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HomeMy WebLinkAbout04-4083ROBERT B. SHEAFFER, PLAINTIFF CHEVONNE T. SHEAFFER, DEFENDANT IN THE COURT OF CO~94ON PLEAS ~RLANqD COUNTY, PENNSYLVANI3% 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. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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 ~NY OF THEM. YOU SHOULD TAKE THIS PAi~ER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR C~/qNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA/q GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9f08 NOTICE OF AVAII2%BILITY OF COUNSF~LING TO THE WITHIN~NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is .available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ROBERT B. SHEAFFER, PLAINTIFF Vo CHEVONNE T. SHEAFFER, DEFENDANT IN THE COURT OF COFR4ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Robert B. Sheaffer who resides at 48 Kingswood Terrace, Carlisle, Cu/nberland County, Pennsylvania 17013. 2. The Defendant is Chevonne T. Sheaffer who resides at 600- A N. Baltimore Street, Mt. Holly, Cumberland County, Pennsylvania 17065. 3. The Plaintiff and Defendant have been a bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 8, 1999, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate June 2, 2001. and apart since 8. There were two children born of this marriage, Brianna Nicole Sheaffer, born 03/16/98 and Ashley Marie Sheaffer, born 05/2i/00. 9. The Defendant is not a member of the United States or any of its Allies. 10. The Plaintiff has been advised of the Armed Services of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 11. Plaintiff :requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION and correct. I understand subject to the penalties of falsification that false 18 Pa. C.S. to authorities. verify that the statements made in this Complaint are true statements herein are made 4904, relating to unsworn Date: ~-77-0 "/ ROBERT B. SHEAFFER, PLAINTIFF CHEVONNE T. SHEAFFER, DEFENDANT IN THE COURT OF COb94ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE NOTICE TO THE DEFENDANT 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. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 2, 2001 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: ~3/~___RO~ert B. Sheaffer ROBERT B. SHEAFFER, PLAINTIFF Vo CHEVONNE T. SHEAFFER, DEFENDANT IN THE COURT OF CO~4ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 - 4083 CIVIL IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that Notice of Intention To Request Entry of Divorce Defendant's Counter-Affidavit Under Section 3301(d) of Code was served upon the Defendant by depositing the same in United States mail, first class, postage pre-paid on September 2004, to the address to which he received the complaint in divorce. The envelope was not returned by the postal authorities. Plaintiff's Decree and the Divorce the 13, Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA (717) 731-1461 17011 ROBERT B. SHEAFFER, : PLAINTIFF : CHEVONNE T. SHEAFFER, : DEFENDANT : IN THE COURT OF CO~94ON PLEAS CUMBE~ COUNTY, PENNSYLVANIA NO. 2004 4083 CIVIL IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified Affidavit depositing the on August 17, Service, 2004. copy of the Complaint in Divorce and Plaintiff's under section 3301(d) was served upon the Defendant by same in the United States mail, postage pre-paid, 2004. As indicated by the signed Acceptance of the Complaint was received by the Defendant on August 24, Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ROBERT B. SHEAFFER, PLAINTIFF V. CHEVONNE T. SHEAFFER, DEFENDANT IN THE COURT OF CO594ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE ACCEPTANCE OF SERVICE I, Chevonne T. Sheaffer, accept service of the Divorce Complaint in the above captioned matter. 600-A N. Baltimore Street Mt. Holly , PA 17065 DE FENDANT ROBERT B. SHEAFFER, PLAINTIFF CHEVONNE T. SHEAFFER, DE FENDA/qT IN THE COURT OF CO~ON PLEAS ~ER/~Z~ND COUNTY, PENNSYLVANIA NO. 2004 4083 CIVIL IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: CHEVONNE T. SHEAFFER You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit. Therefore, on or after October 4, 2004, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter- affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. Lawyer Referral Service Cumberland County Bar Association 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ROBERT B. SHEAFFER, : PLAINTIFF : CHEVONNE T. SHEAFFER, : DEFENDANT : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not: oppose the entry of a divorce decree. (b} I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken, 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this are true and correct. I understand that false are made subject to the penalties of 18 Pa,C.S. unsworn falsification to authorities. counter-affidavit statements herein 4904 relating to Date: CHEVONNE T. SHEAFFER ROBERT B. SHEAFFER, PLAINTIFF Vo CHEVONNE T. SHEAFFER, DEFENDANT IN THE COURT OF COI~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d) (1) of the Divorce Code. 2. Date and manner of service of the complaint: August 24, 2004, Acceptance of Service by Defendant. 3. (a) (1) Date of execution of the affidavit required by section 3301(d) of the Divorce Code: August 17, 2004; (2) Date of filing and service of the plaintiff's the respondent: Filed on August 17, 2004, served affidavit upon August 24, 4. 5. file U.S. Mail, 2004. Related claims pending: None Date and manner of service of the notice of intention to praecipe to transmit record, a copy of which is attached: September 13, 2004. Thomas D. Gould Attorney for Plaintiff IN THE COURT OF COMMON PLEAS ROBERT B. SHEAFFER, Plaintiff VERSUS OF CUM BERLAND COUNTY STATE OF PENNA. CHEVONNE T. SHEAFFER, NO. 2004-4083 CIVIL _, z o____o4 Defendmnt DECREE IN DIVORCE DECREED THAT ROBERT B. SHEAFFER AND CHEVONNE T. SHEAFFER ArE DIVORCED FROM THE BONDS OF MATRIMONY. .., IT IS ORDERED AND , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JUF~ISDICTION OF THE FOLLOWING CLAIMS WHiCh HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ATTEST: . ~ _ / J.