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Home My WebLink About05-0288 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. OS' - dJ>? C~oLC-T~ JEFFREY SHEARER v. : CIVIL ACTION - LAW MAUREISA SHEARER : IN DIVORCE 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 wamed 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 of 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. A list of marriage counselors is available in the Office of the Prothonotary. 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. 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, P A 17013 (800) 990-9108 or (717) 249-3166 JEFFREY SHEARER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 05 - -2P]> C;u~LI8L~ v. : CIVIL ACTION - LAW MAUREISA SHEARER, : IN DIVORCE Defendant COMPLAINT DIVORCE UNDER SECTION 3301(c) and (d) OF THE DIVORCE CODE AND NOW COMES Plaintiff, Jeffrey Shearer, by his attorney, Jay R. Braderman, Esquire, and respectfully represents as follows: 1. Plaintiff, Jeffrey Shearer, is an adult individual residing at 589 Trail Court, Etters, York County, Pennsylvania, 17319. 2. Defendant, Maureisa Shearer, is an adult individual residing at 423 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 17, 2004 in Etters, York County, Pennsylvania. 5. There have been no children born ofthis marriage. 6. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301 (d). The marriage of the parties is irretrievably broken. The date of separation was on or about December 24, 2004. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a Decree in Divorce from the bonds of matrimony. Date: 2 JEFFREY SHEARER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW (!u:;>~ C ~02-"'1 : NO. Df;- v. MAUREISA SHEARER IN DIVORCE Defendant AFFIDAVIT JEFFREY SHEARER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4909 relating to unsworn falsification to authorities. rtJfr ~ ~~ JE Y<8'REA R VERIFICATION Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein made are subject to the criminal penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. Date: 01/ 1 0 I~s (1)/ ~~ ~arer I verifY that I have reviewed this form with my client and to the best of my knowledge the allegations herein are true and correct. Attorney For Plaintiff D -{Q. i - 1 --a ~ ....... ~ () (-:1 ", CJ') ['.- C,) 0 W C:.,:J ~ (:....,., -n c.r, Ii' -cJ s ::J ~ CI) ~ -<;,- ... <-.) b :-') - ;t (',) -; "---'-- JEFFREY SHEARER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff : NO. 05-288 Civil T\~rm v. : CIVIL ACTION - LAW MAUREISA SHEARER, : IN DIVORCE Defendant AFFIDAVIT OF CONSEN1: 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 13,2005. 2. The marriage between 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 understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses in 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. Section 4904, relating to unsworn falsification to authorities. Date: 611K{or- {Uj~ c. ./J..~J.\.)I'-- ~~er SSN: 162-66-0196 0 "" ~:~ = 0 (;;;:) c.n -n '- :r." ~i G1- N .- yQ:1 N a;:s "";'J (~:;~~ .:J -,.", ;5~~ f::- -;.., 2:' 'i! (if-rl --j ,r:- :;j - ~ N JEFFREY SHEARER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 05-288 Civil Term v. : CIVIL ACTION - LAW MAUREISA SHEARER, : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l(c} OF THE BlVORCE CODE 0 ,..." = 0 c =, ";:-p en ." , '- -l , c: :r:.." ::r.':: rnr '" 'oe;; -b -- N OJ. ..-je> 3! ~T: =n _\1.. '"52c) c." <5rn ::::1 .r:- ~.i5 N .< Defendant 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 in 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 understand 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. S4904 relating to unsworn falsification to authorities. Date: JIA~ III ).O~ ~ rUA"-",, (7 ~"'- ~he~r v SSN: 162-66-0196 JEFFREY SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-288 Civil Term v. : CIVIL ACTION - LAW MAUREISA SHEARER, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 13,2005. 2. The marriage between 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 understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if! 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. Section 4904, relating to unsworn falsification to authorities. Date: 7. / 7 ,a5 t21v~/~ lhMA./JA . Maureisa Shearer SSN: 278-80-7064 .-,~ ~ !~'::.~. (") c 1"-) <::::) ~ (,:';-1 o "'11 --I I_p i'nF i:I,~ ['-,,) C L ( j --r-, .:' -fl ','0 ~,,::,~ fT', :=':I ......i:~. '.:.1 :< --','.,~ r-...) ..f'.:"" IT" ["'- IT" 0 r:Q rn .....:.i Ll1 ..J ..lJ 0 0 "':J 0 1 0 0 r:Q ..lJ r-'l rn 0 0 ["'- os- - ~f? Ciu~l /~W1 u.s. Postal ServiceTM CERTIFIED MAILTM REC IPT (Domestic Mail Only; No Insurance /:olterage Provided) FEDERAL SQUARE STATION HARRISBURG, Pennsylvania 171089998 4134870115-0094 01/18/2005 (717)238-2202 11:11:12 AM Certified Fee .--- Sales Receipt Sale Unit Qty Pri ce Final Price Return Reciept Fee $1 7') (Endorsement Required) .' .~ Restricted Delivery Fee *':.': . ..;[.1 (Endorsement Required) , Product Description -----_._---~-----_.._--~ $0.60 $3.50 $1.75 $2.30 70031680000656380979 NEW CUMBERLAND PA 17070 First-Class Restricted Delivery Return Receipt (Green Card) Certified Label Serial #: -------- -------- Total Postage & Fees $ $.g .15 Issue PVI: $8.15 $8.15 Total: Paid by: Personal Check $8.15 Bill#: 1000601216368 Clerk: 12 ," l - All sales final on stamps id postage. guaranteed se ices only. 'ou for your b iness. L ^. .... SENDER, )0,]PLE If 1"'") ~I CTlON ~ . . . . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. . Print your name and address on the reverse . so that we can return the carcI to you. . Attach this card to the back of the mailpiece, or On the front if space permits. 1. ArtiCle Addressed to: r<\l:.u...("e.\~CA S\.e.cSe..1 ~ ~3 Gc.0-1(""'1 \==\ 0~~ ~w CU~ be(\Df"'~. ~ \ 1-0 -=to 3~' Type itied Mall 0 Express Mail o Registered 0 Retum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) as 2. Article Number (rransfer from service label) PS Form 3811, AugUSt 2001 7003 1680 0006 5638 0979 Domestic Return Receipt 102595-02-M-1540 CERI'IFICATE OF SERVICE (jj )". ~~ ~u 5(') S,' ~~~? :~ .J;- ....~ " , ,_I , N o -0 :t:- ry J JEFFREY SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 05-288 Civil Term v. : CIVIL ACTION - LAW MAUREISA SHEARER, : IN DIVORCE 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: January 30,2005 by U.S. Certified Mail, Restricted Delivery, Return Receipt Requested, No. 7003 1680000656380979. A copy of which is attached hereto. 3. Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: June 18, 2005 by Plaintiff. By Defendant: July 17, 2005. Defendant's Affidavit of Consent is being filed simultaneously with this Praecipe. Plaintiff s Affidavit was filed with the Prothonotary on June 22,2005. 4. There are no related claims pending. 5. Indicate date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and attach a copy of said Notice under Sections 3301(c) or 3301(d)(1)(i) of the Divorce Code: Plaintiffs Waiver executed on June 18, 2005. Defendant's Waiver executed on July 17, 2005. Defendant's Waiver is being filed simultaneously with this Praecipe. Plaintiff s Waiver was filed with the Prothonotary on June 22, 2005. ./l Date: i Attorney For Plaintiff /'..J c::~) t..::::J C.n C- , r-'" o -/1 :.:;:l (:1?J ,~~ ;".:::; rTl ~~! :.D --< r" CJ -"J ~) .1:-- . . . . . . . . . . . . . . . . . , . , , IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY STATE OF . . JEFFREY SHEARER . . . . , VERSUS . . . MAURElSA SHEARER . , , . , . . . . , . . . . . . . . . . . . . . . . . . . AND NOW, PENNA. No. 05-288 Civil Tenn DECREE IN DIVORCE :r Jq d7 G:{d:U ~-O.,vJ. .r I ,JUt) ,IT IS ORDERED AND DECREED THAT Jeffrey Shearer , PLAINTIFF, AND Maureisa Shearer , DEFENDANT, 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; ,J O~ t: , . . . . . . . . . . , - PROTHONOTARY . . . . , . ~. . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . , . , . . . . . . . . J. . . . , . . , " . L ~ ~ ~/,t. 50 '/J-t' -L ~'~ ;~4lF'J SOS(L .. ",,". *' " ...,)..~:..,,: .