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Home My WebLink About06-2723 ... ...... C-o ("\ 0. ',E., {'r\.<J-.,: E:.. c... \.', ~\G <1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 06- J1J.:b CIVIL TERM S~(k~~ c-~~tS\d0"e \' Defendant (. \'\ Y.\oll IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE 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 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, I 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 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 . . ,.. . . C-O(\('\',t:. l\\O-,',f.. C.X, ~\O" Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA v. No. 06- ),/p-eML TERM S'x\QC\e.. c.....h,S\OP'M.\ C..t~\o'l Defendant IN DNORCE COMPLAINT UNDER ~3301(c) or Cd) OF THE DIVORCE CODE 1. P]aintiffis(\J(\(\.~_ cnQ.r.E.. C'--I~ '-\0(\ , who currently resides at i?'olo e.:.-\.(\~, \4\(~\\k)~ (' 0--- \',~\~ ? A \,0\<" Cumberland County, Pennsylvania. 2. Defendant is dhn(\ e C hr-; S~<\'n~ ( C r\ i-.\on who currently resides at q'1~ ~,~ ~""'('\~ U Sh'W(\"'Y'llX~ QA \t:+s'l 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on _\Uf"'\ f' ~{l, dO(),<, at , C..JJ.rY'I'if 0.c.L1'\ Q r (\1\1\ kl C' OIue + \\Oll'\f I 5. The marriage is irretrievably broken, and the parties separated on fY\ c...,C'<\ 1?') ~n()lo 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. .. ~ . '.. .. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ~-).I-olo Date ~p iff, Pro Se C'?c I, ({')()r<,f_ (' \ ~ \=- \.C)f), verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. ~4904. ~ - ). \ - Olo Date: Plamtiff, Pro Se Assisted by: Marylou Matas, Esquire Saidis. F]ower & Lindsay 26 W. High Street Carlisle, Pennsylvania 17013 (717) 243-6222 o c. ;.l~:, 'i1 ;~! I [1! ~.\l "~,I' ..!- '7C - '(I"J.' \,'-'.. ~('- 'j;t-. ~'~~ r-.> c:.? ,,"0> d' ::0: ~ : ,,~ - Q. ~:):l ;~~ "':::\~~l .:t:-r\ 90 <'.~"' (fl 9 ~ N -0 :> - .. - o Ctnme. fYJ<<-.ne. C/t-f/D, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA Shh7e v. CJ.mlol'l1k' C /; f/lJ., Defendant : NO. 06- "z"7,).J CIVIL TERM : DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kind]yallow, Connie Marie Clifton , Plaintiff, to proceed in forma pauperis. I, Marylou Matas, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ~a~~ M atas' Attorney for Plaintiff 26 W. High Street Carlisle, P A 17013 (717) 243-6222 (') ~ ~ "'" f:', "'" --' ~,.. :s: ~~. -oi.:i,' :::<. rnf' ~ ;:'~~' - 13 (.f.~", N ~, -<:.- 7\ 1:" >: :s ~p. .c. ~ ~-f: -- Q - i PC " ~ - 0 - , I SAIDIS, FLOWER & LINDSAY AI l' -".RWQ'lAW 26 West High Street Carlisle,PA II CONNIE MARIE CLIFTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 06-2723 SHANE CHRISTOPHER CLIFTON, : Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, MARYLOU MATAS, Esquire, being duly sworn according to law, hereby deposes and says that on May 16,2006 she served a true and correct copy of the Divorce Complaint upon Shane Christopher Clifton., by mailing those documents to his address at 973 Big Spring Road, Shippensburg, PA 17257 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, May 18, 2006. Respectfully submitted, SAlOIS, SHUFF, FLOWER & LINDSAY ~ Dated: '5 / 2- ~l () 10 Marylou Attorney .84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff , (") r-.> 0 <= c = -n ",.Y. O' _'h ==2 :'::;r;l<o n1E -< -1'"11' , N ~:] C;:J (.n {~~3 (::,~ ~.__.~ -T" :>> -;;:?c:') :z t)lfl -, .r::'. '> ..,,-{ W "".:0 -( N '< ~ . o ~ ri~L z :-~ro~ 7r~ ~~";; i'::0 ~ ~('J ,...., = = 0'." :::JJ: ~ -< N <Jl , ~ ::< SAIDIS, FLOWER & LINDSAY ATIOIlNlMMr.\AW 26 West High Stteet Carlisle, PA II CONNIE MARIE CLIFTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2723 v, SHANE CHRISTOPHER CLIFTON, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed May 12, 2006, 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 of a final Decree in Divorce after service of notice of intention to request entry of the Decree, I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief, 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: \0 J q lo~ DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST E RY OF A DIVORCE DECREE UNDER~ 3301 ecl 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 if I 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 to the best of my knowledge, information and belief. 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:~ ~~ OCT 1 1 'Z(dJ ~ ~ ~ $ 0 s! ~~! ~ ~~ ,r-p zr' - -09 @J~ 0) go =<..i:-: ~c.. ~ :J:. ::;; pc. (::> - 2?O 26 om 'j>c: '.f? ~ z ~ :.t cJ' J;:" C-O~0.-,~ \Y'-.C?.-.('\~ C\: ~\P", Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, NO.06- c;}1'J3 CIVIL TERM s~~<\ ~ Ur :~c:R~-e( c.x,~\o{) Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1, A cOl1)plaint in divorce under S3301(c) of the Divorce Code was filed on ~ /cJ, dODfo , ~ 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 of a final decree of divorce after service of notice of intention to request entry of divorce, 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 aute ' Date:J9 q l t>tp Signatur , , Plaintiff " (") t;; ~-. r-:> = = c;ro o ;;J -i N (j\ :::0<' :;JI:,':. '-P. N s::- ~ ~~ -om -bO 0.,)(-,) :.~~ ~~.~~ :20 :Sr11 --I --po ~ COn n', tS \<\.0 (': E- CJ: ;--\(..)V"") Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, No. 06- d7J.3 CIVIL TERM ~ hQ,- f) €.- ~'^~ '&\cR"'-\:[ ~\. f\o~ Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date:~ Signat/~ c~ ' Plaintiff , L I"..) = 0 = 0' .." C) s:! n -~ r11 :!1 ,- N -elm en :ny ,::) () { - ...J...<"\); ~_-;- -f I .....-.''''" (' :5 :r~~ _.;:'~'o- ':>(') .....-.:.. VJ on'; :-l =~ 1') ~ ,r.' -< SAlOIS, FlDWER & LINDSAY XrIORNEYS.ATolAW 26 West High Street Carlisle. PA CONNIE MARIE CLIFTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2723 v, SHANE CHRISTOPHER CLIFTON, : Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on October 9,2006, via acceptance of service. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: 10/09/06 and filed with Prothonotary on 10/26/06 By Defendant: 10/09/06 and filed with Prothonotary on 10/26/06 4. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: 10/09/06 and filed with Prothonotary on 10/26/06 By Defendant: 10/09/06 and filed with Prothonotary on 10/26/06 t ? ,~ //v ~ It eu. V . 'l{.] Marylo Matas, Esquire SAIDIS; SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: f II '1/ ( L~ ........, ~~ C'"' -, ~n (}", --C) --..,'" "-... r:..~j "--:.0 ~~~ r..,~) G ,.,,., ~ '" ,., ,., 1Ii~ "'~~1Ii~;f.;f.""~ ~ ot';f. ,.., ~ If. If. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. CONNIE MARIE CLIFTON No. 06-2723 VERSUS SHANE CHRISTOPHER CLIFTON DECREE IN DIVORCE AND NOW'~ 27-.. CONNIE MARIE CLIFTON ~ IT IS ORDERED AND DECREED THAT , PLAI NTI FF, AND SHANE CHRISTOPHER CLIFTON , 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 EN~ PROTHONOTARY If.lf.;f. If. If. ;f.lf.lf. If.lf. If.;f.;f.~lf.lf. If. If.~lf. ~lf.~;f. ~~lf.lf.~ If. ~~~~~~~~lf.lf. J. , h ? ~ ~#, ~. J - e! ~U/~? ~~~~~ ~, I-e! .I .