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Home My WebLink About10-1767Z) `1LED 'J6 S?1'V4 ?•!'\1 i? Tr- 201 O MAR 12 AM E' 11 1ANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com ---------------------------------------------- CU?J???,; ?aY SAMANTHA STODGHILL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. DAVID STODGHILL, Defendant No. Ib - /767 Civil Term 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 35.2 -00 'ad .04 4Ir S" a3 ? ? a? JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esdadams®gmail.com ---------------------------------------------- SAMANTHA STODGHILL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. Civil Term DAVID STODGHILL, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Samantha Stodghill, a competent adult individual, who resides at 111 Big Spring Terrace, Newville, Cumberland County, Pan 17241. 2. Defendant is David Stodghill, a competent adult individual, who is currently incarcerated in Cumberland County Prison, Carlisle, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 30, 1996 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling; Plaintiff waives the right to request counseling. 7. Plaintiff and Defendant have two children together; a custody action has been filed under a separate docket number. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) Under section 3301(c) of the Divorce code, that the marriage is irretrievably broken, and; (b) Under section 3301(d) of the Divorce Code, that the marriage is irretrievably broken, and that the parties have been separated for a period of over two years. WHEREFORE, Plaintiff requests the court to enter a Decree in divorce. 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. §4904 relating to unsworn falsification to authorities. nt a Stodghill, Pla Respectfully submitted, oate Pfirlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF J3 Adams, Esquire D. 0.79465 17 est South St. ?l 7 p 4?Ur+ 1 2 SAMANTHA STODGHILL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. /?- 1'7& 7 Civil Term DAVID STODGHILL, ACTION IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on June 1, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose my 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. §4904 relating to unsworn falsification to authorities. Date: mantha Stodghill, PI 'ntiff SAMANTHA STODGHILL, PLAINTIFF V. DAVID STODGHILL, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 10-1767 CIVIL TERM ORDER OF COURT >f~ AND NOW, this _day of May, 2010, the court is in receipt of a motion for continuance filed by the defendant on May 6, 2010; however, it appearing from the record that there is no pending matter to be continued, the court takes no action on said motion. Similarly, the court notes that the defendant attached to said motion for continuance acounter-affidavit under Section 3301(d) of the Divorce Code in which he requests economic relief under paragraph 2(b) of the affidavit. The defendant is advised that until such time as he files an economic claim with the prothonotary and serves the same on plaintiff, there is nothing before the court which it may consider. By the Court, ~ Jane Adams, Es uire q For Plaintiff -~ David Stodghill Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 :sal ll rr ~ E.S ~t~.t(£d.- S I ~.l t0 Albert H. Masland, J. ~ c ~ a ~ ~~ ~ ~ ~.- c^: ~ ~-, -~ ~ AC N •- ~--~ .. ~ 1 ~I~J~.. 20t0~iAY t3 p~ t; ~~ P~~,`.~Yt.Vq~ItA SAMANTHA STODGHILL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 10 - 1767 Civil Term DAVID STODGHILL, :ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE I, Robert Lindsay, do hereby certify that on the date listed below, I went to the Cumberland County Prison and personally served David Stodghill, Defendant, a true and correct copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE, AND COUNTER-AFFIDAVIT, in the above-captioned matter. Location Served: Cumberland County Prison Date Served: ~ ~D ~ (~ Time Served: ' ~~ I~ Person Documents Delivered to: David Stodghill ~~ ~.. Date: ~ ~ 2, ~ Signed: Cons able be W. Lindsay Pennsylvania ate ConstablE P.O. Box 224 Shippensburg, Pa. 17257 Sworn to and Subscribed before me this h /~~ '~ ~ day of l ' ~~' , 2010 ~(,~ Notar~ Public CoMMOf~V4'~-~~#_7H t~si ~~.+~~~`~i-VANIA tJot2~~iSi `~~~# Julie M. ~~ ~`~"~'~~ Pubiic Carlisle faro. Cclirsberi2r~i County My ~rnmisswn ~~`+r`~ C:~• 6.2011 Men~~er ~enn~''~`~`''~'iion 9f P~oiaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMANTHA STODGHILL, V. DAVID STODGHILL, NO 10 - 1767 Civil Term DIVORCE DECREE AND NOW, l ~ d , it is ordered and decreed that SAMANTHA STODGHILL, plaintiff, and DAVID STODGHILL, 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. By the Court, At st: J. C Prothonotary ~ • ~'~ [ ~ C~'-~- . es~,~ rv~.~' led --~ ~ erns SAMANT ~ A STODGHILL, IN THE COURT OF COMMON PLEAS OF P INTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. II DAVID S ODGHILL, DEFENDANT 10-1767 CIVIL TERM ORDER OF COURT ANID NOW, this 9th day of July, 2010, the court having directed the defendant to file and serve any economic claims within fourteen (14) days of June 22, 2010, and defendant having failed to do so and the court having previously given him notice of his obligation'to properly file said claims in its order of May 12, 2010, the court determines that no valid claims exist and will proceed to enter a divorce decree pursuant to the request of plaintiff. By the Court, Albert H. Masland, J. ~ Jane Adams, Esquire For Plaintiff avid Stodghill Cumberland County Prison 1101 Claremont Road Carlisle, IAA 17013 :sal l.0 i Es rr~ ~ 7 4/, a - ,,-, r- - -; _ ~ -J ~c' ~ __~ _;;. - ~ - c... ~, ~ ; : ~ ~