HomeMy WebLinkAbout05-3796MYCALA WORLEY SHAULIS,
Plaintiff
V.
GLENN DANIEL SHAULIS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. ('j _ 9L C,1vI l
CIVIL ACTION - LAW
IN DIVORCE
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 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, Carlisle, PA 17013.
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, PA 17013-3302
Telephone: (717) 299-3166
E1\d--r\SHAUL7S,MYCALA-33n!CDIV
MYCALA WORLEY SHAULIS,
Plaintiff
V.
GLENN DANIEL SHAULIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0,5-- 79 (p
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is MYCALA WORLEY SHAULIS, an
adult individual, who recently moved from 1176 West Trindle Road,
Mechanicsburg, Cumberland County, Pennsylvania, 17055, to an
undisclosed location.
2. The Defendant in this action is GLENN DANIEL SHAULIS, an
adult individual, who currently resides at 1176 West Trindle Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055-
3. The Defendant has been a bona fide residents of the Common-
wealth of Pennsylvania for at least six (6) months immediately
previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on July 23, 1994, in Camp Hill, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
-1-
7. The Plaintiff avers that no children have been born of this
marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of
divorce.
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 P.C.S. 54904, relating to unsworn falsification
to authorities.
Date: July 1001 5--
STONE LaFAVER &..-SH?KLETSKI
Of o I #60251
414 e et, P.O. Box E
Ne Cumber d, PA 17070
elephone 7-774-7435
Attorne or Plaintiff
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MYCALA WORLEY SHAULIS,
Plaintiff
v.
GLENN DANIEL SHAULIS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3796
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, GLENN DANIEL
SHAULIS, on August 9, 2005, at 1176 West Trindle Road, Mechanicsburg,
PA 17055, by United States Certified Mail, post•fe prepaid, restricted
delivery, on August 9, 2005, as evidenced by the attached Certified
Mail return receipts.
SWORN TO AND SUBSCRIBED
before me this 11th day
of - August
Notary Publi
COMMONWEALTH OF PENNSYLVANIA
'ELIZABETH $! S
Attorney t LA
NOTARIAL SEAL
KATHLEEN KEIM,Notary Public
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Explanatory
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
1. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
11 Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
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F ULI-OFFICE
IN THE COURT OF COMMON PLikS HE €'PO TIIGNO A ,'
CUMBERLAND COUNTY, PENNSYLV2MIttil y _2.
mi 1
13
CIVIL DIVISION
Glenn Daniel Shaulis
Plaintiff
CUMBERLAND COUNTY
PENNSYLVANIA
vs. : File No. Q005- - O 379 (
Mycala Shaulis
Defendant
NOTICE OF INTENTION TO RETAKE PRIOR NAME
Mycala Shaulis, being duly sworn according to law, deposes and says that a divorce action
was filed on JU l y a(o aaos in Cumberland County in which she is the
OPlaintiff ❑Defendant; that Mycala Shaulis elects to retake her maiden name (or prior name)
of Mycala Worley, and gives this written notice avowing her intention in accordance with the
provisions of 54 Pa. C.S.A. Section 704.
Dated: NVat,Y a, dOIA
aulis
TO BE KNOWN AS:
Sig
On the a day of / V C( , 201 Lf , before me,
Public, personally appeared Mycala Sh lis, known to me to be the person whose name is
subscribed to in the within document and acknowledged that she executed the foregoing for the
purpose therein contained.
IN WITNESS THEREOF, I have hereunto set my hand and seal.
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
-THOMAS W FOGELSONGER
Notary Public
SHIPPENSBURG TWP., CUMBERLAND CNTY
My Commission Expires-Apt22, 2011
Notice of Intention to Retake Prior Name
NO
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Page 1 of 1
THE LAW OFFICES OF ELIZABETH B. STONE
3507 Market Street, Suite 303
Camp Hill, PA 17011
Telephone: (717) 909-1500
Facsimile: (717) 731-8115
estone@tanner-law.com
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213,14.UN 12 2: 1 2
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PENNS YL TYNIA
MYCALA WORLEY SHAULIS, §
Plaintiff
v. § NO. 05-3796
GLENN DANIEL SHAULIS, § CIVIL ACTION - IN DIVORCE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
July 26, 2005.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing and service of the
Complaint.
I consent to the entry of a final decree of divorce after service of Notice of
Intention to Request Entry of Divorce.
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: ii/3/ /11-
THE LAW OFFICES OF ELIZABETH B. STONE
3507 Market Street, Suite 303
Camp Hill, PA 17011
Telephone: (717) 909-1500
Facsimile: (717) 731-8115
estone@tanner-law.com
MYCALA WORLEY SHAULIS, § IN THE COURT OF COMMON PLEAS
Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA
v. § NO. 05-3796
GLENN DANIEL SHAULIS, § CIVIL ACTION - IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Date: / //3// �-
0.1. I f1\div\SHAULIS,MYCALA-affofservice
MYCALA WORLEY SHAULIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 05-3796
GLENN DANIEL SHAULIS, • CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
SS :
COUNTY OF CUMBERLAND
I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, GLENN DANIEL
SHAULIS, on August 9, 2005, at 1176 West Trindle Road, Mechanicsburg,
PA 17055, by United States Certified Mail, post_•fe prepaid, restricted
delivery, on August 9, 2005, as evidenced b the attached Certified
Mail return receipts .
,/*°09
LIZABETH ; 'ONE
Attorney :w
SWORN TO AND SUBSCRIBED
before me this 11th day
of August 05 .
5 .
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Notary Publi'
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
KATHLEEN KEIM,Notary Public
New Cumberland Boro.Cumberland Co.
My Commission Expires Dec.5,2006
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THE LAW OFFICES OF ELIZABETH B. STONE
3507 Market Street, Suite 303
Camp Hill, PA 17011
Telephone: (717) 909-1500
Facsimile: (717) 731-8115
estone@tanner-law.com
MYCALA WORLEY SHAULIS, § IN THE COURT OF COMMON PLEAS
Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA
v. § NO. 05-3796
GLENN DANIEL SHAULIS, § CIVIL ACTION- IN DIVORCE
Defendant §
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
July 26, 2005.
2. The marriage of the 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 of divorce after service of Notice of
Intention to Request Entry of Divorce.
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: /&//yhY
Glenn Daniel Shaulis, Defendant
THE LAW OFFICES OF ELIZABETH B. STONE
3507 Market Street, Suite 303
Camp Hill, PA 17011
Telephone: (717) 909-1500
Facsimile: (717) 731-8115
estone@tanner-law.com
MYCALA WORLEY SHAULIS, § IN THE COURT OF COMMON PLEAS
Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA
v. § NO. 05-3796
GLENN DANIEL SHAULIS, § CIVIL ACTION - IN DIVORCE
Defendant §
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER§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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Date:
Glenn Daniel Shaulis, Defendant
MYCALA WORLEY SHAULIS, IN THE COURT OF COMMON PLEAS
Plaintiff
: CUMBERLAND COUNTY,PENNSYLVANIA
VS.
CIVIL DIVISION
GLENN DANIEL SHAULIS, : NO. 05-3796 CIVIL TERM
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))and :r
§ (3301(d)(1))of the Divorce Code.
(Strike out inapplicable section.)
2. Date and manner of service of the complaint:
By United States certified mail,restricted delivery on August 9, 2005. See attached
Affidavit.of Service.
3. Compete either paragraph(a) or(b).
(a) Date of execution of the affidavit of consent required by§ 3301(c)of the
Divorce code:
by plaintiff November 3, 2014 ;by defendant December 14, 2014
(b)(1)Date of execution of the affidavit required by § 3301(d)of the Divorce Code:
(2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the
respondent opposing party:
4. Related claims pending: None.
5. Complete either(a)or(b)
(a) Date and manner of service of the notice of intention to file praecipe to transmit
record,a copy of which is attached:
(b) Date plaintiff's Waiver of Notice was filed with the Prot 'notary:
November 12, 2014
Date defendant's Waiver of Notice was filed with the 'rothonotary:
With the filing of this Praecipe to Transmit.
Attorney for Pl, ntif 'i; endant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
MYCALA WORLEY SHAULIS
V.
GLENN DANIEL SHAULIS : NO 05-3796
DIVORCE DECREE
AND NOW (.4,4 1 ,oZiZ 416141 it is ordered and decreed that
MYCALA WORLEY SHAULIS plaintiff, and
GLENN DANIEL SHAULIS , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
By the Court, w.
Attest: J.
cA_
Pr. honotary
CJ CoPe let( aiky Zfone
Nice+cry mai W, debt