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Home My WebLink About87-0084 __ THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CHERYL LEE SHOAP Plaintiff ~O. 84 CIVIL ~987 Versus ........ RD_Y_ DD]SALD.._S.HO. AP._.jR ................................. .......................... De-f-endan~ ................................... IN DIVORCE DECREE IN DI RCE ; AND NOW, ...... ~.e.b.r.u.~.r.y. ......... , 19.87 .... , it is ordered and decreed that Cheryl Lee Shoap ................. , plaintiff, and .a~y..Dqaald Shoap .Or, ........ ' ' ............................ 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 Cheryl Lee 'Shoap, IN THE COURT OF COMMON PLEAS OF Plaintiff CU~BERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 84 CIVIL 1~87 vs. ROY DONALD SHOAP, JR., Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section ~g~l~x (201(d) (1)) of the Divorce Code. (Strike 'out inapplicable section.) 2. Date and manner of service of the complaint: January 15, 1987 by certified mail, return receipt requested, restricted delivery . 3. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by Section 201(c) of the Divorce Code:' by the plaintiff N/A ; N/A ' by defendant (b) (1) Date of execution of the plaintiff's affidavit required by Section 201(d) of the Divorce Code: January 13, 1987 ; (2) date of service of the plaintiff's affidavit upon the defendant: January 15, 1987 by cergif%ed mail, return receipt requested . 4. Related claims pending: none Attorne~ ~or (Plaintiff) CHERYL LEE SHOAP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. f~ CIVIL, 1987 ROY DONALD SHOAP, JR., : 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 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 break- down 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, One South Hanover Street, Carlisle, Pennsylvania, 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 LAW~ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Third Floor Cumberland County Courthouse Carlisle, PA 17013 Telephone: (717) 249-1133 Atkbrney for Plaintiff 701 East King Street Shippensburg, PA 17257 CHERYL LEE SHOAP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA : ~ VS. : CIVIL ACTION - LAW : NO. CIVIL, 1987 ROY DONALD SHOAP, JR., : Defendant : IN DIVORCE COMPLAINT IN DIVORCE COMES NOW, the Plaintiff, Cheryl Lee Shoap, by and through her counsel, Sally J. Winder, Esquire, and represents as follows: 1. Plaintiff is Cheryl Lee Shoap, who currently resides at 2438 Lindsey Lot Road, Shippensburg, Franklin County, Pennsylvania, 17257, since September, 1986. 2. Defendant is Roy Donald Shoap, Jr., who currently resides at R. D. 4, Shippensburg, Cumberland County, Pennsylvania, since 1974. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 16, 1974, at Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff avers that she has been advised of the availability of counseling sessions for both parties upon request of either party or by order of court, and that a list of qualified professionals who provide such counsel- lng service is available at the Domestic Relations Office upon request. By the filing of this Complaint, the Plaintiff acknowledges having been advised by her attorney of record of the availability of counseling sessions and of a list of qualified professionals. Plaintiff further avers that she has been advised that the choice of a qualified professional shall be at the option of the Plaintiff and Defendant and need not be selected from the list available upon request and, further, that arrangements for and the payment of the service~ of the qualified professional shall be the responsibility of the parties and will not be included in the docket costs of this proceeding. 8. Plaintiff requests the Court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 'CheryI Lee Shoap., Pl~a'ntiff Date: _ ~J ~ ~~ SI~Y J Winder, AttOrney for Plaint if -2- COMMONWEALTH OF PENNSYLVANIA: : SS COUNTY OF CUMBERLAND : VERIFICATION Cheryl Lee Shoap, being duly sworn accoding to law, deposes and says that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of her knowledge, information and belief. [ ~heryl Lee Sworn to and subscribed before me this ~ ~ day of . ~.~~ ~c~ , 1987. fTotary Public My commission expires April 16, 1990 Shippensburg Township Cumberland County -3- CHERYL LEE SHOAP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. CIVIL, 1987 ROY DONALD SHOAP, JR., : Defendant : IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 201(d) OF THE DIVORCE CODE 1. The parties to this action separated in 1982 and have continued to live separate and apart for a period of at least three 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. §4904 relating to unsworn falsification to authorities. ~ff Sworn to and subscribed before me this _~ day of <~<~.~ , 1987. Not{~. Public My commisk~ion expires April 16, 1990 Shippensburg Township Cumberland County CHERYL LEE SHOAP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : NO. 84 CIVIL, 1987 ROY DONALD SHOAP, JR., : Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Sally J. Winder, being first duly sworn according to law do depose and say that I mailed a Complaint in Divorce in the above action to the Defendant, Roy Donald Shoap, Jr., at R. D. 4, Shippensburg, Pennsyl- vania, 17257 by certified mail, return receipt requested, on January 15, 1987, at the Shippensburg Post Office, Shippensburg, Pennsylvania, which Complaint in Divorce was received by the Defendant as evidenced by his signature on the attached receipt. 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. §4904 relating to unsworn falsification to authorities Sall~lJ. Winder Atto~ey for Plaintiff