HomeMy WebLinkAbout01-7249PAMELA K. SCHAFFNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 2001
JOHN MICHAEL SCHAFFNER,
Defendant
CIVIL ACTION - LAW
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 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 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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
PAMELA K. SCHAFFNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 200~- '/:Lq ct O~;tJ "~
JOHN MICHAEL SCHAFFNER,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. The Plaintiff is Pamela K. Schaffner, an adult individual whose mailing
address is 713 Drexel Hills Blvd., New Cumberland, Cumberland County,
Pennsylvania 17070, and whose social security number is 198-54-9686.
2. The Defendant, John Michael Schaffner, is an adult individual, whose
current address is 728 15th Street, New Cumberland, Cumberland County,
Pennsylvania 17070, and whose social security number is 191-54-1980.
3. Plaintiff and Defendant were married on December 29, 1990, in New
Cumberland, Cumberland County, Pennsylvania.
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania
for a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff is a citizen of the United States and Defendant is a citizen of the
United States.
7. There has been no prior action for divorce filed in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are two minor children bom of the marriage; namely, Nico John
Schaffner, born June 17, 1991, and Cole Anthony Schaffner, born June 5,
1996.
10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiffrespectfully requests your Honorable Court to grant
a Decree in Divorce.
Date:
December 27, 2001
Respectfully submitted,y
/ Diane M. R~ ic~_q~S~luire
1017 North Front Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
VERIFICATION
I verify that the statements made in this Complaint in DJ. vorce
are tree and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
Date: 12/27/01
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