HomeMy WebLinkAbout05-5986CAREN L. SEALOVER, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. ?S- J ZCT C? C=(c?il I ?fL1
W. SCOTT SEALOVER, IN DIVORCE
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 action within twenty (20) days after
this Complaint and Notice are served, by entering a written appearance
personally or by attorney and filing in writing with the Court your defenses or
objections to the claims set forth against you. You are warned that if you fail
to do so the case may proceed without you and a judgment may be entered
against you by the Court without further notice for any money claimed in the
Complaint or for any other claim or relief requested by the Plaintiff. You may
lose money or property or other rights important to you.
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 WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
CAREN L. SEALOVER, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. S - S 1 ST(c
SCOTT W. SEALOVER, IN DIVORCE
Defendant :
NOTICIA
Le han demandado a usted en la corte. Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene viente (20)
dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe
presentar una apariencia escrita o en persona o par abogado y archivar en la
corte en forma escrita sus defensas o sus objeciones a las demandas en contra
de su persona. Sea avisado que si usted no se defiende, la corte tomara
medidas y puede entrar una orden contra usted sin previo aviso o notificacion
y par cualquier queja o alivio que es pedido en la peticion de demands. Usted
puede perder dinero o sus propiedades o otros detechos importantes para
usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O S1 NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
CAREN SEALOVER,
Plaintiff
V.
SCOTT W. SEALOVER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05- S-9PL
IN DIVORCE
COMPLAINT IN DIVORCE ORDER
SECTION 3301 ( c ) OF THE DIVORCE CODE
AND NOW, comes Plaintiff, Caren L. Sealover, by and through her
attorneys, Rupp and Meikle and Richard C. Rupp, and files this Complaint in
Divorce, based upon the following:
1. Plaintiff, Caren L. Sealover, is an adult individual, who resides in
Cumberland County, Pennnsylvania.
2. Defendant, Scott W. Sealover, is an adult individual, now residing in York
County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months previous to the
filing of this Complaint.
4. Plaintiff and Defendant were married on July 3, 1999 in Dilisburg, York
County.
S. There have been no prior actions for divorce or annulment between the
Parties except this Complaint filed for divorce.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and of the
right to request the Court require the parties participate in counseling.
8. Plaintiff is not a member of the Armed Services of the United States of
America and Defendant was not a member of the Armed Services of the
United States of America.
9. Plaintiff and Defendant have no children in this marriage.
10. Plaintiff and Defendant separated on August 4, 2004.
11. Plaintiff has been advised of her right to have marriage counseling
and the elects to waive this right.
12. Plaintiff asks the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree
in Divorce dissolving the marriage between Plaintiff and Defendant and
such further relief as the Court may determine equitable and just.
Respectfully submitted,
RUPP EIKLE
Richard C. Rupp
Attorney I.D. No.: 34832
355 North 21 st Street, Suite 201
Camp Hill, PA 17011
(717) 761-3459
Attorney for Plaintiff
VERIFICATION
1, Caren L. Sealover, verify that the statements in the foregoing Complaint
in Divorce are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein are made subject to penalties
of IS Pa. C.S. § 4904 relating to unsworn falsification to authorities.
AREN L. SE LO
Date: 10/015) 05
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CAREN L. SEALOVER,
Plaintiff
VS.
W. SCOTT SEALOVER,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 05 - 5986 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
Please withdraw the appearance of Richard C. Rupp, Esquire, in the above-captioned action
as Marlin L. Markley, Esquire is entering his appearance on behalf of the Plaintiff.
RespectfWlly-submitted,
1
Richard C. Rupp, Esquire r
355 North 21St Street, Suite 201
Camp Hill, PA 17011
Date: ID # 34832 Tel. (717) 761-3459
PR 1F CIPF TO FNTFR APPEARANC R
TO THE PROTHONOTARY:
Please enter the appearance of Marlin L. Markley, Esquire, in the above-captioned action.
Date: ?40,03
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street
Camp Hill, Pennsylvania 17011
ID# 84745 Tel. (717) 763-1800
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CAREN L. SEALOVER,
Plaintiff
VS.
W. SCOTT SEALOVER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 05 - 5986 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
TO THE PROTHONOTARY
Kindly reinstate the Dii vorce Complaint in the above-captioned matter.
Respectfully submitted,
Date: D Z eel
ivlall ri,. iaa-iucy, mquire
Law Off ides of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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CAREN L. SEALOVER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 05 - 5986 Civil Term
W. SCOTT SEALOVER, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
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 ?e 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, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXP NSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIG 14T 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.
RLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
CAREN L. SEALOVER, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 05 - 5986 Civil Term
W. SCOTT SEALOVER, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AND NOW, comes the Plaintiff, Caren L. Sealover, by and through her attorneys the Law
Offices of Patrick F. Lauer, Jr?' LLC, files this Amended Complaint in Divorce against the
Defendant, representing as follows:
1. The Plaintiff is Caren Sealover, an adult individual who resides at 103 North 26`i'
Street, Camp Hill, Cumberland County, Pennsylvania 17011.
2. The Defendant is W. Scott Sealover, an adult individual who resides at 111
Greenbrier Lane, Dillsburg, York County, Pennsylvania 17019.
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3. The parties have been residents of the Commonwealth of Pennsylvania at least six
months prior to the filing of th?s action in divorce.
4. The Plaintiff and the Defendant were married on July 3, 1999 in Dillsburg, York
County, Pennsylvania.
5. Pursuant to the Divorce Code, Section 3301 (d), the Plaintiff avers as the grounds
I
upon which this action is based that the marriage between the parties is irretrievably broken and that
the parties hereto have lived se arate and apart for a period of at least two years. The parties have
lived separate and apart since a out August 4, 2004.
6. The Plaintiff avers that she has been advised of the availability of counseling and
that she has the right to request that the court require the parties to participate in counseling.
I
WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the two
parties.
Respectfully
Martin L. Nfarkl-y, Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street
Camp Hill, Pennsylvania 17011
ID# 84745 Tel. (717) 763-1800
Date: T -10- 0 7
r•
CAREN L. SEALOVER,
Plaintiff
vs.
W. SCOTT SEALOVER,
Defendant
I verify that the
understand that false
relating to unworn
/D 7
Date: 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 05 - 5986 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
V ERTFTCATTnN
nts made in this Amended Complaint are true and correct. I
herein are made subject to the penalties of 18 Pa. C.S. § 4904,
i to authorities.
Signature: ??.
Caren L. Sealover
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CAREN L. SEALOVER,
Plaintiff
vs.
W. SCOTT SEALOVER,
Defendant
IF YOU WISH TO D
AFFIDAVIT, YOU MUST F
AFTER THIS AFFIDAVIT I
BE ADMITTED.
AFFIDAVIT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 05 - 5986 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
OTICE TO THE DEFENDANT
'"ANY OF THE STATEMENTS SET FORTH IN THIS
A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS
BEEN SERVED ON YOU OR THE STATEMENTS WILL
ER § 3301(d) OF THE DIVORCE CODE
I. The parties to this action separated on August 4, 2004 and have continued to live
separate and apart for a
2. The marriage
3. I understand
lawyer's fees or expenses if I
I verify that the
false statements herein are
unworn falsification to
Date: I'f O k-?
of at least two years.
irretrievably broken.
I may lose rights concerning alimony, division of property,
not claim them before a divorce is granted.
made in this affidavit are true and correct. I understand that
subject to the penalties of 18 Pa. C.S. § 4904 relating to
Caren L. Sealo r, Plaintiff
CA F { ,
CAREN L. SEALOVER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 05 - 5986 Civil Term
W. SCOTT SEALOVER, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
I, W. Scott Sealover, Defendant in the above-captioned matter, accept service of the
COMPLAINT IN DIVORCE, AMENDED COMPLAINT IN DIVORCE, and PLAINTIFF'S
AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE pursuant to Pennsylvania Rule of
Civil Procedure, Rule 1930.4(d).
W. Scott Sealover
Date: / i? oZ&V7
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CAREN L. SEALOVER,
Plaintiff
VS.
W. SCOTT SEALOVER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 05 - 5986 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF § 3301(d) DIVORCE DECREE
TO: W. Scott Sealover, Defendant
111 Greenbrier Lane
Dillsburg, PA 17019
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after the 31St day of May
2007, the other party can request the court to enter a final decree in divorce.
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in
divorce. A counter-affidavit which you may file with the Prothonotary of the Court is attached to
this notice.
Unless you have already filed with the court a written claim for economic relief, you must
do so by the above date, or the court may grant the divorce and you will lose forever the right to
ask for economic relief. The filing of the attached form counter-affidavit alone does not protect
your economic claims.
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
(717) 249-3166
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CAREN L. SEALOVER,
Plaintiff
vs.
W. SCOTT SEALOVER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:No. 05 - 5986 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE
1. Check either (a) or (b):
? (a) I do not oppose the entry of a divorce decree.
? (b) I oppose the entry of a divorce decree because:
Check (i), (ii), or both:
? (i) The parties to this action have not lived separate and apart for a period of
at least two years.
? (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
? (a) I do not wish to make any claims for economic relief. 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.
? (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees, or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the prothonotary in writing and serve them on the other party. If I fail to do so before
the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may
be entered without further delay.
I verify that the statements made in this counter-affidavit 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.
Date:
W. Scott Sealover, Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC
RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT
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CAREN L. SEALOVER,
Plaintiff
vs.
W. SCOTT SEALOVER,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 2005 - 5986
CIVIL ACTION - AT LAW
IN DIVORCE
Transmit the record, together with the following information, to the Court for entry
of a divorce decree:
1. Ground for Divorce: Irretrievable breakdown under §c) § 3301(d)(1)
of the Divorce Code. (Strike out inapplicable section)
2. Date and Manner of service of the Complaint:
Service by first class mail to Defendant. Defendant accepted service on April 18, 2007.
See attached Acceptance of Service.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required by § 3301(c) of
the Divorce Code: by the Plaintiff
by the Defendant
(b) Date of execution of the affidavit required by § 3301(d) of the
Divorce Code: April 10, 2007 ;
Date of filing of the Plaintiffs affidavit:T1 0, 9007 ;
Date of service of the Plaintiffs affidavit upon the respondent:
And, 9007
4. Related claims pending: None All matters, settled
5. (Complete either paragraph (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, served
(b) Date Plaintiff s Waiver of Notice in § 3301(c) Divorce was filed with
the prothonotary: ;
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed
with the prothonotary:
Date: 31-2, D(7 7
MarlJA. arkley, Esquire
Law Offic s of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
vii
STATE OF PENNA.
CAREN L. SEALOVER,
Plaintiff
VERSUS
W. SCOTT SEALOVER,
Defendant
No. 2005 - 5986
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
AND
Svt? E .?
Caren L. Sealover
1407, IT IS ORDERED AND
W. Scott Sealover
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
BY THE COURT:
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PROTHONOIA
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