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HomeMy WebLinkAbout10-3258F{I.EL~-~-~~",.,t- w~r~~~ v Paul J. Esposito, Esquire I.D. #25454 Z~~~ ~i~~ t 7 H~ ~i~~ L °::. ~' ~ ~;-~~/ GOLDBERG KATZMAN, P.C. ~~~'-~~ , ,t_1r' ~r i_,'.}sf' ~d i 1 320 Market Street ~~>~?`,~~~~t frk,~v;+l~ P. O. Box 1268 Y7'4 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Plaintiff SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ~l/- ~o?_~i~ _ -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND 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 with twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may also be entered against you by the Court without further notice for arty money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. When the ground for 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TfIIS OFFICE MAY BF, 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 BAR ASSOCIATION 32 Court Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 ~ ~dc/ ~fl C,~~~ 9~a?3/ Yle~~t -~ya~~s ~~~~ Paul J. Esposito, Esquire I.D. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Hamsburg, PA 17108-1268 (717)234-4161;(717)234-6808 (facsimile) Counsel for Plaintiff SHANNON BISHOP, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. - Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF COUNSELING SHANNON BISHOP, being duly sworn according to law, deposes and says: I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I to participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Waiver 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. tJ /~~~0 / C7 Date: ~~. SHANNON BISHOP Paul J. Esposito, Esquire LD. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717)234-4161;(717)234-4161 (facsimile) Counsel for Plaintiff SHANNON BISHOP, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE Plaintiff, SHANNON BISHOP, is an adult individual, wha currently resides at 3 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, ALLAN C. BISHOP, is an adult individual, who currently resides at 3 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on December 11, 2008, Cumberland County, Pennsylvania. Neither Plaintiff nor Defendant is in the military service oi~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. 6. There have been no prior actions of divorce or annulment filed by either of the parties hereto. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. COUNTI 9. The averments of Paragraphs 1 through 8 herein are hereby incorporated by reference thereto. 10. The marriage is irretrievably broken. COUNT II 11. The averments of Paragraphs 1 through 10 herein are hereby incorporated by reference thereto. 12. Plaintiff and Defendant have acquired property, during their marriage until the date of their separation, which property is marital. 13. Plaintiff requests this Court to preserve her right to have all marital property of the parties equitably distributed. 14. The averments of paragraphs 1 through 13 herein are hereby incorporated by reference thereto. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to adequately support herself through appropriate employment. 16. Plaintiff requires reasonable support to adequately maintain herself. 17. Plaintiff requests this Court to preserve her right to seek an award of reasonable temporary alimony and additional sums as may become necessary from time to time hereafter until final hearing and permanent alimony thereafter. 2 COUNT IV 18. The averments of paragraphs 1 through 17 herein are hereby incorporated by reference thereto. 19. Plaintiff has employed the firm of Goldberg Katzman, P.C., as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 20. Plaintiff requests the Court to allow her reasonable counsel fees, costs and expenses. WHEREFORE, Plaintiff prays Your Honorable Court to: a. Enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant; and b. Order equitable distribution of marital property; and c. Order payment of alimony as the Court deems just and reasonable; and d. Order payment of alimony pendente lite, counsel fees, costs and other expenses as the Court deems just and reasonable; and e. Order such other relief as the Court deems just and reasonable. GOLD~jERG K~yT'ZMAN, P.C. Paul J. F~posit ,Esquire Attorney I.D. 25454 320 Market Street Date: ~~ ~ a~ P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 (717) 234-6808 (facsimile) Attorney for Plaintiff VERIFICATION I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: `,r / ~ ~~ ~~ ~ SHANNON BISHOP ~iLEC~,` ,s_ ~;;, ,. ; ~4~ ,;,,~~~,T,,RY 20{0.l~L ~6 °~ IZ~ 39 GOLDBERGKATZMAN,P.C. CUi~Yi~`~;~'t:-,.i.+' ~'.1rUa~llY 320 Market Street r~ P,~~.;.lr.;,i~~ P. o. BoX ]zbg Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Plaintiff __ Yaul J. F,sposito. Esquire I.D. #25454 SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-3258 -Civil Term ALL.~ILT ~;. EiS:iv:', ~iVi:, ci ~: iv?v -- i.~ i v ' Defendant IN DIVORCE ELECTION TO RESUME PRIOR NAME SHANNON MARIE BISHOP, being duly sworn according to law, deposes and says that she is the Plaintiff in the above suit, which was filed with the Court of Common Pleas on May 17, 2410, at the above-referenced docket number. That Plaintiff wishes to retake and hereafter use her prior name of SHANNON MARIE HART, and therefore, gives written notice of avowing said intention, in accordance with the provisions of Title 54 Pa.C.S.A. §704(a). SHANNON MARIE BISHOP To be kno as SHAN RIE ART SHANNON MARIE HART Sworn to d subscribed befo e this ~ da f - i~~~~ , 2010. Notary Pub is ~,y~ ~ ~ n ~ n ~f My Commission Expires: I I c O'~ , o~lJ~ TN OF PENNSYLVANIA NohrW !seal Janrte L. WaNars, Nomry Put+llc Prar~IcNn Twp., Yark County N~ ExpU~s IAarah 28, 2013 sdsmber, Penr>sylvanla AsaoGadon of Naiades ~,,~• ~ d P ~ ~Y ~~d.bc% cY.~9g's3F! l~~f~~t 2~ ~y~~~i ~'-~~-0~ F~~ Paul J. Esposito, Esquire ~ ! ;.~, r> p t } ! ~ ~ tir ~ ~ _._ ~ 1 . <~ ~ t ~ ; . f? 1. ~ ~ . t 1 I.D. #25454 . GOLDBERG KATZMAN, P.C. 320 Market Street .,~g E t t _ ~ ~ , ~ (~ ~} ~t ~ ~ ~ ~~ 6 ; :, P. O. Box 1268 4 iJ Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) `"` e ~ 1.1 ~' ` 3 r't ~ ~ "~ ~~~ (~ l`~ ~ jf ~ ` 1 ~ ~ (~ ~~~ k ~ U W Counsel or Plainti I 1I ' rr"c,I~y~'ti\!I kfi\ ~,aj r"a SHANNON BISHOP, :' ~"'~'T`I~~'COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v• NO, 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Kindly withdraw the claims contained in Complaint for Divorce, namely: Count II - Equitable Distribution of Property; Count III -Alimony and Alimony Pendente Lite; Count IV -Counsel Fees, Costs and Expenses, filed in behalf of Plaintiff in the above-captioned action. Dated: ~ ' ' ~ ~ ~ I~ Paul J. Es sito squire Goldberg Katzman, P.C. P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiff CERTIFICATE OF SERVICE On this oZ4 ~ day of ©t",~ , 2010, I certify that a copy of the foregoing was served upon the following counsel of record by delivering same in the manner indicated, addressed as follows: VIA FIRST CLASS MAIL Debra Denison Cantor, Esquire McNees, Wallace & Nurick, LLC P.O. Box 1166 100 Pine Street Harrisburg, PA 17108-1166 Attorney for Defendant ~~~~ ~~ Paul J. E~osi Attorney I.D. 25454 Attorneys for Plaintiff {~ 1~ ~~_r}. F 1~E ~ I Paul J. Esposito, Esquire LD. #25454 ~ ~,,~~p , GOLDBERG ICATZMAN, P.C. "' i ~ r Fr + tz (. 1'i ~ i 320 Market Street "` ~ ~ ~ t t ~ .~ f~ ~ p P. O. Box 1268 ~ E~. i~=E ~ `E ,~ C ~ ~ ~ ¢ 1. ~ ~ t ~°,, Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel (or Plaintiff SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on May 17, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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: ~~ ~ C~ t !(.G`K SHANNON HART, Formerly Known as, SHANNON BISHOP ~ ~- t e ~ ~ ~ ~ ~ ^,- _ ~ ~}~' ; L: !~ ~3 ~ ~ ~~~ # ' e~ ~ ~ r ~ 4 Paul J. Esposito, Esquire I.D.#25454 no..~? [^;~~~~y~~'~r 4 ` g`` GOLDBERG KATZMAN, P.C. 320 Market Street , , '. , f j" { CJ ~ ~t (.. ~"~ i ~ `~ " ~ "3 L, ~'t ~1 Cti ~ ~},l r + ~ 0 l`' P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Plainti/f SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v• NO. 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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 them 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 P . :S. §4904 relating to unsworn falsification to authorities. ~ ~ Date: / ~ / ~ SHANNON HART, Formerly Known as, SHANNON BISHOP ~'s ~ 0 ~~'«' -1 P~9 i ~ ~' ~ Paul J. Esposito, Esquire i, I.D. #25454 `et * 4 ~~ ~,, tJ V ~ ~~ {~ GOLDBERG KATZMAN, P.C. A ~ ~ ~~ ~ f (L ~ ~ ~ 320 Market Street r ?~ ~' ~'~ YS C',~ ~~' ~ r'al 4 ~, k ~ ~ t`*. P. O. Box 1268 Harsisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel /or Plainti[f SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on May 17, 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 the decree. 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint in Divorce on or about May 24, 2010, via Acceptance of Service executed by my attorney, Debra D. Cantor, Esquire. 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. h. (~ Date: OC-CJ6E~2. ~r 0 /~ ALLAN C. BI OP ,- s r- i-1 +- t°~~~ -C3ti E ,- ~~ g~Y E. Paul J. Esposito, Esquire p , } 4' (~ ~ fi~~ tiQ I.D. #25454 ' {~'~~ ~t~. i-k4~ w' ~° a i t GOLDBERG KATZMAN, P.C. a eJ ~' ~~ ~,~ ~~, ~t` ~ Y ~i• + ~ i 320 Market Street ~ ` P. O. Box 1268 Hamsburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Plaintiff SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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 them 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. §4904 relating to unsworn falsification to authorities. Date. ALLAN C. BISH P Paul J. Esposito, Esquire ~ °n' ~ ~~~ ~.~ ~~~ ~~ ~ ~f~. ~. ~/ LD. #25454 GOLDBERG KATZMAN, P.C. +it~ ~~ AI)"p(~? 320 Market Street i'~ 1 ~~ ~; ~ , P. O. Box 1268 Harrisburg, PA 17108-1268 .`~ ~ ~ ~+~ ~ , . r (717) 234-4161; (717) 234-6808 (facsimile) ) ~~^tr~" ~ i-• ~1 f s ~ ~,t(,~> ~,~,t~ ~` ` ' Counsel orPlainti ~C..3~~£ d SHANNON BISHOP, IN THE URT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Via first class mail; Acceutance of Service signed by counsel for Defendant, Debra D. Cantor, Esquire, on May 24, 2010 3. (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on October 8, 2010 ; by Defendant on October 25.2010 (b)(1) Date of execution of the Affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver ofNotice in § 3301(c) Divorce was filed with the prothonotary: November 1, 2010 Date Defendant's Waiver ofNotice in § 3301(c) Divorce was filed with the prothonotary: SHANNON BISHOP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-3258 -Civil Term ALLAN C. BISHOP, CIVIL ACTION - LAW Defendant IN DIVORCE DIVORCE DECREE AND NOW, U e i IS- , _ _2 0 1 D , it is ordered and decreed that SHANNON BISHOP , Plaintiff, and ALLAN C. BISHOP , 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. By the Court, J. V ____b , ')r,?Ad Prothonotary as ? a? ? ???` 1r- as -?o ?a?c y,,???/ ? a