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F: \User Folder\Firm 00C5',Gendocs2006\3938-1 d;vcomplaint wpd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plaintiff
v.
CIVIL ACTION - LAW I' . (C
NO. 2006- Iq~b c.!/ull TSa-~
TIFF ANI M. DAVIS,
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 orreliefrequested 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 at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is
kept as a convenience to you and you are not bound to choose a counselor from the list. AI1
necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within twenty (20)
days of the date on which you receive this notice. Failure to do so will constitute a waiver of your
right to request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plaintiff
v.
CNILACTlON - LAW L,-.
NO. 2006- /'1&(., CIULl 102...1
TIFF ANI M. DAVIS,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this 4- +1l day of April, 2006 comes Plaintiff, Matt R. Davis, by and through
his attorneys, Knight & Associates, P.C., and files the following Complaint in Divorce, and in
support thereof avers as follows:
I. The Plaintiff is Matt R. Davis, who resides at 3 Park Street, Mt. Holly Springs,
Cumberland County, Pennsylvania 17065.
2. The Defendant is Tiffani M. Davis, who resides at 1704 Whitcomb Road, Forked
River, New Jersey 08731.
3. The Plaintiff and Defendant are sui juris, and Plaintiffhas been a bona fide resident
of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months
immediately preceding the filing of this Complaint in Divorce.
4. The parties were married on December 27, 2002, in Ocean County, New Jersey.
5. The marriage is irretrievably broken. The foregoing facts are averred and brought
under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended.
6. The Plaintiff has been advised ofthe availability of counseling, and that the Plaintiff
may have the right to request that the Court require the Parties to participate in counseling, and
Plaintiff waives same.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintiff from the Defendant.
Respectfully submitted,
. Shultz,
Attorney ill No. 90946
II Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
.
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered by
my counsel in the preparation ofthe lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint in Divorce and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
~~~~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plainti ff
v.
CIVIL ACTION - LAW
No. 2006-1966
TIFF ANI M. DAVIS,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
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AND NOW, this ~day of April, 2006, I, Sean M. Shultz, Esquire, hereby certify that the
following person was served with a True and Correct copy of the Complaint in Divorce filed in the
above-referenced matter. The Complaint was mailed on April I 0, 2006, but actual service took place
on April 14, 2006, by Defendant signing for a copy of the Complaint in Divorce which was mailed
in the United States Mail, Certified MailnReturn Receipt Requested, Restricted Delivery, Postage
Prepaid, addressed as follows:
Tiffani M. Davis
1704 Whitcomb Road
Forked River, New Jersey 08731
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof
Respectfully submitted,
F\Uscr FolderlFilw Do;::sIGendocs2006\393S-lcertservk<:.wpd
M. Shultz, e
Attorney ID No. 90946
II Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
1, Article Addressed to:
)jffCttl j N)' ba ViS
1104 Wh~icVW1~ M.
t1rkfd Q'iV'f(j t\JV-
()n31
2. Micle~
(Trans,"
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B.
D. Is delivery address different from item 1?
If YES, enter delivery address below:
3. Service Type
~ertified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
o C.OD.
4. Restricted Delivery? (Extra Fee)
es
.7005 1160 0002 1108 9537
102595-02-M-1540
PS Form 3811 , February 2004
Domestic Return Receipt
--.1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plaintiff
No. 2006-1966
In Divorce
v.
Civil Action - Law
TIFFANIM. DAVIS,
Defendant
AFFIDAVIT OF CONSENT
STATE OF PENNSYLVANIA
)
: SS.
)
COUNTY OF CUMBERLAND
1.
5, 2006.
A Complaint in divorce under Section 330 I (c) of the Divorce Code was filed on April
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry ofa final Decree of Divorce after service of notice of intention
to request entry of the Decree.
4. 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 prior to a Divorce
Decree being handed down by the Court.
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.
Date:
114
,2006
~~~
Matt R. Davis
!horn to and sUbJf;t~fore me this
ih day of , 2006.
Nl*IIIBI SeoI
Daly M. HouBel. NoI8IY Ptdc
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATTR.DAVIS,
Plaintiff
No. 2006-1966
In Divorce
v.
Civil Action - Law
TIFF ANI M. DAVIS,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER 6330HC) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that! may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
3. I un?erstand that I will not be divorced until a divorce decree is entered by the Court
and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary.
I verify thatthe statements made in this Mfidavit 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: ~, 4-/ DL!
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plaintiff
No. 2006-1966
In Divorce
v.
Civil Action - Law
TIFF ANI M. DAVIS,
Defendant
AFFIDAVIT OF CONSENT
COUNTY OF ~
)
: SS.
)
STATE OF NEW JERSEY
1.
5, 2006.
A Complaint in divorce under Section 3301 ( c) ofthe Divorce Code was filed on April
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry ofa final Decree of Divorce after service of notice of intention
to request entry of the Decree.
4. I have been advised ofthe availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling prior to a Divorce
Decree being handed down by the Court.
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.
Date: /LJ - 3 -CJ ~ , 2006
~??'
. ani M. Davis
--
Sworn to and subscribed before me this
3M day of &.L;;Z;LI ,2006.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plaintiff
No. 2006-1966
In Divorce
v.
Civil Action - Law
TIFFANI M. DAVIS,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses in 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.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATT R. DAVIS,
Plaintiff
v.
CIVIL ACTION - LA W
NO. 2006- 1966
TIFF ANI M. DAVIS,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please 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 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: served on Defendant by United States
Certified, Return Receipt Requested, Restricted Delivery Mail on April 14, 2006.
3. Date of execution of the Plaintiff's Affidavit of Consent required by Section 3301 (c)
of the Divorce Code; August 4,2006; by the Defendant; October 3, 2006.
4. Related claims pending: None.
5. Date Plaintiff' s Waiver of Notice in ~ 3 30 1 (c) Divorce was filed with the Prothonotary:
August 9, 2006.
Date Defendant's Waiver of Notice In ~3301(c) Divorce was filed with the
Prothonotary: October 25,2006.
Sean M. Shultz, EsqUIre
Attorney LD. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Plaintiff
Date: October 24,2006
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
f0o'Ve~beJ 3
MATI' R. DAVIS
MATI' R. DAVIS,
Plaintiff
VERSUS
TIFFANI M. DAVIS,
Defendant
AND NOW,
DECREED THAT
AND
PENNA.
No. 2006-1966
DECREE IN
DIVORCE
2006 IT IS ORDERED AND
, PLAINTIFF,
TIFFANI M. DAVIS
, 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;
N/A
By THE COURT:
ATTEST:
ROTHONOTARY
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