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Home My WebLink About06-2350 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. ()(= - ,.::r~s(') C!.,~L Y8z.h[ HARVEY H. SHAPIRO, Plaintiff CHRISTINE S. SPANGLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 maniage, you may request maniage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, One Courthouse Square, 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 LA WYER 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 Phone: (7 I 7) 249-3 I 66 HARVEY H. SHAPIRO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VI. : NO. CHRISTINE S. SPANGLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, 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 this list. All 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. Prothonotary HARVEY H. SHAPIRO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VI1. : NO. tJI.c. - ,:} ~5/) G~~L 't<CR...~ CHRISTINE S. SPANGLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Harvey H. Spapiro, social security no. 579-56-4774, who currently resides at 10 Butternut Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Christine S. Spangler, social security no. 210-52-5588, who currently resides at 10 Butternut Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing ofthis Complaint. 4. Plaintiff and Defendant were married on August 14, 2002 in Oahu, Hawaii. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a mernber of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff requests the Court to enter a Decree in Divorce. II. This action is not collusive. WHEREFORE, the Plaintiff requests the Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: 4 -lr -0 (p By: Attorneys for Plaintiff Harvey H. Shapiro VERIFICATION I, Harvey H. Shapiro, verifY that the statements made in the foregoing pleading are true and correct. 'understand that false statements herein are made subject to the penalties of I 8 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Date: i- 2./ - 0 <-0 Harvey -l4. ( ., (::; - ..a ~ ;::) 0th \) ~ << , , U( U( ~ - - ~ .< -:t -() ~ --.oJ ., -l '<: L. - ---:t g - -:t ~ HARVEY H. SHAPIRO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2350 : CIVIL ACTION - LAW : IN DIVORCE CHRISTINE S. SPANGLER, Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this 2nd day of May, 2006, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Divorce Complaint was served on the Defendant, Christine S. Spangler, on May 1, 2006, by certified mail number 7004 2890 00014068 9299, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and subscribed before me this ~ YL.J. day of May, 2006. 9{~~o/ otary Public COMMONWEALTH OF PENNSYLVANIA NcIariaJ SeoI Maria B. LaRue, t-btary P\lbIIc Deny Twp., Dauphin CoIny My Commission ExpIres Nov. 8, 2llOll Member, Pennsylvania Association of Notaries ,,-.' . (' . ----- ~ ---.........-""f:~ _...~- _ ..~n_ _. _ __ -;~___ T....... --....,..-. . . ........- .' -. ..', ~ . 4' . ~.....,.. ! .___.....--011..- .... __..... CIII:I \O)W. . MIl:IllllllCIII:I......af...1 .'ne. _",..fnlnt If ~ pemlllL 1. .-AM uuf ~ c..hr\4tK S. Sr-~ \er \ C i>l.L.\4 f.,( (\ vJ- L CU'U.. n\lJ\l\1'\1 t.S ~ lAJ .5 L ......... ................. .....11I11, ........... 3.....__ ..-c..d.... C ......... P A- C Ill.) 1..d C lllUIlAlallplforlAJ - C ......... C c.o.D. n D$() .. _, "DoIoIoIy'I""''' 7DD~ ~I~O ODO~ ~D~I ,a" ----- I... ,_J.' . C1 ~~; ~ 'i?- ~ ... c' " t.~ ';t 3. ~ ,~'-{\ ..A "-'; ';'"\ . \ (. r " HARVEY H. SHAPIRO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2350 CHRISTINE S. SPANGLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO DISCONTINUE THE ACTION TO THE PROTHONOTARY: Please discontinue the Complaint in Divorce filed on April 26, 2006 in the above-captioned action. JAMES, SMITH, nmrrnRICK & CONNELLY LLP Date: q -- ~~-D (0 By: P.O. Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 HARVEY H. SHAPIRO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2350 CHRISTINE S. SPANGLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, John 1. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly LLP, attorney for the Plaintiff, Harvey H. Shapiro, hereby certify that I have served a copy of the foregoing Praecipe to Discontinue the Action on the following on the date and in the manner indicated below: u.S. MAIL. FIRST CLASS. POSTAGE PRE-PAID Christine S. Spangler 10 Butternut Lane Mechanicsburg, P A 17050 JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: q - ~ :l.{) Cf By: Jo A 0 P. . ox Hershey, PA 17033 (717) 533-3280 PA J.D. 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