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Home My WebLink About10-2886 Francis A. Zulli, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 Phone: (717) 232-1488 Email: wzs@mindspring.com FILED- D +E HE T??P, 2010 APR 29 PIN 3: 56 SHONDA A. STERNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA vs. NO. Al/ - 07???! e/v TODD A. STERNER, ; Defendant CIVIL 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 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 THE DIVORCE IS INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. 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 AOU 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 Lawyer's Referral Service 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 (717) 249-3166 9 q1 3 7,7 r Francis A. Zulli, Esquire Superior Court #15316 WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, Pa 17101 Tel: (717) 232-1488 Fax: (717) 236-6100 Email: fazulli.wzs@mindspring.com SHONDA A. STERNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA vs. TODD A. STERNER, Defendant NO. CIVIL ACTION - IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE OF 1980 1. The Plaintiff is Shonda A. Sterner, an adult individual, who currently resides at 5217 Deerfield Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050 since November 2003. 2. The Defendant is Todd A. Sterner, an adult individual, who currently resides at 5217 Deerfield Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050 since November 2003. 3. The Plaintiff and Defendant were married on October 20, 1990, in Camp Hill, Cumberland County, Pennsylvania. 4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 5. There has been no prior actions of divorce or annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. The Plaintiffhas been advised that counseling is available and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling; however, the Plaintiff waives her right to counseling. 8. The Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce. Respectfully submitted, WION, ZULLI & SEIBERT: BY: r is A. Zulli, Esquire 1sb0purg, cust Street ox 1121 PA 17108 (717) 232-1488 VERIFICATION I verify that the statements made in the foregoing 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. Dated: April ,, 2010 c5io'?nda A. Sterner ~i Francis A. Zulli, Esquire Superior Court #15316 WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, Pa 17101 Tel: (717) 232-1488 Fax: (717)236-6100 Email: fazulli.wzs@mindspring.com Y~ ~ 0 MAY 17 P~ 2~ ~ 9 ~~.Pd~iSY~!,1;~.;;~. , SHONDA A. STERNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA • NO. 10- c18'8(0 ~iw 1 -Ti~t~ vs. . TODD A. STERNER, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF SERVICE I, Francis A. Zulli, Esquire, being duly sworn according to law, depose and say that the Defendant in the above-captioned action received a certified copy of the Complaint in Divorce Under Section 3301(c), by Certified Mail, Restricted Delivery of the United States Postal Service with service being made on May 1, 2010. See attached Certified Mailing Sworn and subscribed to before me this ~~ay of May, 2010. may ~ .~~i~ .rC~, ~` Notary Public J[ e ~ ~~ [{ 6411, r ry _ yi4~C`~l i ... .. CERTIFIED MAIL,, RECEIF (Domestic Mail Only; No Insurance Covera~ i u, ~ Postage $ ~ Certified Fee ~ ° Postmark ° Retum Reciept Fee Here (Endorsement Required) ° Restdcted Delivery Fee r-~ (Endorsement Requred) ° r-9 Total F Sterner Todd A m . ° ant To 5217 Deerfield Avenue ° '` sir~i. ~ -------- PA 17050 Mechanicsburg orPOB , ------•- City, Ste :ri rr ^ Complete items 1, 2, and 3. Also compbl+s Rem 4 'rf Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the cans to you. ^ Attach this card to the back of the mailpiece, or on the front if space permRs. 1. Article Addressed to: Todd A. Sterner 5217 Deerfield Avenue Mechanicsburg, PA 17050 A. O B. Received by (Printed Name) C. Date of Delivery D. Is delivery address dHferertt from item 1? 0~ If YES, enter delivery address below: o 3. Servbe type Certified Mail Mall O Registered Retum Receipttor'irtersi~enie ^ Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7 0 0 3 101 D Q A p t 81 S? 3 6 51 (Transfer ham ewvlor! lobsl)~~_ PS Form 3811, Felxuary 2004 Domestic R~urn Rem _ X,~t ya Francis A. Zu11i, Esquire Superior Court #15316 WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, Pa 17101 Tel: (717) 232-1488 Fax: (717)236-6100 Eroail: fazulli.wzs®mindspring.com ~r 'Y~x 1 2~tQOCT 27 py ~: [ ~U ~B~~SY~~ta~~~1~T ~~r~ SHONDA A. STERNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA vs. NO. 10-2886 TODD A. STERNER, Defendant CIVIL ACTION - IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mazk the above-captioned divorce action discontinued and terminated.