The URL can be used to link to this page

Home My WebLink About10-3679F:\F1LHS\CGrnts\ 13889 Shrawder\ 13689. I .DivorceComplaint Revised: 613/10 4:30PM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 2Qi0 Ji?~ _~ Pry I : 4l; & FALLER CU~,v'~.F .~, =, ~~ ~~:~:~NTY Phi ilk vS`I'lt~,~'~"~~;r~ DAWN M. SHRAWDER, Plaintiff v. CHRISTOPHER A. SHRAWDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010- ..~l.'~' ~ (.. l vc L CIVIL ACTION -LAW IN DIVORCE 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 maybe 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 A $'352.00 ~L~/y~ CK~ z2.54[~ ~ ~~ ~~~~ DAWN M. SHRAWDER, Plaintiff v. CHRISTOPHER A. SHRAWDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010- : CIVIL ACTION -LAW IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) or 3301 (D) OF THE DIVORCE CODE 1. Plaintiff is Dawn M. Shrawder ,who currently resides at 110 West Ridge Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Christopher A. Shrawder, who currently resides at23 Partridge Circle, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 6, 2004 in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage between Plaintiff and Defendant. MARTSON LAW OFFICES Date: Hubert X. Gil y, Esquire 10 East Hi Street Carlisle, 17013 (717) 2 -3341 Atto evs for Plaintiff VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. /'~ /~ DAWN M. SHRAWDER F:\Clients\I38119 Shrawdcr\12689.I.AFF DIVORCE Created: 611/06 8:50AM Revised: 1 /9/ 12 11:46AM Hubert X. Gilroy, Esquire I.D. 29943 z MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER z;0 -O MARTSON LAW OFFICES _ G 10 East High Street ' Carlisle, PA 17013 zcc:) (717) 243-3341 z W Attorneys for Plaintiff -< co . c DAWN M. SHRAWDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ; NO. 2010-3679 CIVIL ACTION - LAW CHRISTOPHER A. SHRAWDER, Defendant IN CUSTODY AFFIDAVIT OF CONSENT L A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on June 4, 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. 3. 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. § 4904 relating to unsworn faisifica6on to authorities. Date: Laa?'A M - <-?Vac - Dawn M. Shrawder, Plaintiff F:1Chents\13889 Shrswder\13889.I.Waivu DIVORCE Created: 6/1/06 8:50AM Revised: 1 /9/ 12 11: 47 AM Hubert X. Gilroy, Esquire I.D. 29943 MARTSON DE'ARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff C-) C "L7MCC = M x:X) r- U) t r-= c? ?C? a P?J 0 -v a °-* n~' DAWN M. SHRAWDER, Plaintiff v CHRISTOPHER A. SHRAWDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3679 CIVIL ACTION - LAW IN CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §33010 AND § 3301(_d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I,understand that I may lose rights concerning alimony, division ofproperty, 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 waiver 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. ?) r Date: /'9 ' zof ,Z ?? ??? • J/t ?-, Dawn M. Shrawder, Plaintiff DAWN M. SHRAWDER, Plaintiff V. CHRISTOPHER A. SHRAWDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYlm)VA;NIA, CIVIL ACTION -LAW =m rr i- NO: 2010 - 3679 C4 CE IN DIVOR DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed on June 4, 2010. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: j A 1 I a `14 &,Z? C STOPHER A. SHRAWDER Defendant DAWN M. SHRAWDER, Plaintiff V. CHRISTOPHER A. SHRAWDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO: 2010 - 3679 IN DIVORCE C) C -OZ rn M xrn z;70 cn z r? 3??? 0 C*)` WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33010 OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. c.J z r-n r- C Z r?r 4 p .S^ 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: o? C OPHER A. SHRA DER Defendant NIP F:\Clients\ 13889 Shrawder\ 13889. L PraeMansmit Created: 6/1/06 S:SOAM Revised 1/23/12 1.25PM , C) n 2OU12 JAN' 23 : ' 3: 0 Hubert X. Gilroy, Esquire UMBERLAl?• D C,UUNT 'f I.D. 29943 PENNSYLVANII A MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DAWN M. SHRAWDER, Plaintiff V. CHRISTOPHER A. SHRAWDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3679 CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) or 3301 (d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: June 11, 2010 via Certified Mail, Restricted Delivery, as per attached Exhibit `A,. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; January 9, 2012; by the Defendant; January 6, 2012, (b)(i) Date of execution of the Plaintiffs affidavit required by § 3301(d) of the Divorce code: (b)(ii) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: NONE. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301(d)(1)(i) of the Divorce Code: (Complete either (a) or (b).) (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 Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 9, 2012 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 13, 2012. Date: January ?, 2012 MARTSON LAW OFFICES L By ubert X. Gilro Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 1 I L? L_ 3 ?Ga (o oiled Fee ';Mu in Ai iceipt Fee 3 (Enc xnenieid Required) 3 Fie>triel&J Delivery Fee (En(arsen e14 Required) 3 Tctal Postage & Fees can''T--_ 3 aire9tApi?rc _...___ . 3 orPO8cu No. I Corrlpleto itf ms t, 2, and & Item 4 If 13estrtcted De1hrery Print your neune and address so that we can return the ca • Attach this card to the back or on the front if space pi3m 1. Article Addreltmd toi C?I h s'r? p r^? a duplicate return receipt, a U ostmark on your Certified Mail receipt is required. ------- ¦ For an atldM0ltlfeal! deliv&41A y be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mailpiece with the endorsement "Restricted Delivery". i ¦ If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: save this receipt and present It when making an Inquiry. PS Form 3800, August 2006 (Reverse) PSN 7530-02-000-9047 Article Number i ! . (ftrisrerffims ivloiIiI ' 7010 0290 3001 7803 4095 'S Form 3811, February 2004 Domestic Return Receipt UNITED STATES POSWU. SERVICE I First-Class Mail Postage $ Fees Paid USPS Permit No. ^ 4 • ,ender. Please print your name, address, and ZIP+4 in this box • MARTSON LAW OFFICES 10 East High Street Carlisle, Psi, 17013 1111IIIM11111,,,,III 1 1111111111 1"111111 11111111111111111111 EXHIBIT 'A' Via. ' r Vet Certified Mail Provides: _ ¦ A mailing receipt loom ?- a A unique identifier for your mailpiece ¦ A record of delivery kept by the Postal Serv 4 igQ fort P9Y J? 1 :; o\ Lif15 A \ S, Important Reminders., I, xdme ' I • Certified Mail may Y be cqRpIW with First-Class Mails or Priority Mails. t ?! cG j ¦ Certified Mail is not available for any class of international mail. J) ¦ NO INSURANCE CQYyERAG?I ?pROVIDED with Certified Mail. For v valuables, please conbrder Inst d f Registered Mail. • For an additional fee, a Return It may be requested to provide proof of I fob delivery. To obtain Return Recei e, please complete and attach a Return Receipt (PS Form 3811) to the article and add applicable postage to cover the fee. Endorse mailpiece"Return Jllocoot Requested". To receive a fee waiver for IN THE COURT OF COMMON PLEAS OF DAWN M. SHRAWDER CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER A. SHRAWDER NO 2010-3679 DIVORCE DECREE AND NOW, it is ordered and decreed that DAWN M. SHRAWDER plaintiff, and CHRISTOPHER A. SHRAWDER , 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 claim;, remain indicate "None.") NONE:. By the Court, Attest: J. Prothonotary / -.a 6 - 1.2- - ?eh'? /office Copy mgll eal 71, tbp y *9,91 le C 7, rrD y X,,Ilelr