lynn Shelly Defendant Pro Se. ACCEPTANCE OF SERVICE ^ Complete items 1, 2, and 3. Also complete item 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 mailpiece, or on the front if space permits. I, Kristy Lynn Shelly, defendant in this divorce action, hereby certify that I personally received a copy of the Complaint in Divorce with a Notice to Defendant and Claim Rights on or about ~~2y/l0 n C \ Kristy Lynn Shell efe t Date: ~ ~~ - 1~ ~t,o~Kt ~ ~.-J Curnb. Co . Pro~o~ry ~~~~ . 1. Article Addressed to: I~riSTy' S~ ~e~~y q gv ~ D~- W Odd t-4'H ~ C~~l%s/r ~i~ ~7of~ A. Signat~ C X ,~ )~,.. P~ ~~1s aolo ~ t~: is .~~ c~~ l ^ Agent B. Received by (Printed Name) C. Date of Delivery ~-I7 D. Is delivery address different from Rem 1? ^ Yes If YES, enter delivery address below: ^ No 3. Service Type - ^ Certified Mail ^ Express Mail ^ Registered ^ Retum Receipt for tse ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Y~ 2. Article Number -f (rransferfromsen 7009 3410 0301 6175 3313 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Exhibit A: Acceptance of Service Page 1 of 1 r 1 d `J ~ ... ~~~ 1 1 J {1 ,4 I ~ ./ Gt _ i } j y •J I x .~ ~ ~ ~~ ~~ L • U H m 'O 7 7 Jos~ve Cie e Stit~/~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1~ r i ~r~ ~ Yr~~ C. -S~ ~ l ~f/ N O. ~ 0 ^ ~6 ~~ ~ iyil DIVORCE DECREE AND NOW, ___ ~li k l /-~ 020 6 , it is ordered and decreed that wTos~ va ~ ~ ~. S~~ ~/~/ ,plaintiff, and krit~Y [v~r~~ Sh~1~16 ,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.") ~ /~l,~r~~/ /~~~~~ ~~~~"+~~~ `~~,•~~ ~JGu~ a~ K t 7 Z O / 0~ ~"/ fA ~'~w~ >~i/~ ~a ~ .e. /~ ~+G,r~Ih ri- ~6 f ~~ ~C.dKl, K By the Court, l~•(7• IO ~•~-~.[d Ccr~- C~ ~ ted ~ `~~~ .. -_I Q N~"fi L`Q. (`(~Cti~lG -~-o ~ ~-