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Home My WebLink About05-4887 .. /'y \- " SHERRY A. DECKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE ; NO. 05- '/rt1 CIVIL TERM JON P. DECKER, 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 right 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 ALA WYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA WYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 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, P A 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SHERRY A. DECKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JONP. DECKER, Defendant : NO. 05- J.j g !)? CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. ~~ 3301(c) & (d) OF THE DIVORCE CODE The plaintiff, Sherry A. Decker, by her attorneys, the Family Law Clinic, sets forth the following in support of her Complaint for Divorce: 1. Plaintiff is Sherry A. Decker, who currently resides at 10 Cherokee Drive, Cumberland County, Shippensburg, Pennsylvania 17257. 2. Defendant is Jon P. Decker, who currently resides at Bakersfield Rescue Mission, 816 East 21 st Street, Kern County, Bakersfield, California 93303. 3, Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 28, 2001 in Pleasant Hall, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since May 2005. 6. A prior action in divorce was filed to Docket Number 03-6662, but the action was withdrawn without prejudice on December 17,2004. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff or Defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Date o/ZO/C5 /}! , '7 i /{,~1:V (/1 , ~ I...-h() l C rrla ]..'-..,./ , Jessica L. Bowman / /Certified Legal Intern I i\ " }\ ,I C 'j' i " ';" r ,~ 11.),! '---~ . v.::-~ . \'fV ~. ANN l\CDONALD-FOX LUCY JOHNSTON-WALSH THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 717-243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me tot he penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date q-;2()- oS- .~ LJ,<~ Sherr cker Plaintiff -\-\ )\ ~ n ~; ~ ~ r-> c:::> = cJ' en f""1 --0 N o Q. :i!:n rot:: rr:! :9,~ ~) '~~, 'CH~~ s~~ ."-~ 0' "~ 115 :.< :P'" :>. - - N N - SHERRY A. DECKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION-LAW : IN DIVORCE 05" ,(t6~7 : NO. CIVIL TERM JON P. DECKER, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Sherry A. Decker, through her attorneys, the Family Law Clinic to proceed in forma pauperis. The Family Law Clinic, attorneys proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully Submitted, I ,/, , .' - v '--:tf:;, , /4:k~1' ~ ~ )i~ l,:'ln(".v~ } ySsica L. Bowman ,~ertified Legal Intern THE F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 o c: ~:>>. 'T~ =:3 -- r-..) = = c:.n (/) rr1 -0 N o ~ ~1:n ft, ~..r.J E9 06 --I -,-, ~-n C)O ;-;; m ~l 13 ~ :.Pa :x N N SHERRY DECKER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v JON P. DECKER, Defendant : CIVIL ACTION-LAW : DIVORCE : No. 05-4887 CIVIL TERM PETITION TO DISMISS COMPLAINT Plaintiff, Sherry Decker, by and through her attorneys, the Family Law Clinic, hereby requests that the Court dismiss without prejudice the Complaint for Divorce filed September 20, 2005 in the above captioned case. In support of her Petition, Plaintiff avers as follows: 1. Plaintiff filed a Complaint for Divorce under Sections 3301(c) and 3301(d) with this Court on September 20,2005. 2. Plaintiff has informed the Family Law Clinic that Plaintiff and Defendant have decided to reconcile the marriage. 3. Plaintiff has informed the Family Law Clinic that Plaintiff does not wish to pursue this action and requests that the Complaint for Divorce be dismissed without prejudice. 4. The Family Law Clinic has not sought concurrence of opposing counsel pursuant to Local Rule 206.2, because Defendant is not represented by legal counsel in this matter. WHEREFORE, Plaintiff requests that the Court dismiss without prejudice the Complaint for Divorce filed September 20,2005. l~- JL{~ 0<0 Respectfully Submitted,. ~ Ii , /' 1/(" .,' .-/" /' ",,//' . ',,- .!,: Iici1t1!,; N, <"1:;"; fi', .Cli'..?-l_ M ;JR' E ; egan lesmeyer, sq. ) Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 VERIFICATION I verify that the facts and statements in the attached Petition are true and correct to the best of my knowledge, I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. (~"" '~-.,.~ , (>:C/1-/~/v\......r-00 DEe 19 2006 (If ~ SHERRY DECKER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v JONP. DECKER, Defendant : CIVIL ACTION-LAW : DIVORCE : No. 05-4887 CIVIL TERM ORDER OF COURT AND NOW, this /11' day of ~ , 2006, upon Plaintiff s Petition to Dismiss Action, it is hereby ordered and directed as follows: Plaintiff s Complaint for Divorce filed September 20, 2005 is dismissed without prejudice. By the Court, ;44 J.