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Home My WebLink About01-3536 ~ HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TONYA M. SHOFF, v. : CIVIL ACTION - LAW : NO. 01 - 353 ~CIVIL TERM : IN DIVORCE ROBBIE S. SHOFF, Defendant NOTICE 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 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 of your children. When the ground for 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717 -249-3166 " TONYA M. SHOFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ROBBIE S. SHOFF, Defendant : NO. 01 - 3.f3'- CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 ~ OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Tonya M. Shoff, an adult individual residing at 58 West Big Spring Avenue, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Robbie S. Shoff, an adult individual residing at 243 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on September 11, 1997 in Newville, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 2 t 6. The plaintiff avers that she has been advised of the availability of counseling and that said she has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as your Honorable Court may deem equitable and just. 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 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. /" May L, 2001 HAROLD S. IRWIN, I Attorney for plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 3 . TONYA M. SHOFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ROBBIE S. SHOFF, Defendant : NO. 01 -.j <d(. CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. May 11.., 2001 4 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TONYA M. SHOFF, v. : CIVIL ACTION - LAW ROBBIE S. SHOFF, Defendant : NO. 01 - 3536 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 Uill.1.llil NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1 . That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about June 13, 2001, by certified mail "restricted delivery", addressed to the defendant at 243 Redwood Lane, Carlisle, PA 17013, certified mail, return receipt No. Z 338 755 872. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsific ion t authorities. August 20, 2001 Harold S. Irwin, III Attorney for plainti 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. " A':iicle Addressed to: Hof3a \ E S ~ SHOF\= 2.113 R\;DwOOO U\NE" (J1~l\SLE PA 1'1013 Article Number (Copy from service label) L33~ Domestic Return Receipt 102595-00.M.09 D. Is delivery address different from ite If YES, enter delivery address below: 3~ce Type ~ertified Mail 0 Express Mail o Registered ~eturn Receipt for Merchandi: o Insured Mail 0 C,O,D. 4, Restricted Delivery? (Extra Fee) Yes 155 ~..., 'L t'--"'.._-- , ....""_.,~.,.".,,',... '''--"-,.",_.~,-'- ..-----..."'..-----.,. ......".,------~.. ------. Fi;si~Class'M1jiT .. Postage &'f'ees Paid USPS -Permit No.,..G4l}--- · Sender: Please pr' e, address. "",d Zl~rrthts-oo)(....!'---_.-'-- ?O i ::::+30=52 HAROLD SlRWIN III 35 E HIGH ST SUITES 201/202 CARLISLE P A 17013 I, ,,11111, III", /I,ll, ./1, 1I'I"~IMldr(t!'~ 1,1",1.11,1111,1111111,; t-.1 uJ uJ 0' ...l IJ"' IJ"' 0' ...l ru Stick postage stamps to article to cover First-Class postage, certified mail fee, and charges for any selected optional services (See front). 1. 11 you want this receipt p08tmarKed, stick the gummed stub to the right of the return address leavlng the receipt attached, and present the article at a post office service window or hand it to your rural carrier (no extra charge). 2, 11 you do not want this receipt postmarked, stick the{lummed stub to the right of the 'return address of the article, date, detach, and retain the receipt, and mail the article, 3. If you want a return receipt, write." e certified mail number and your name and address on a return receipt card, Form 3811, and attach it to the front of the article t1y means of the gummed ends if space permits. Othe~ise, affix to back of article, Endorse front of article RETURN RECEIPT REQUESTED adjacent to the number.. 4. If you want delivery restricted to the addressee, or to an authorized agent of the addressee, endorse RESTRICTED DELIVERY on the front of the'a,rticle, 5. Enter fees for the services requested in the appropriate spaces on the front of this receipt If retum receipt is requested, cheek the applicable blocks in item 1 of Form 3811. 6, Save this receipt and present it if you make an inquiry. 102595-99-M-0079 Q) ~ ~ <ll ~ U) Ol Ol ,.~ <( o o CO M E o LL en a.