The URL can be used to link to this page

Home My WebLink About04-4652 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Wayne Edward Hershey, Jr., Plaintiff : No. CY-i-4lDb':1... GOit-r~ : Civil Action - Law vs. : In Divorce Barbara Jo Hershey Defendant 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 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 the custody or visitation rights of your children. 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 AUMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 OFACE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Wayne Edward Hershey, Jr., Plaintiff : No. 04- 4t..S'L CL>ll~8Ll : Civil Action - Law vs. : In Divorce Barbara Jo Hershey, Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Wayne Edward Hershey, Jr. who currently resides at 386 Strohm Road, Shippensburg, Cumberland County, Pennsylvania, since September 1,1989. 2. Defendant is Barbara Jo Hershey who currently resides at 4170 Orrstown Road, Orrstown, Franklin County, Pennsylvania, since July 17, 2003. 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 December 29,1995 at Hagerstown Courthouse, Hagerstown, Washington County, Maryland. 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 that she be granted a divorce from the bonds of matrimony. Respectfully submitted. \\~~ ~~ H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 I verify that the statements made in this 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. oare,~~ a4ft ~ ~ Wayne Edward Hershey, Jr. (:J r-~ r-~') --kt (.J (", Y \., ~;J -q ....t::- i -- " .-~ ..-1 ...() ,. ;1""""1 0 -- '- C' -- 8 Lr) - ere C). .,.J:: w ~ ~ ff! c.~) -: ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Wayne Edward Hershey Plaintiff vs. Barbara Jo Hershey Defendant : No. 04-4652 Civil Term : Civil Action -. Law : In Divorce AFFIDA vrr OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Barbara Jo Hershey, of 4170 Orrstown Road, Orrstown, Pennsylvania, 17244, certifiied mail, return receipt requested on September 20,2004 and was accepted on delivery by Barbara Hershey on September 22, 2004. , - -1 -1 uJ. CI __~K-~~ - H, Anthony A ams, ,- Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburt~, PA 17257 (717)-532-3270 Sworn to anl~ subscribed this I~J1I' day of~)Gfr-/)7 ff.--- , 2004. /Yl GCOMM()NWEA;:~~NNSYLVAN'A peggy A. GilsOn. Notary Public ShippensbU!Q BorO. Cumberland County My (;ommlsSion expires Aug. 31.2008 Member. Pennsvlvanla A5So~iation Of Notaries s~, ~~.~ ~:3 --.. o .-:> c:::> (''':':'' ....- C::J r'l C) .- - o -1'1 --' ~:C ""T1 r 11 ".~ h1 1'10 ~~; (L) ~ -' .....'. -'Tt '. .on i:.~ () ::"." '""-:'1 -r1 ...... '" .. (...~ r---: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Wayne Edward Hershey Plaintiff : No. 04-4652 Civil Term : Civil Action - Law vs. N, Barbara}6 Hershey Defendant : In Divorce STIPULATION TO AMEND Now come the Plaintiff and Defendant and do state and agree as follows: 1. The complaint and associated pleadings filed in this case have the Defendant's name stated as Barbara ]0 Hershey. 2. The Defendant's name is Barbara H. Hershey and the Defendant has never been known as nor used the name of Barbara ]0 Hershey. 3. The Plaintiff and Defendant agree that the complaint and associated pleadings be amended to correct the name of Defendant to Barbara H. Hershey. Respectfuliy submitted. c--~'-'---~)~~ ~ >- H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 ..:::::.. . . VERIFICATION I verify that the statements made in this statement 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: / / (PJ ~{" ~~cidJ~jl . arbara H. Hershey 1 . VERIFICATION I verify that the statements made in this statement 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: /2/zr/y h / c /. /c:;;(.' ,/ U/ ~ t (~((#V( ,';; (if/;~ . Wayne i:dward frershey ;/:/ .,..... ',;-; ; \ , - -: .J ;---0 ~ ... .\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Wayne Edward Hershey Plaintiff : No. 04-4652 Civil Term : Civil Action - Law vs. : In Divorce Barbara H. Hershey Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 16, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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: /24 y'19' / .~' ,I il/ ? ... v , / ','/ .r _c;"" . j /; ',/1 / ,,',',' ..' ,~,. , .,ta/</ . VJayrre Edward Hershey ~ ~/./ /' /// ~. . f.4~"i~" <',/ ~,/I>~-. j'~ ,) -'it I C !""" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Wayne Edward Hershey Plaintiff : No. 04-4652 Civil Term : Civil Action - Law vs. : In Divorce Barbara H. Hershey Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 16, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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: 116~ ~s ~~~jp.v Barbara H. Hershey (1 (~,.- ---------- .-...\ r',~' . ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Wayne Edward Hershey Plaintiff : No. 04-4652 Civil Term : Civil Action - Law vs. : In Divorce Barbara H. Hershey Defendant 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. Date: 12;;{Y;iy 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. / /' /...' j. / / j -/'./ / , ~',,' . 1,/ -1" ~,.~ W~$Ed~~~;f~;;ey/-.{:;~' .. ,./ ("..~ I" ,~~ \ I:. (.;:.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Wayne Edward Hershey Plaintiff : No. 04-4652 Civil Term : Civil Action - Law vs. : In Divorce Barbara H. Hershey Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SEmON 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. Section 4904 relating to unsworn falsification to authorities. Date: I /IJ'I/~s . T ~#--Q~ JJWh/J/~ Barbara H. Hershey =rr '- r' -.) , .J .Jl ~.~ r-' , ~. .~ ------ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Wayne Edward Hershey Plaintiff : No. 04-4652 Civil Term : Civil Action - Law vs. : In Divorce Barbara H. Hershey Defendant 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on September 20, 2004 and received by Defendant on September 22, 2004. An affidavit of Service was filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff December 24, 2004; by Defendant March 5, 2005. 4. Related claims pending: None. 5. g aintiff's Waiver of Notice was signed on December 24,2004 and was filed l\J 1..\4' t:, a and Defendant's Waiver of Notice was signed January 4, 2005 an is lied herewithin. ~~ H. Anthony Adams,~e' Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532- 3270 .,;:,.' 'i; f'<: 1f.+:i+.i+.1f.i+.i+.i+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1f.""'fOf.'f. i+.'f i+.i+.i+.i+.i+.i+.i+.i+.i+.i+.i+.i+.i+. i+. i+.i+.1f.i+.i+. i+.i+.i+.i+.+. i+.i+.+.i+.i+.+.+.1f.i+.1f.+.i+.+.+.i+.+:i+.i+. +'+'+'1f.+'i+.i+.i+.i+.i+.+'+'+'i+.+'+'i+.i+.~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. Wayne Edward Hershey No. 04-4652 Ci vil VERSUS Barbara H. Hershey DECREE IN DIVORCE AND NOW, Cl~, - -..... Wayne Edward Hershey , PLAI NTI FT, -- .?(.()> , u , IT IS ORDERED AND DECREED THAT AND Barbara H. , DEFENDANT, Hershey ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None } / B' THE co~:~f:~ ATTEST~ . ~ J. ~ ~PROTHONOTARY . .. . Of. Of i+.i+. ... i+.i+.i+.+:i+.+:i+.i+. i+.i+.i+.Ofi+.'f. i+. i+.i+.~'f.i+. +'i+.i+.1f.i+.'fi+.i+.i+.i+.+.i+. i+.i+.i+.+'i+.+:i+.+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i+.i+.i+."'i+. . ~)':2 /-?j;J7 PYI/ 7 ~/U, [""~I/ /~?/ ;Z /f?7ZW;' ~/ /"(/ . )<70/ >:2:." C'l/