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Home My WebLink About05-5549DEBRA R. VAUGHN, Plaintiff V. ROGER L. VAUGHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0<- 6u l 11? 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 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, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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, Pennsylvania 17013 717-249-3166 WEIGLE 6 ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBVRG. PA 17257-1397 DEBRA R. VAUGHN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 0 5. 5 5-Y9 eti? j ?TC.-- ROGER L. VAUGHN, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT I - IRRETRIEVABLE BREAKDOWN AND NOW, comes the above named Plaintiff, Debra R. Vaughn, by and through her attorneys, Weigle & Associates, P.C., and Jerry A. Weigle, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Debra R. Vaughn, is an adult individual presently residing at 215 Running Pump Road, Newville, Cumberland County, Pennsylvania 17241, since June 17, 2005. 2. Defendant, Roger L. Vaughn, is an adult individual presently residing at 28 Vaughn Road, Newville, Cumberland County, Pennsylvania 17241, since approximately 1982. 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 June 9, 1982, in 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 June 17, 2005. 9. The Plaintiff requests the court to enter a decree of divorce. 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. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 COUNT II - INDIGNITIES GROUNDS FOR DIVORCE 15. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 16. Defendant has offered to the person of the Plaintiff, Plaintiff being the innocent and injured spouse, such indignities as to render Plaintiff's condition intolerable and Plaintiffs life burdensome. 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 " Je A. W igle, Esquire lytomey f Plaintiff Attorney ID # 01624 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSSURG. PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. § 4904, relating to unworn falsification to authorities. Debra Vaughn, WEIGLE G ASSOCIATES. PC. - ATTORNEYS AT LAW - 126 EAST KING STREET SHIPPENSBURG, PA 17257 139 7 .., --?, ?` { ?, ?? ? ? ?? C 4 ? ? -? p ? .. G ??` u; ?_ ??. DEBRA R. VAUGHN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 05-5549 CIVIL TERM ROGER L. VAUGHN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I, Wayne Shannon, Pennsylvania State Constable, being duly sworn according to law, depose and say that on November 4, 2005, at 1:25 PM, I served a true and attested copy of a Complaint in Divorce with Notice to Defend and Claim Rights attached upon the Defendant, Roger L. Vaughn, at 28 Vaughn Road, Newville, Cumberland County, Pennsylvania, by handing said Complaint to the Defendant, Roger L. Vaughn. Wayne annon Sworn to and subscribed before me this I ) ^A day of 1 e + 2005. Notary Public Notarial Sea! Linda K. Klein, Notary Public Shippensburg, PA Cumberland County M Commission Expires August 15, 2008 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 - r-' : -y r ' - - i _ 'i F.. R ?. G? DEBRA R. VAUGHN, Plaintiff V. ROGER L. VAUGHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5549 CIVIL ACTION - LAW DIVORCE PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Roger Vaughn, Defendant in the above captioned matter. Date: ,Aj"Uali' Angel' a Revelant Certified Legal Intern Robert Rains, Esquire Lucy Johnston-Walsh, Esquire Ann MacDonald-Fox, Esquire Thomas Place, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r -' -} ; ? - f (.- _?. DEBRA R. VAUGHN Plaintiff vs. ROGER L. VAUGHN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO: 05-5549 CIVIL ACTION-LAW DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of the Family Law Clinic on behalf of Roger Vaughn, Defendant in the above-captioned action. Date: V/`1 06 q a.Q t ud-4 Angel I?Oelant Certified Legal Intern F04?n?f Robert E. Rains, Esquire Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 Phone: (717) 243-3696 Fax: (717) 243-3639 PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of Roger Vaughn, Defendant in the above captioned action. H. Anthony Adams, Esquire 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 Attorney ID No. 25502 (717)-532-3270 ll . DEBRA R. VAUGHN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-5549 ROGER L. VAUGHN, CIVIL ACTION - LAW Defendant DIVORCE CERTIFICATE OF SERVICE I, Angel Revelant, Certified Legal Intern, hereby certify that I am serving a true and correct cnpy of the Praecipe for Withdrawal and Entry of Appearance on the follo%ving person, counsel for plaintiff, by depositing a copy of the same in the United States mail, postage prepaid, this P/ fl, day of Zd , 2006: Jerry A. Weigle, Esq. Weigle & Associates, P.C. 126 East King Street Shippensburg, PA 17257 Angel l elnant Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle. Pennsylvania 17013 Phone:(717) 243-3696 Fax: (717) 243-3639 _' DEBRA R. VAUGHN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 05-5549 CIVIL TERM ROGER L. VAUGHN, Defendant IN DIVORCE PRAECIPE TO DISCONTINUE To the Prothonotary, Glenda Farner: Please discontinue the above-captioned matter as the Defendant, Roger L. Vaughn died on July 21, 2007. (0 , z2 ^07 Dated: GLE & ASSOCIATES, P. . r r 71 Q By: Ferry A. Wtigle, Esquire Attorney for Plaintiff Attorney I.D. #01624 126 East King Street Shippensburg, PA 17257 Telephone (717) 532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 C . - ., .? U CL