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Home My WebLink About06-1614 \. REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE JASON SHEARER, Defendant : NO. f)!-o - /Id'l CIVIL TERM 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA Y BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JASON SHEARER, Defendant : NO. 0(., - JUY CIVIL TERM DIVORCE COMPLAINT The plaintiff, Ms. Rebecca J. Shearer, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. !l!l330!(c) AND 330!(d) OF THE DIVORCE CODE I. Plaintiff is Ms. Rebecca 1. Shearer, who currently resides at 455 North Pitt Street, Carlisle, Cumberland County, PAl 7013, since February 2006. 2. Defendant is Jason Shearer, who currently resides at 23 Mt. View Terrace, Newville, Cumberland County, P A 17241. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on June 27, 1998 in Newville, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have Jived separate and apart since March 2001. 6. There have been no prior actions for divorce or for annulment between the parties. 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. ". WHEREFORE, Plaintiff requests the court to enter a decree of divorce. \S'c;vUvf\ 'f- f2.u.,~~ Sarah Rubright Certified Legal Intern /,;iu:J-: \, vROB . RAINS THO AS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorney . Lee) .- CU&.JiX F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle,PA 17013 (717) 243-2968 Fax: (717) 243-3639 '~ ~ "~~~ '~\ ~: ~ '\ ~, '\-A" c, " ;.;; C) C ......... \~_:~~ d" ::{: .~,,-' ::....-., /" f"-' - (A -\ -c -f1 rnr:-~ -n;:!'~ ,)'-/ >, ~-~ -r'~ ~,," ;;~!rl, ~1?,:"~ .~, ..... ~7? r') -, VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. !l4904, relating to unsworn falsification to authorities. Date ,5- ft-/ 00 Plainti0<d1'h ~ 5J;/~ Ms. Rebecca J. earer REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JASON SHEARER, Defendant : NO. t'&- -1M'! CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Rebecca J. Shearer, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date sld/lC'b Respectfully submitted, \JOv'\P~h ~ I2\Ab~\, Sarah Rubright Certified Legal Intern i.1."i_,,/\ ! \ () "II ..-' -......_ \... ~ t\.__... '/...". " OBE RAINS THOM S M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 r~,') '::-=l C:;;) ':.r~ o -n :r!- rn.d~ -rtm ~..cIO '..')(\ ......!:.... .'; :~j ;C) ;:~S;Tl ~ .-< :!~: ~C:--,. :;.0 "" :X:.~ .---.. c: ~ ,_.~. REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JASON SHEARER, Defendant : NO{7erp,/1/ CIVIL TERM AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I. The parties to this action separated in March 200 I and have continued to live separate and apart for a period of at least two years. 2. The marriage of Plaintiff and Defendant 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. Date J - /7-()C caC:o",,", a,-,5A(7/p~tG// Rebecca J. Sh:aJr, Plaintiff n c~ ,-." ~;::~ c.'...... o "i1 ,-l fr,:n e- rr: C;J C' :;0 r".) ,., Cj }l. ':..- :'17 ...< CJ _J REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JASON SHEARER, Defendant :NO. 06 1614 CIVIL TERM CERTIFICATE OF SERVICE I, Sarah L. Rubright, Certit1ed Legal Intern, Family Law Clinic, hereby certifY that I served a true and correct copy of the Divorce Complaint on Mr. Jason Shearer, residing at 23 Mt. View Terrace, Newville, PA 17241, by depositing a copy of the same in the United States mail. certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Jason Shearer, on the I st day of April 2006 as evidenced by the attached green card. U CUa ^ rJ. f&,~~ Sarah L. Rubright Certit1ed Legal Intern g J nston-Walsh, Esq. ising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 . Complete items 1, 2. and 3. Also complete rtem 4 ij Restricted Delivery Is desired. . Print yotlr name and address on the reverse so that we can return the card to you. . Attach this card to th& back of the mailpiece, or on the front if space permits. 1. Article Addressed to: J lbOY\ 5Vi,um y rJ "7 f'j'1 V It W1Ut1UL 01,:; NtWyi)'l.t,YY\- 1-1-dY\ D. Is delivery address dtfferent from If YES. enter delivery address below: f1P.ff'(~ to a 3. Ser)dCe Type l!!I" CertIfled Ma" o Registered o Insured Mail Drtlll D Express Mail o Return Receipt for Merchandise DC.O.D. PS Form 3811, February 2004 2 ^"':~I~ "'.,~..~~ . 7005 0390 0003 2632 6369 4, Restricted Delivery{ (Extra Fee) ~es Domestic Return Receipt 102595-02-M-1540 ,"-) C:l REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE JASON SHEARER, Defendant :NO. 06 1614 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint at the above-captioned docket. [.S.~^"'!\ l ~~~ Sarah L. Rubright Certified Legal Intern i 1 /( /))(:1/p~ tA_)(~-;Y;~~ William G. Martin, Esq. Supervising Attorney Date: t-f Il~ IDt,;, .-it --- Ms. Rebecca J. Shearer, Plaintiff v. Mr. Jason Shearer, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 06 - 1614 CIVIL TERM CERTIFICATE OF SERVICE I, Gillian Woodward, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Mr. Jason Shearer, residing at 1554 Majestic Drive, Chambersburg, P A 17201, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Jason Shearer, on the 11 th day of May 2006 as evidenced by the attached green card. I &:i- ~ u-I '6 C ::::::=-' c: 01 Gl'CfIlo -- .c: JfJl.~z ---- ~ Gl '0 DO .....,....J ::i: c;.:::1 .... "" .E ~ a. f5 ~ c::::3 = 'Qj 01 &l ~Q; u-J ::i:a:: ~~ t=- gj c: . l!! .... 0 i! c:"....:) a..ad )( Gl . ~ - wa::u ~ ~ c.-= ODD a-----=-- ~~ c-,/':) 'iU '0'0 ......, Gl::i:~~ ~~ ~i c:::-r= ~~~~ Gl 1:: .- ::l .2: cti '~'~ Giw '0>- ~ DO ..... (") Q) iii ~ ~ .~ _ > a. ~-Q e ::i 'alE O~Q)O (,).-.c>-Q) olll"o.c f1)'1'Jc:...... . ce.!!! ~"E!O~ M~lIl~tiE "CQ)eGlalGl r::: .2 "C .c.c a. llIGii"Q)Gl N'O"CE.sl'il ,..:ia~gi s lIlOQ)""n:!::: E'r:::Er:::c;.. al :m~~~~e ~ 'Q) a: ... ~.!!! - '0 Qj:t::S:>.s~ Jl. Q.v>>ai.s=.... Q) EE'E-5l'il!5 13 8~;tg~(; ~ . . :,. ~ ~ ~J: ~~ ()... ~'V {J~ tt~r .(\ ~ 1) VI ~ ~ .2.. ;>.J c "]"5 .n {l s:. tsJ) ~ -l-u ~ ~.f~W fIl j Gillian Woodward ~ Ii Certi ed Legal Intern ~ "J~ '" ~ 'i' Lucy Jo to -Walsh, Esq. u:. Supervising Attorney i "" FAMILY LAW CLINIC ~ .2: 45 North Pitt Street Gi 0 ,., al Carlisle, PA 17013 '0 .;: a. (717) 243-2968 gj .~ a:: .:r- Fax: (717) 243-3639 a:: ~ .:r- c: .:r- 5 .ll 'li5 a:: ru ! m .ll ru 8 m CJ CJ .... CJ CJ tr 8l m CJ Cl .... >- LI"l "3 CJ ""') - CJ .- I"- .- co C') E (; u.. (/) a. ~ c::> = 0..... ~,~ ~ ~.""" -<'. o -n -\ ::r:-.- n'r: --r1 rr, '.::JC) l~~~~; (~) _..!..., ...-', UJ -0 .....".. -- ;"";;:(~ ~111 ~ t)? --l ... REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JASON SHEARER, Defendant : NO. 06- 1614 CIVIL TERM DEFENDANT'S 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. ~904 relating to unsworn falsification to authorities. Date Mr. Jason Shearer ...'"' r-""',~ I..'-~) .'~-) -TI --4 7~ II. I U', c,.~\ C) I',: .., .. ",,, REBECCA J. SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYL VANIA v. JASON SHEARER, Defendant : CIVIL ACTION - LAW : DIVORCE : NO: 06- 1614 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: DEFENDANT 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 Tuesday, June 20, 2006, 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 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ......~." C:'"::l ~ (:-1 "rl -~ t en -ry (.) in c::' ...-<< ......... o REBECCA SHEARER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06- 1614 CNIL TERM JASON SHEARER, Defendant : CNIL ACTION - LAW : 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 and separation for two years under 9 330I(d) of the Divorce Code. 2. Date and manner of service of the complaint: service was completed on the 11 th of May, 2006 by United States mail, certified, restricted delivery. 3. Date of execution of the affidavit required by ~ 330I(d) of the Divorce Code: March 17, 2006; Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on March 17, 2006 and served May 11, 2006. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: Service by first class mail on May 30,2006. Date~ ~ Gillian Woodward Certified Legal Intern .;Jtap~ r.J~ Robert F: Rains, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire Supervising Attorneys .. ... ' F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 :--:1 j ;1 ( , , .' \,>.' ,-" .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . REBECCA J. SHEARER PEN NA. . . . 2006 . . . . . Plaintiff VERSUS . JASON SBEARER Defendant No. 1 hl L1 DECREE IN DIVORCE AND NOW, \. - ;/, L- ~, 'T " ORDER'D A'" --~ . DECREED THAT REBECCA J. SHEARER . PLAINTIFF, . 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 ENTER~r;~ !'J Ok!? . . . . . . . . . . . AND JASON SHEARER . DEFENDANT, . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . ~~:~ .K: ~A. 93' PROTHONOTARY . . . J. . . . .~.% "t/ r;,,, ~u; "O-hl'-,- -7:/ ;2- ~ ~-~ "'/O-;'/'L .