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Home My WebLink About05-3848 CAREN JESSICA STANN, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ()S' -.3P'1? Clutl ~Efl-L MICHAEL SCOTT STANN, DEFENDANT : DIVORCE ACTION 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 (717) 240-6195, Cumberland County Courthouse; One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYERS 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 S -3f'ff' C/'uL '---r- E/l-rv 1 : DIVORCE ACTION CAREN JESSICA STANN, PLAINTIFF MICHAEL SCOTT STANN, DEFENDANT COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301/dl OF THE DIVORCE CODE 1. Plaintiff, Caren Jessica Stann, is an adult individual who currently resides at 3468 Green Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Michael Scott Stann, is an adult individual who currently resides at 2100 State Street, Apartment 2E, Harrisburg, Dauphin County, Pennsylvania 17103. 3. The Plaintiff's Social Security Number is 219-72-2905. 4. The Defendant's Social Security Number is 390-64-7223. 5. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 6. The Plaintiff and Defendant were married on September 6, 1998, in Germantown, Wisconsin. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in Counseling. 10. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Caren Jessica Stann, urges this Honorable Court to enter a Decree of Divorce. By: q- James G. Nealon, III, Esquire Attorney 1.0. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 RY NEALON G VERIFICATION I, Caren Stann, verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: #5 ('if1/!tt0 ~ Caren Stann 0 ~ (( )c:) ---- ~......, ~ --tl C") C::.;J ft- 1 c-::> C) ~-,-'I - --- ~ U( r,) G'- CY -.l \) 0- W --,-, 'l:::l W F! - c..v (~.0 ~ - ,~ U1 CAREN JESSICA STANN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-3848: MICHAEL SCOTT STANN, DEFENDANT : DIVORCE ACTION AFFIDAVIT OF SERVICE I, John A. Stine do hereby certifY, subject to the penalties of 18 Pa. C. S. Section 4904, relating to Unswo~lsification to Authorities, that 1 am a plmpetent adult and that on the S day of ~ . ,2005,at about '9:/~ o'c1ocka.m.l@servedtrueandcorrectcopies of the following documents in the above-captio~ed matter: Divorce Complaint filed in the matter or in the manner and form as attached upon the ultimate recipient Michael Scott Stann served in the following indicated manner: ~personallY hand~ sai eopies to n~ leav' ann at the address below or at c2ct:) /--~ .-. / 7~1/J"Y _by personally handing said copies to and leaving same with the following name adult member at the address below or at _ by leaving said copies at the last known address of the ultimaw recipient, said last known address at the following location: and said copies being specifically placed at TO BE FILLED IN BY PERSON ACCEPTING 0RvICE: Received the herein described documents on t / <IS' I Signatu (Date) I Date Received: g J / / t06 ~dt?~-~ 7~/P.K? .'""."q""I'..,,,,.,,. ,," 0 "', 0 c-.> C Co:? ." e.n :P'" -< ~ c:: rn~ G) -nrr', !'-> coy W '~?~j -0 -" W Ul ~ N C< CAREN JESSICA STANN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-3848 MICHAEL SCOTT STANN, DEFENDANT : DIVORCE ACTION PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please discontinue the above captioned action without prejudice. NEALON RRY By: q- James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this /3f1\ day of September, 2005, I hereby certify that I have served the foregoing Praecipe to Discontinue on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael S. Stann 200 Fulling Mill Road Middletown, PA 17057 q James G. Nealon, III (') ....., 0 = c = -n ~-.... <:.n :....,., C/l :t ~tJl lrr f""1 ,.,,:0 Z::::.:, -u r Z"C :!j~ Cj)",'. Ul ~ -<.f'. kC' -U :r: -1'l ~8 ::ll;: O~ <7 ' Pc: W 01 Z ~ :::.:! w ~