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SYLINE M. SHINGARA,
Plaintiff
VS.
JOHN M. SHINGARA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMEBRLAND COUNTY, PENNSYLVANIA
NO. «o - S79/ e-,. i. 76 "
CIVIL ACTION- AT LAW
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 at the 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 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, PA 17013
(717) 249-3166
SYLINE M. SHINGARA, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMEBRLAND COUNTY, PENNSYLVANIA
VS. : NO. dC. - SIq j l tr ` F?'Y?
JOHN M. SHINGARA, : CIVIL ACTION- AT LAW
Defendant : IN DIVORCE
DIVORCE COMPLAINT WITH EQUITABLE
DISTRIBUTION CLAIM
The Plaintiff, Syline M. Shingara, by and through her attorneys, The Law Offices of
Patrick F. Lauer, Jr., makes the following Complaint in Divorce:
COUNT I-NO FAULT DIVORCE--§§ 3301(c) or 3301(d)
1. The Plaintiff, Syline M. Shingara, is an adult individual currently residing at 2907
Westbury Court, Apartment 709, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. The Defendant, John M. Shingara, is an adult individual currently residing at 50
River Road, Selinsgrove, Snyder County, 17870.
3. The parties have been bona fide residents of the Commonwealth of Pennsylvania
for at least six months immediately prior to the filing of this complaint.
4. The parties were married on July 22, 1972 Biloxi, Mississippi.
5. There are no minor children to this marriage.
6. A complaint for divorce was filed in 1981 in Northumberland County,
Pennsylvania, that has since been purged.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff
may have the right to request that the court require the parties to participate in counseling.
9. This action is not collusive.
WHEREFORE, the Plaintiff requests this Honorable Court enter a decree of Divorce in
this matter.
COUNT II-EQUITABLE DISTRIBUTION--§ 3502(a)
10. Paragraphs one (1) through nine (9) of this Complaint are incorporated herein by
reference as if set forth specifically below.
11. During the course of the marriage, the parties acquired property and incurred debt,
titled jointly, individually, or both, which remains in possession of the individual parties.
WHEREFORE, the Plaintiff respectfully requests the Court to equitably divide,
distribute, or assign the marital property between the parties in such proportion as the court
deems just after consideration of all relevant factors and thereby enter an order of equitable
distribution of marital property pursuant to §3502(a) of the Divorce Code.
Date: -04
Law Offices of Patrick V..'Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011
ID# 200952 Tel. (717) 763-1800
Respectfully submitted,
SYLINE M. SHINGARA, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMEBRLAND COUNTY, PENNSYLVANIA
vs. :NO. V iL. 1 i/lty?
JOHN M. SHINGARA, : CIVIL ACTION- AT LAW l
Defendant : IN DIVORCE
VERIFICATION
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. § 4904, relating to unswom
falsification to authorities.
Date: O
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SYLINE M. SHINGARA,
Plaintiff
vs.
JOHN M. SHINGARA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2006 - 5194
CIVIL ACTION- AT LAW- IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw the appearance of Shana M. Pugh, Esquire, in the above-captioned action
as the Plaintifft, Syline M. Shingara is entering her appearance pro se.
Respectfully submitted,
Shana M. Pugh, Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
Date: lO A610 6 ID# 200952 Tel. (717) 763-1800
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Syline M. Shingara, Pro se, in the above-captioned action.
Respectfully submitted,
e M. Shingara, Pro se
2907 Westbury Court, Apt. 709
Date: 0 p Camp Hill, PA 17011
(717) 761-4028
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Curtis R. Long
Prothonotary
Office of the i3rotbonotarp
Cumberrarib Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
nb -519V CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573