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Home My WebLink About02-1071 HARRY P. SHAFFER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 02. - /0'7/ GiULl '-r~ CAROLYN M. SHAFFER, Defendant. CIVIL ACTION - 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 breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013" IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL- MENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPH- ONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17103 Phone: 717-249-3166 or 800-990-9108 . . HARRY P. SHAFFER, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA" vs" No. O~- ID'7{ QIUJ. ~~ CAROLYN M" SHAFFER, Defendant. Civil Action - In Divorce COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Harry P. Shaffer, who currently resides at 3803 Glenwood Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011 since February 2002. Plaintiff's Social Security No. is 164-36-7457. 2" Defendant is Carolyn M. Shaffer, who currently resides at 6232 Stephens Crossing, Mechanicsburg, Cumberland County, Pennsylvania, 17055 since February 2001. Defendant's Social Security No. is 219-44-3479. 3. The Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 1, 1980 in Dauphin County, Pennsylvania" 5" There have been no prior actions of divorce or annulment of marriage between the parties. 6. The Defendant is not a member of the Armed Services of the United States of America or its Allies. . . 7. The marriage is irretrievably broken. 8" Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling" 9" 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. Section 4904 relating to unsworn falsifications to authorities. IRA H. WEINSTOC P.C. 800 North Second Street Harrisburg, P A 17102 Phone: 717-238-1657 BY:~(~' ~-I-oc!L IRA H. WEINSTOCK t~ ........ -- H ~ w r-- ..0 V) (J ~ ........... ......... ~~0 ~ 0 ~ I C C> fl~ tlf- '(, . , (') ~ \Jr-~.., m"-'I ~....'rr.: ~"'r zc (/)"" :::<;:.2: '-c $' ZO ~-(-" .P <..:: Z =< c> f"J (---; -'q ;;: -- .... T' "'F'''G itl f"t 't' ,-'- ....... '<_) ...tJ ,', ::;~ ~TJ ,.. ) ~.... .;.C) ;gm ::0 -<: ;;.l'.;J r .c- ..,.., ::Ji (.0, w) .s;:- HARRY p" SHAFFER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs" No" 02 -1071 Civil Term CAROLYN M" SHAFFER, Defendant. CIVIL ACTION - IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Divorce regarding the above-captioned matter. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, P A 17102 Phone: 717-238-1657 ,) I By: VlQ ff " L~;"\.4{a\L IRA H "WEINSTOCK Attorney I.D" No. 01602 (") Cl ~ C '" ;;:: ". .-.~ '"Om "'0 :r nlnl :;;0 n'?!1 2::0 -vm 2~ <:xl c3g ci5 ,; ;:So J> -~,;j :ri :< t")~D ~o ::J: '2-0 "'-m );;0 - 0 ~ .. ~ W .0 -< HARRY P. SHAFFER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No" 02 - 1071 Civil Term CAROLYN M" SHAFFER, Defendant. CIVIL ACTION - IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Divorce regarding the above-captioned matter. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, P A 17102 Phone: 717-238-1657 By: \, O'-Q t-( . 1X'~'~ vrft,dL, IRA H" WEINSTOCK Attorney I.D" No" 01602 , '!,-I'iiii~~,Jii~!tfi,".mlIJ......~;,_, .. ,"",,",'",,,,,,,_Jii',,,,.,, (') c::> ~ ~ N C- ..... -00.' c= ..,.. ~93 % i1i:!! .- --m ~S; N ;:9,9 ~~ ?o -0 :2=\) ~8 ::Ii: Q(') ~ ~rn :;>c: ~ ~ N ~ 0'