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Home My WebLink About14-4200 Andrew C. Sheely, Esquire 127 S. Market Street P.O: Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) PATRICIA B. PUTT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW MARK D. PUTT, 14 - VIM) Defendant IN DIVORCE M �C. T'£ NOTICE TO DEFEND AND CLAIM RIGHTS - You have been sued in Court. If you wish to defTnd against ta the claims set forth in the following pages, you must e prompt action. You are warned that if you fail to do so, the 'lase may proceed against you and a decree in 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 with 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 at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387 . 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 ( 717 ) 249-3166 BY Andrew C. Sheely, Es ire + PA. I.D. No. 62469 3.73, 7t� /�`� 127 S. Market Street P.O. Box 95 4- a Mechanicsburg, PA 17055 ,l 717 697-7050 Attorney for Plaintiff IS • / Ce 1';�- �� ' Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) PATRICIA B. PUTT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. �CIVIL ACTION - LAW � a MARK D. PUTT, 14 - �MU Defendant IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) PATRICIA B. PUTT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW MARK D. PUTT, 14 - Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is PATRICIA B. PUTT, an adult individual who currently resides at 13 West Main Street, Shiremanstown, Cumberland County, Pennsylvania. 2 . Defendant is MARK D. PUTT, an adult individual who currently resides at 13 West Main Street, Shiremanstown, Cumberland County, Pennsylvania. 3. Plaintiff was a resident of the Commonwealth of Pennsylvania for at least six ( 6 ) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married in Minersville, Pennsylvania, on October 8, 1994. 5. There have been no prior actions of divorce or annulment between the parties. 6 . Neither party is a member of the armed forces of the United States of America. 7 . Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request i 4 that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8 . Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10 . After ninety ( 90 ) days have elapsed from the date of filing and service of the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11 . This divorce action is not collusive. 12 . The parties separated on or about January 6, 2014. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety ( 90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT II -_DIVORCE - 3301 13 . Paragraphs 1 - 12 are incorporated herein as if set forth at length. 14 . After a period of two (2 ) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. 2 WHEREFORE, if two (2 ) years have elapsed from the date of separation and Plaintiff has filed her affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. COUNT III - CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 15 . The allegations in Paragraphs 1 - 14 are incorporated herein and made a part hereof. 16. Plaintiff and Defendant are the owners of various personal property, motor vehicles, bank accounts, retirement accounts, retirement assets and insurance policies acquired during their marriage. 17 . Plaintiff and Defendant are the owners of real property acquired during their marriage. 18. Plaintiff and Defendant have acquired various marital debts during the period of their marriage. WHEREFORE, Plaintiff requests your Honorable Court equitably distribute the parties marital property, including marital debt, and including any such further relief as the Court may determine equitable and just. Respectfully submitted Date:Date: July �� 2014 J&1"�4/ 0 QQ ndrew C. eely, E -r-e Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 South Market Street Mechanicsburg, PA 17055 717-697-7050 3 VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: July f 2014 Patricia B. Putt Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) PATRICIA B. PUTT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS . CIVIL ACTION - LAW MARK D. PUTT, 14 - Defendant IN DIVORCE AFFIDAVIT Patricia B. Putt, 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 Domestic Relations 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.A. Section 4904 relating to unsworn falsification to authorities. July /J' , 2014 k&-a Patricia B. Putt Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) PATRICIA B. PUTT, Plaintiff vs. MARK D. PUTT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 14 - 4200 IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF CUMBERLAND CD ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above -captioned matter to be served upon MARK D. PUTT, Defendant, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt card on July 22, 2014. 41; AN REW C. SHEEL SWORN to and subscribed before me this c2c.,,Ickday of July, 2014. Notary Public My Commission Expires: SENDER: COMPLETE THIS SECTION • 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 card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Jnart Or PV /edri i ccf Def/U er FDPA')O,?E55Er O/Wy 60e511- %P70101 stfee 567/re P -1,(7,5 7.06d4, P - / COMPLETE THIS SECTION ON DELIVERY A. Sign• . r: X / � v ■Agent 0 Addressee B. Receiv d • Pri tedm C. Da D. Is delivery address different from Item 7� If YES, enter delivery address below: of Deli ery 0 Yes 0 No 3. ,,v Service Type t* CertiRed Mail ❑ Registered ❑ Insured Mail ❑ Express Mail ❑ Retum Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number jf (Transfer from service label) 11: 7013 2630 0000 6719 ,4553: PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540