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Home My WebLink About06-0083 SAlOIS SHUFF, FLOWER & LINDSAY AITORNEVS.AT.L\W 26 W. High Street Carlisle, PA 'I KENNETH H. SHEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. ~CKJCt- ~ IN DIVORCE v. PATRICIA SHEIBLEY, Defendant NOTICE TO DEFEND 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 wamed 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 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 Court House, Carlisle. Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PA 17013 717-249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY ) SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS-AT.[.AW 26 W. High Street Carlisle, PA II KENNETH H. SHEIBLEY. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 0<;'- 73 PATRICIA SHEIBLEY, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301/dl OF THE DIVORCE CODE 1. The Plaintiff is Kenneth H. Sheibley. an adult individual residing at 112 Round Ridge Road. Mechanicsburg, Cumberland County. Pennsylvania. 2. The Defendant is Patricia Sheibley, an adult individual residing at 418 Candlewyck Road, Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 6, 1976 in New Cumberland. Cumberland County. Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with 33301 (d) of the Pennsylvania Divorce Code. SAIDIS, SHUFF, FLOWER & LINDSAY ~"\ " SAIDIS SHUFF, FLOWER & LINDSAY A'lTORNEYS.t\T.w\W 26 W. High Street CarJisle. PA 'I I VERIFICATION 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 penalties of 18 Pa. C.S. S4904, relating to unsworn falsifications to authorities. i5~ Kenneth H heibley DEe J'l mJ ~ ~ -.l 9...:l '-"'I <:;- '}..::> ~ ~ --- ~ ~ ~ ~ -- ~ -"j ~ V\ ~ ~ ." ~' ~ ';.-. o C2 .-.:> r~.) .';":) 2:.... <- ~-,,", :.,:;: 4.-- C) .'\1 ::;J ;:n?J. ~~:t::) , '-.' -:-) . _~',~' l" :, ":~-1 -<. -'"~ (;;? ..:::> . ~ KENNETH H. SHEIBLEY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-83 PATRICIA SHEIBLEY, Defendant IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d} OF THE DIVORCE CODE 1. The parties to this action separated in October of 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. S4904 relating to unsworn falsification to authorities. Dated: rJIc,Jof.. Kenneth Sheibley .. SAlOIS, FLOWER & LINDSAY AnDRNEtS'Af.!.AW 26 West High Street CJr)i.\le,PA CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 SAlOIS, FLOWER & LINDSAY . , (, ~Qk.j n I fl{(~ /"1-, , ~ ' ~.~ /( _ " i , Barbara E. Steel for Carol J. Lindsay, Esquire Supreme Court 10 No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Dated: January 20, 2006 .,.' .-) ~l.! :-.-1 ~ 1 l c_-, SAIDIS SHUFF, FLOWER & LINDSAY A1TORNEYS.AT.LAW 26 W. High Street Carlisle, PA .- --,- KENNETH H. SHEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. :J.Mf. &'3 IN DIVORCE PATRICIA SHEIBLEY, Defendant ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint on behalf of Defendant Patricia Sheibley and certify that I am authorized to do so. am Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg. PA 17110-3339 Date 1/7/<r;, .--- ',_.I ~ ' - 1 , Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717)232.7200 KENNETH H. SHEIBLEY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW PATRICIA SHEIBLEY, : NO. 2006-83 Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) AND &3301(0) OF THE DIVORCE CODE I. I consent to the entry of a final Decree In Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the . .. Prothonotary. 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. 94904 relating to unsworn falsification to authorities. DATE: /~/f:..(J& ~. :;,.; g~\~ .,..,(-} (:.r., (~' .j' r:-~ 'b cP c.- ~ ~ l~.: C:" ~-/. ~~~ q, -TJ :::;. .;:1~ t~~ ;1)~; ~~\~\ '~f~ ~f1 r:-? (~) r--> r - Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 LingJestown Road Harrisburg, PA 17110 (717) 232-7200 KENNETH H. SHEIBLEY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : CIVIL ACTION - LAW PATRICIA SHEIBLEY, : NO. 2006-83 Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE I. Check either (a) or (b): 181 ( a) I do not oppose the entry of a divorce decree. D (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): D (i) The parties to this action have not lived separate and apart for a period of at least two years. D (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): 181 (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. D (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 notice to me, and I shall be unable thereafter to file any economic claims. I verify that 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. Section 4904 relating to unsworn falsification to authorities. DATE: r I? 'f!C'~ ~',(J Patricia K. Sheibley, 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. I ~ CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the ('), ~day of '-"-. /' ,2006, I served a true and correct copy of the foregoing Counter- I ( Affidavit Under ction 3301(d) Of The Divorce Code by depositing same in the United States Mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Carol J. Lindsay, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, P A 17013 Attorney for Plaintiff d&f CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg,PA 17110-3339 (717) 232-7200 Attorney for Defendant Q c;. ;,,," 4:.1 \:Y', ~;;~', 7':;~ (jl ~" . r.;.:~ \- r-> c"..> = 0" <-- ~ - ~ ~;-'(, Y"s;. :~~ --c ~ -. o "ll :;! ..-""" 111 r:: -(1 f1'~ .,l-'l'("(" "-1 "'" '~-',tj '.~..~; \:?:.~~;.; ,", "::;~-\ J:- ::l ~ c....' N , SAIDIS, FLOWER & LINDSAY ATTORNEYS.AT.lAW 26 West High Street Carlisle,PA [' KENNETH H. SHEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2006-83 PATRICIA SHEIBLEY. Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on January 9, 2006, by her attorney, Constance P Brunt, Esquire. An Acceptance of Service was filed with the Court on January 20, 2006. 3. Date Affidavit of Consent required under Section 3301 (d) of the Divorce Code was executed: By Plaintiff: January 13. 2006 and filed with Prothonotary on January 20, 2006 By Defendant: January 24. 2006 and filed with Prothonotary on January 27, 2006 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated January 19, 2006 are incorporated, but not merged, into the Decree in Divorce. 5. executed: Date Waiver of Notice under Section 3301 (d) of the Divorce Code was By Plaintiff: January 13, 2006 and filed with Prothonotary on January 20, 2006 By Defendant: January 24, 2006 and filed with Prothonotary on January 27.2006. C. ! '.' I Carol J. Un say, Esquire Supreme Cu D No. 4469 26 West Hig Street Carlisle. PA 17013 717-243-6222 SAIDIS, FLOWER & LINDSAY AT1URNEYS.AT'IAW 26 West High Street Carlisle, PA 'I CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Constance P. Brunt, Esquire 1820 Linglestown Road Harrisburg. PA 17110-3339 SAlOIS, FLOWER & LINDSAY Carol J. Lindsa, squire Supreme Court No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Dated: 1{3ififr C) l ," (:~~ ,:.':;:;J c,__ o " :i! nlp! -oj:!:; ~O't ,,':)( -' ~,~ nT, L _'~"\ ,"J...,'"'::; :i:~1 (~~ " :-b -< ..,., l"'"1 = I ::'1... co ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+'f'f'f ~'f'f 'f'f:f. 'f'f'f'f+''f'f+''f ++.+. +''f+'+'++'+'+'+'+++'+,+,+,.+++,+.++,+~ . . . . . . . . . +,+' 'f ;f:li 'f '+' 'f 'f '+: . . . . . . . . . . . . . . ... .. 'f ;f.:f'f+:+: IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY KENNETH H. SHEIBLEY STATE OF PENNA. Plaintiff No. 06-83 VERSUS PATRICIA K. SHEIBLEY Defendant DECREE IN DIVORCE AND NOW. fC.l.,N~ 1 KENNETH H. SHEIBLEY 1. 00 b 2.2.. DECREED THAT AND PATRICIA K. SHEIBLEY ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'f +. +. :+ 'f 'f +. +. '+ '+ 'f +. +. ",+ 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; The terms of the Separation and Property Settlement Agreement dated January 19, 2006 are incorporated, but not merged, into this Decree in Divorce. BY THE COURT:,;j7 ~.1lL Yj () ~j An & u ~ <' :+::++:f' :+ +++'f++ ++++++++++++++++++ +:+:+'f'f +++i''f+ ++'1' ++;1'++:1;+ ROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. r>-n-pr-fn' JP tPf!"'>Yf/ ?~;: ?'1:1 L.c p ~;P"~ ~? -.;2 ~.4Z~p .r?/' -lc?/F.;<' . r , . '. ..II; ,"