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Home My WebLink About87-0059IN the cOUrt OF COMMON Pleas Of CUMBERLAND COUNTY STATE OF PENNA. ..................................................................................... No .... .5...9. ................... ~ ~'~'~'~ L 19 87 .......................... SUSAN_._ STANBAU.GH ...................... Versus DECREE IN DIVORCE AND NOW .......................19.83. .... it is ordered and decreed that ......... .S.qS.A..~..S.T..A.M.~.A.U. 9.H ....................... plaintiff, and ................... ~T~-1~5~];¥..~,. ~q.T..~. ku. q8 ............... defendant, are divorced from the bonds of matrimony. 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; NONE SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 59 Civil 1987 : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 201(c) of the Divorce Code. 2. Date and manner of service: January 16, 1987, Certified Mail, Restricted Delivery, Return Receipt No. P285117877. 3. Date of execution of the affidavit of consent required by Section 201(c) of the Divorce Code: by Plaintiff - April 18, 1987; by Defendant - April 18, 1987. 4. Related claims pending: none. B:./P.Y Rich d ~ner,Esq. -~ MANCKE, WAG~ER & MARCELLO 2233 North/Front Street Harrisburg, Pennsylvania 17013 ATTORNEY FOR PLAINTIFF Dated: April 29, 1987 IN THE COURT OF COCA, ON PT.VAS OF ~ERLAND COUNTY, PENNSYLVANIA NO. ~? C~.~-- /~7 CIVIL ACTION - LAW IN DIVORCE ~USAN STAMBAUGH, Plaintiff vs. STANLEY R. STAMBAUGH, Defendants COMPLkIR~ D~O~E LAW OFFICEB MANCKE, LIGHTMAN & WAGNER 2233 NORTH FRONT STREET HARRISBURG, PA. 171tO SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : 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 another 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 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 OUR WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR Cumberland County Courthouse Carlisle, Pennsylvania 17013 PHONE: (717) 249-1133 SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT SUSAN STAMBAUGH, 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 Office of the Prothonotary, County Courthouse, 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 decree in divorce being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4094 relating to unsworn falsification to authorities. ,, USAN ST B 0G /3 / Dated: /~ --~-- ~ SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, SUSAN STAMBAUGH, by and through her Attorneys, MANCKE, LIGHTMAN & WAGNER, and respectfully represents the following: 1. The Plaintiff, Susan Stambaugh, is an adult individual presently residing at 6 Park Circle, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant, Stanley R. Stambaugh, is an adult individual presently residing at 6 Park Circle, Camp Hill, Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bono fide residents in the Commonwealth of Pennsylvania all of their lives. 4. Plaintiff and Defendant were married on April 5, 1980, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The Plaintiff avers that the grounds on which this action is based are: (a) that Defendant has offered such indignities to the person of the Plaintiff as to render the condition of the Plaintiff intolerable and life burdensome; or, in the alternative, (b) that the marriage is irretrievably broken. COUNT II 9. Paragraphs 1 through 8 are incorporated herein by reference and made a part hereof. 10. Plaintiff and Defendant are the joint owners as tenants of the entireties of certain real property, various items of personal property, furniture, and household furnishings, and a mortgage acquired during the marriage which are subject to equitable distribution by the court. COUNT III 11. Paragraphs 1 through 10 are incorporated herein by reference and made a part hereof. 12. Plaintiff has inadquate means of support for herself except as provided by husband. COUNT IV 13. Paragraphs 1 through 12 are incorporated herein by reference and made a part hereof. 14. Plaintiff does not have sufficient funds to support herself or to pay the counsel fees and expenses incidental to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree: (a) dissolving the marriage between the Plaintiff and Defendant; (b) equitably distributing all property owned by the parties hereto; (c) directing the Defendant to pay adequate and reasonable alimony to the Plaintiff; (d) directing the Defendant to pay Plaintiff adequate and reasonable alimony pendente lite, counsel fees, and the expenses of this proceeding; and (e) for such further relief as the Court may deem equitable and just. Respectfully submitted MANCKE, L IGHTMAN & WAGNER P. ~Ric/~Wagner, Esq. .2.23/~.N.orth Front Street ~rrisburg, PA 17110 ~JPhon e (717) 234-7051 ATTORNEY FOR PLAINTIFF I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the pemalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 59 CIVIL 1987 VS o ° : : CIVIL ACTION - LAW STANLEY R. STAMBAUGH, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, P. RICHARD WAGNER, ESQ., certify that I did serve a copy of the Complaint in Divorce upon the Defendant on January 16, 1987, by Certified Mail, Restricted Delivery, Return Receipt No. P285117877, which receipt is attached hereto and designated Exhibit A. p. Richard Wagn/r, Esq. MANCKE, WAGNE~ & MARCELLO 2233 North ~ont Street Harrisburg/ Pennsylvania 17110 Phone: (717) 234-7051 P 285 117 877 RECEIPT FOR CERTIFIED MAIL 1-12-87 co~la~t ~ Di~rce EXHIBIT "A" SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 59 CIVIL 1987 : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on January 12, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. I verify that the statements made in this affidavit 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. STAMB~GH l~. .. FILE LAW OFFICES WE DO HEREBY CERTIFY TH/ THE , i!4ANCKF,, %~TAGNEIR. & ;'.'IARCELLO THE WITHIN IS A TRUE AND CO . RECT C G.F.,;,r--'O'F~ THE ORIGIN~ FROM ~MENT 2233 NORTH FRONT ST, FILED IN THIS ACTION YOU ~-----'---~ BY _ ,:, HARRISE3URG, PA. 17ilo ATTORNEY : IN THE COURT OF COMMON PLEAS OF SUSAN STAMBAUGH, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 59 CIVIL 1987 V. : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE ~FFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on January 12, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. I verify that the statements made in this affidavit 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. TO YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ' L~W OFFICES WE DO HEREBY CERTIFY THAT ENCLOSED [4ANCKE, WAGNER & MARCELLO THE WITHIN IS A TRUE AND COR- WITHIN TWENTY {20) DAYS FROM RECT COPY OF THE ORIGINAL SERVICE HEREOF OR A JUDGMENT 2e33 NORTH FRONT ST, FILED IN T~ MAY BE ENTERED AGAINST YOU HARRISBURG, PA. 17110 BY BY ATTORI~EY ~ _. ATTORNEY SUSAN STAMBAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 59 CIVIL 1987 : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT STANLEY R. STAMBAUGH, 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 office of the Prothonotary, Cumberland County Courthouse, 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 decree in divorce being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4094 relating to unsworn falsification to authorities. STANLEY R. ~/~TAMBAUGH Dated: : -- . -" : FILE THE . LAW OFFICES WE DO HEREBY CERTIFY THA1 ~J~z~Nc~'' t ~'~AGN~'i~ & ~I~RCJ~LT~O THE WITHIN IS A TRUE AND COR RECT ~F THE ORIGINAl ~233 NORTH FRONT ST. FILED IN THIS ACTION ~ApplqRURG, PA, 17110 BY , ATTORNEY : IN THE COURT OF CO~v~ON PLEAS OF SUSAN STAMBAUGH, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 59 CIVIL 1987 : STANLEY R. STAMBAUGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE FOR WITHDRAWAL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw Counts II through IV of the Complaint filed to the above captioned term and number, as these matters have been settled by Agreement of the parties. Thank you. By ~'" ~. Richard Wagner, Esq. MANCKE, WAGNER & MARCELLO 2233 North Front Street Harrisburg, Pennsylvania 17110 Phone: (717) 234-7051 Dated: April 29, 1987