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Home My WebLink About05-1598 PAMELA A. SHUGHART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 2005- /s4ff ittJ ADAM C. SHUGHART, Defendant : CIVIL ACTION - LAW NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 32 South Bedford Street Carlisle, Pennsylvania 717-249-3166 PAMELAA. SHUGHART, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION LAW Defendant : NO. 2005 - : DIVORCE ADAM C. SHUGHART, COMPLAINT Plaintiff, PAMELA A. SHUGHART, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, PAMELA A. SHUGHART is an adult individual residing at 2215 Circle Road, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, ADAM C. SHUGHART, is an adult individual residing at 730 Conodoquinet Avenue, Carlisle, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married in Cumberland County Pennsylvania on March 15, 2003 in Philadelphia, Pennsylvania. 4 Both Plaintiff and Defendant have resided continuously in the Commonwealth of Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of this action. 5 There have been no prior actions of divorce or for annulment between the parties. 6 The marriage is irretrievably broken. 7 The Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing her from the Defendant. BROUJOS & GILROY, P.c. By Hubert X. Gilroy, Es Attorney for Plaint' f Broujos & Gilroy .c. 4 North Hanover Street Carlisle, P A 17013 717-243-4574 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. ~)'2'2~ Date I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. 3'27,05 Date I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. 3 ~2J.-OS Date \~ - -..... ~ '-.J \J W ~ ~ ~ l" \) v-.. ~ ."\ '-J" ~ ;\ \ "0 \.f'>:\ ~ ~.J ~ ~ ~ ~\~ ~ ~ ""- ~ ~ ~ (i C ~.:.:.r ~ c-::J. 'iJ. .,c. :r:~ '/) r--') ~ ~ .-\ :~r: -r'\ r;"\ 1'-.;0 -r' ,"l\ ,,"-0 (~::., \, v,e. :~;~f~~ ':~;;\ '{l :;J ::.:: -0 ~~ r:-? cJl o ,- PAMELA A. SHUGHART, Plaintiff : I]~ THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2005-1598 CIVIL TERM ADAM C. SHUGHART, Defendant 1:'01 DIVORCE AFFlDA VIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330i(c) Of THE DiVORCE CODE 1. A Complaint in divorce under Section 3301(C) ofthe Divorce Code was filed on March 24, 2005. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about March 25, 2005. 3. The marriage of the Plaintiff and Defcndant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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 protho.wtary. 7. I have been advised of the availability (If marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: \ ~- 2. ~ -~~ ~ () i::; _) ;5~~ l~ 1 ~'-: ---;;> ~ ' ''; t/;, ~::: '-'- ~~~~ -- :&:~~: ~,; -.( .... = = en ..".. C5 ..0::; I t.J () -n :I'~ nl..,..!...l .- -om :nn '::".) T "'le> ~.~2~ OfTl --I ~D -< :t."'" :x 'f? N W PAMELA A. SHUGHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 2005-1598 CIVIL TERM ADAM C. SHUGHART, Defendant IN DIVORCE AFFlDA VlT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THF mVORCF CODF 1. A Complaint in divorce under Section 3301 (C) of the Divorce Code was filed on March 24, 2005. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about March 25, 2005. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: II /S-~S- I / // e~~ Adam C. Shuglnl'ij; e endant @~i>QJJf9J f"',., C) Z:_~; () -1'1 --, T Fi'1 ._c;",W ::~ !'-) \.0 en c:: - ~ PAMELA A. SHUGHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2005-1598 CIVIL ADAM C. SHUGHART, Defendant CIVIL ACTION - LAW IN DIVORCE 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. Defendant acknowledged receipt and accepted service of the Complaint on or about March 25, 2005. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff on October 28, 2005; by Defendant on November 5, 2005. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: November 3, 2005 Date Defendant's Waiver of Notice was filed with the Prothonotary: November 29, 2005 Date: ()-7- 6J H ert X. Gi oy, Esquire Attorney ~ Plaintiff Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 --~<.. ._-------~,",-" .~-._--,_.".>~.~ ,+:,+;;f.:+. . . . . . . . . . . . . . , . . . . . . . . . . . . . . . n :+.:+.:+.:f.:+.,+: :+.:+. "':+. '+::+.:+.:+.'+::+.:+. :+.:+.:+.:+.:+.ItO'+::+: :+. '+::to '+:+.:+.:+: '+:+.:+.:+.:+. "':+. . . . . , . , . . . . .. .n . :f.:+. 'to'+::+': 'f.:+' .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PEN NA. STATE OF Pamela A. Shughart, No. 2005-1598 VERSUS Adam C. Shughart, . . . . . . . . , . . . , . . , . DECREE IN DIVORCE . . . + . + . + , + + . . , + . + . . + + , . , + . + . + + + . . + + . . + . . + + , + + + + + , + + . + , + +:+.:+::+.:+.:+. :+. AND NOW, "))~~ J~~ 'Ufo-S- , IT IS ORDERED AND Shughart Pamela A. , PLAINTIFF, DECREED THAT Adam C. Shughart _' DEFENDANT, AND 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; No claims pending. 04~ :c!t . .~ , ~ ,/P"O'HONOO'"' :+.:+.:+.:+:+.:?:+.::+.:+.::+. :+.:+.:+.:+. '+':+.:+.: H+ :+.::+.::+':t::+.:+':+'::+.: :+.:+. 'to:+.::+.: Of.:+':+. + :+::+.::+.:+.::+.::+.:+.:+.:+.:+. +H .H H + . + . + . + + , + + + + + + + . + + . . . . + . . . . + . . + . . . + . . . . + . . . + . + . + . . + . . + . + . . + . , . . J. . . . + . . + + . . . . + + . . + . . + + + . :+.:+.: :+.+ ~;? ~j7;>-$?rW T~U-, Xl 1/ (/ ~ ~ .z /}fT?:n1t~)T1J 5/7 ,1/ ("/ . . ,