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Home My WebLink About05-2430 MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA ~, _ LC-.-- NO. 0:;- d4.JD LIl"" 1t4....'( IN DIVORCE HOLLY C. STOUFFER, 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 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 grounds 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 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 MAYBE 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, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES. P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. OS- ~ ~430 C/OL '---r~"'l IN DIVORCE HOLLY C. STOUFFER, Defendant COMPLAINT IN DIVORCE UNDER SECTION 330l( c) OR 330l( d) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Michael P. Stouffer, by and through his attorneys, Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: I. Plaintiff, Michael P. Stouffer, is an adult individual presently residing at 178 Creek Road, Newville, Cumberland County, Pennsylvania, since August 2004. 2. Defendant, Holly C. Stouffer, is an adult individual presently residing at an unknown location in the Shippensburg, Franklin County, Pennsylvania, area since August 2004, with a mailing address of 15 Milesburn Road, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on February 14, 2002, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since February 2003. 9. The Plaintiff requests the court to enter a decree of divorce. WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPEN5BURG, PA 17257-1397 1 WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C. By: /{;JJ /J ";I( / ' ( o--c/:'/.[>! Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID # 49634 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 VERIFICATION 1 verify that the statements made in the foregoing Complaint in Divorce are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa c.s. 9 4904, relating to unsworn falsification to authorities. Dated: o ~,Io5" /-2ons- t / WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW ~ 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 ~ ~ C) -- c~ N 7tL ...(J ~ C> - ~ l.rJ ~ 6"" () I.)-J D ~ ..0 c; ::t) t:- ~ \--"\ '~~?) ~" -" - C"i, .-\ .~'~" -<,-; \,;-; ':~:.:~) ~?: r:-? LJ'''~ ::'~;~;f', ~ -':'1 -.::c:. v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term MICHAEL P. STOUFFER, Plaintiff HOLLY C. STOUFFER, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Patricia A. Frey, being duly sworn according to law, deposes and says that on May 23, 2005 a true and attested copy of Divorce Complaint and Notice to Defend and Claim Rights was served upon the Defendant, Holly C. Stouffer. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Holly C. Stouffer 7 A Mainsville Road Shippensburg, P A 17257 The return receipt signed by the Defendant is evidence of delivery to her and is attached hereto as "Exhibit A." ;J~ A L Patricia A. Frey d- Sworn to and subscribed before me this 25th day of May, 2005. ~~ fl. Tcms2 Notary Public I HOWIW. SIAL ~L 10ME Holary NlIc lI.._1ll'~~~ Mv CommlssIM bDirois ./un 7. 2008 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 II v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term MICHAEL P. STOUFFER, Plaintiff HOLLY C. STOUFFER, Defendant IN DIVORCE PROOF OF SERVICE LJ'l n.J '" '" rn lr ;r '" Cl Cl Cl Cl Cl Cl LJ'l Cl U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage ProvIded) lo\'i!q /\,0 Po,tage $ .&,0 -'- .. ..~ "... " . l. ~ . fl. Certiiied Fee ~. 30 ;J:.,..--....,....' MAY P~.'" Return Aeciept Fee ,. S- if H." {Ef\OOrsement Required) Restricted Delivery Fee 2W!5 / (Endorsement Required) "---"" $ 3.15 , ~ Total Postage & Fees rn o Sent To Cl Mrs. Holly C. Stouffer P- SiiB"ei..A'jifiilo:;....-.h---------..-----.-------.-------.--..-----------.------..------ orPOBoxIVo15 Milesburn Road cny;"Siiri8;zip+4---------UOh_-------------------------------.-.-...._-------------- Shi 1. Article Addressed to: Mrs. Holly C. Stouffer LS lKle..b..... Ihrlid 'lit /lil(' ~.~ '1t!(I!t Shippensburg. PA 17257 3. Service Type W Certified Mail o Registered o Insured Mail o Express Mail :D!f Return Receipt for Merchandise o C.O,D. 4. Restricted Delivery? (Extra Fee) 'Xl Ves 2. Article Number (Transfer from service label) PS Form 3811 . August 2001 7003 0500 0000 8493 8825 Domestic Return Receipt 10259S.02-M.1540 EXHIBIT "A" WEIGLE & ASSOCIATES. pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 (') "'" \---. ~ ,=., ~:/~ " :'''7J .-, .~ ".' , ~, _I >c: '-:? l~ --:C" ~ ;~ .),.- _I ..< MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term HOLLY C. STOUFFER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 330I(c) of the Divorce Code was filed on May 1 I, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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. S 4904 relating to unsworn falsification to authorities. Dated: ~/'),."'I/OS . WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 n r-> 0 c.,) l C::~J -, I I.-jl cn ..... =1: "T1 r',". [11 r 'J rr I C; N , (-') ?:-.,...", ~~i; ) . n C:':j ) , -,,~ Cl ::~ , 0") .., MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term HOLLY C. STOUFFER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on May 11,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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. ~ 4904 relating to unsworn falsification to authorities. Dated: q- q - OJ ~o~r,~~end~ WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 ,-) I'::;) :.::> ,';_.~.~ -n I.:,,,'" ",-'"} :? r'il .., (..,J , ;> ..,.~ <. ~< -, MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term HOLL Y C. STOUFFER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER II 3301(c) AND II 3301(d) 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! 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. ~ 4904 relating to unsworn falsification to authorities. Dated: o/~/6S"" MiC~~~d WE'GLE & ASSOCOATES, Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET _ SH'PPENSBURG, PA 17257.1397 C) C~ r-' ~...:::r '.:::;:1 (;r1 (~ r',--' 'J o -"11 .-1 1~ [-,;-;'1 "8 I ['c S:~J, -:rJ ,""-., j:;-/\ :;.:"" -'- cs <.0 cD <.-, ::< MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term HOLLY C. STOUFFER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER II 3301(c) AND ll3301(d) OF THE DIVORCE CODE I. 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. ~ 4904 relating to unsworn falsification to authorities. Dated: 9 - q -(\S- ~L. ~~U. Holly C. Stouffi ,Defendant WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 r..... r''-\ --:;::1 . C~F -n -.... ~;\.;...r ",;.:.c;... n-; ,.W) '-,.- cJ <~\ ~< _-'i MICHAEL P. STOUFFER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-2430 Civil Term HOLLY C. STOUFFER, Defendant 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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and marmer of service of the complaint: May 23, 2005, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff, August 29, 2005; by Defendant, September 9, 2005. 4. Related claims pending: None 5. Date Plaintiffs Waiver in ~ 3301(c) Divorce was filed with the prothonotary: September 2, 2005 Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: September 13, 2005 WEIGLE & ASSOCIATES, P.C. I!. '->./ Richard L. Webber, Jr., Esquir Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WE'GLE & ASSOC'ATES. Pc. - ATTORNEYS AT LAW - 126 EAST K'NG STREET _ SHIPPENSBURG, PA 17257-1397 l'") 1'-) ~:.:':) C_,) L.-f"l ~)l .-..\ -'1- \d ~,,-, C::-J . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS STATE OF . . . . . . . . . MICHAEL P. STOUFFER. . . . . . . . . . . . VERSUS HOU,y C. STOUFFER. . OF CUMBERLAND COUNTY PENNA. PT.AT1\ITTFF No. 05-2430 DEFENDANT . . . . . . . . . . . . . AND NOW, . . . DECREED THAT . AND . . . . DECREE IN DIVORCE ~f'e.-k ..2d v 2005 , MICHAEL P. STOUFFER HOU,y C. STOUFFER ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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 AJ . J. PROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,~ :z ~ 7U-, 5r:?kb ~ f;p ~~ 4; /"(J 50' /C"b . ..,.. . ... ~