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Home My WebLink About02-2422 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 0).. ).,/.:2.1.. CUrJ. r~ JEFFREY SCOTT DAVIS Plaintiff SHANNON KAY DAVIS Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM ~IGHTS 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 within twenty (20) days. 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 import 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, York County Courthouse, 28 East High Street, York, Pennsylvania. IF YOU DO NOT FIE 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 Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 JEFFREY SCOTT DAVIS Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. C!,)... ,),,'-/-'-2.. ~ T-,-",- SHANNON KAY DAVIS Defendant CIVIL ACTION - 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 within twenty (20) days. 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 import 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, York County Courthouse, 28 East High Street, York, Pennsylvania. IF YOU DO NOT FIE 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 Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 - " JEFFREY SCOTT DAVIS Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 0.2. .2 'f2~ ~ 1.....- SHANNON KAY DAVIS Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. Plaintiff is JEFFREY SCOTT DAVIS, an adult individual who currently resides at 215 West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is SHANNON KAY DAVIS, an adult individual who currently resides at 41 Landvale Road, York Haven, York County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at lease six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on Septemper 10, 1991, in Lewisberry, York County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. ~ , 7. Neither the Plaintiff or Defendant is a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. 9. Plaintiff avers that there are two (2) children of the parties under the age of eighteen (18), namely: Randi Jean Davis, DOB 10/10/93 Kenneth James Davis, DOB 3/19/99 WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in Divorce dissolving the marriage between the parties pursuant to Section 3301(c) of the Divorce Code of 1980, as amended. Respectfully submitted DATE: 5/ /5/0,2 Fr cis M. Socha, Esquire 01 North Second Street Harrisburg, PA 17110 717/233-4141 Attorney for Plaintiff i' VERIFICATION I, JEFFREY SCOTT DAVIS, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. f- /Fro.)- .. . JEFFREY SCOTT DAVIS, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. SHANNON KAY DAVIS, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Carrie E. Cook, secretary to Francis M. Socha, Esquire, hereby certify that a true and correct copy of the foregoing Complaint was sent by United States mail, postage prepaid, certified mail, restricted delivery, return receipt requested, to the following: Shannon Kay Davis 41 Landvale Road York Haven, PA 17370 Date: ... . ~ (") 0 p r ~ ~ N ~ ~ "'00:) :z: mrTl "'" :.:;:t ~ 2::rj -< ZC !'-11 :T1 .... S;9L; ..rr )., ~ r-:OC) -' ~_d~ ~ '"' ':.J , -'I ZC) "'" ~-..~ J Iv "l ::i:: ,i".' 5> C) '..ii:i -.l - c: 'R CC'O ~ ~ ?j (5m ." ?G cr ....., C'J -< :IE 05/02/2003 11:27 71 78466665 GLENN C VAUGHN PAGE 02 IN THE COURT OF COMMON PLEAS 0' YORK COUNTY, PENNSYL V ANlA Se~d Sro-t\" ~IJ \ S , Plaintiff No. 0;;) - ';;;2 4 ~~ v. : CIVIL ACTION - LAW s mn no tl ~Q~ "Del u \ ~ , Dcfcudant IN DIVORCE NOXlCR TO R'E..qUME 'PRrO~SUJllY A.MR Notice is hereby given that the Plaintiff1.Defendant in the above matter. [select ODe by marking "'X"] ~ prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree ill Divorce dated h<irel>y ._ to """"'" the prior !III1'IIaIIle of &w ~ee... . lIIIll gives tills ....-_ avowina hislhcr intention. pursuant to the provisions of S4 P .S. 704. DAtE: 5 ~o.-3 ~ilJlM1{, r\. ~ Signature 8fuw~u!>~~ COMMONWEALTH OF PBNNSYLV ANlA. ss COUNTY OF YORK. On the ~ day of ~ . 20 #3 . before me the ProthOtlOWy or a Notary Public, pClS9D8lly appeaxedih~ afftrmt kno"Vll tome to be the person whose :nllU)e ~ subscribed to the within docuinent lIIKi ackDOW'lqed. thu helshe executed the forejOing for the purpose therein contained. In Witness Whereof, I have huunto lIet my hand and official seal. ~~ NOTARiAL llAL fIfWIC8I CI. ROIl, NOTARY PUaUC II\' ~C:LE BORO, C~"L.Me CO. 110M IXPIIES NOWlllltllt.._ , ...-....-."'..,-"'.-........-.-----.---- r<'-""'-"""". "~-~..._,,,.......,.,.. J~} "~~.. :)tJ'!:U~ V"-.f. T <i. <~ -:( '.):1 ft....,J'I ., ~". J ;.'''''>. o:.s: A.'!P'" .~.,...:...' : (") 0 0 C w -(1 s: :x \JCO :r- q;! (II -c: 'JJ L- _-L' .'n Z C I -",--'1 f-~1 ~:> N -,.- 1 r-r- Q <:: --' ..-"'{) .~'.~~ ~(.: ~ );>C' r:-? ,,<m C- .,...) Z --I ~ '" 55 \.0 -< .:;..>'",,-'~"""""'" ...,.~,.~." I '." ,..' \ _i,.n", '.' . ,~'''~,~~.:~j vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2422 CIVIL ACTION - LAW IN DIVORCE - 330I(d) JEFFREY SCOTT DAVIS SHANNON KAY DAVIS AFFIDA VIT UNDER SECTION 330UdJ OF THE DIVORCE CODE NOTICE TO THE DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. 1. The parties to this action finally separated July I, 2000, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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. g4904 relating to unsworn falsification to authorities. Date: CZ)'Ijos- SlUW/; f7 (~ Shannon Kay Dav JEFFREY SCOTT DAVIS vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 02-2422 CIVIL ACTION - LAW IN DIVORCE - SECTION 3301(d) SHANNON KAY DAVIS COUNTERCLAIM IN DIVORCE I. The date of final marital separation of the parties was July 1,2000, and therefore the parties have been separated for two years. 2. The marriage remains irretrievably broken. 3. Counterclaim Plaintiff, Shannon Kay Davis, does not desire marital counseling and believes that it would be futile. Marital counseling has not been requested. WHEREFORE. Counterclaim Plaintiff requests your Honorable Court to enter a Decree divorcing the parties from the bonds of matrimony on the basis of a two year separation and irretrievable breakdown of the marriage. ,,~~/ Glenn C. Vi gh Attorney fo VERIFICATION 1, Shannon Kay Davis, hereby verifY that all of the statements made in the foregoing Counterclaim in Divorce are true and correct, upon my personal knowledge or information and belief. 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: cfl/1)6- ~ ~ ~ 'shan~1i~av;s' ~ vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2422 CIVIL ACTION - LAW IN DIVORCE - 3301(d) JEFFREY SCOTT DAVIS SHANNON KAE DAVIS CERTIFICATE OF SERVICE AND NOW, this 13th day of July, 2005, I, Glenn C. Vaughn, Esquire, hereby certify that I have served a copy of the Counterclaim in Divorce and Affidavit Under Section 3301(d) ofthe Divorce Code upon counsel of record for the Plaintiff, Frances M. Socha, Esquire, 220 I North Second Street, Harrisburg, P A 17110 by regular mail dated March I, 2005. I further certify that no response to the Counterclaim or to the 330 I (d) Affidavit has been received. ,L~~ Glenn C. Vaug, re 22 South Beaver Street York,PA 17401 (717) 845-9689 J.D. No 07484 o s; ~~; :::-~ -< ,...., = = c.n '- (=: r-. o " :J:I-n rnF -om -nO :'~.:;~~ g~? -.:;: :0 .< ~ 2;: 'D Ul ~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 02 -2'-/22. CIVIL ACTION - LAW ACTION IN DIVORCE - 3301(c) and (d) JEFFREY SCOTT DAVIS SHANNON KAE DAVIS CERTIFICATE OF SERVICE AND NOW, this 1st day of August, 2005, I, Glenn C. Vaughn, Esquire, hereby certify that I have served a copy of the Notice ofIntention to Request Entry of Section 3301(d) Divorce Decree by first class mail, addressed as follows: Frances M. Socha, Esquire 2201 North Second Street Harrisburg, PA 17110 C1 ~ -~~S ~,;c,; ~ ~ ~~ (;) tj, ~6~:.'C . ~~;~ ~ ~- q. ~::g ("'~ ....0.0 --;9i':<-;' ~':;"(} .~ -,. 'S-e::1 .;:.. (0 <::>, J:; ~ --0 ~~ - <? c OJ JEFFREY SCOTT DAVIS, Plaintiff IN THE CUlRT OF CCMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2422 CIVIL 19 vs. SHANNON RAE DAVIS, Defendant 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. Grounds for divorce: irretrievable breakdown under Section~ 3301 (d)(l) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: 5/12/05, by U.S. certified mail; Counterclaim for Section 3301 (d) divorce was served by ordinary mail on counsJ31** 3 . Canplete ei ther Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff by the defendant B. (1) Date of execution of the defendant'saffidavit requjred by Section 3301 (d) of the Divorce Code: February 14, 2005 (2) Date of service of the defendant' s affidavit upon the plaintiff: March 1, 2005 4. Related cla:ims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code 8/01/05, by first class mail **of record for Plaintiff on March 1, 2005. ~~/ Attorn ? [IDefendant ~ ~ ~,. '--:::.. (,,' ,..., '..:;; Q, -::-~ ff"'~ '~:?)(--<-~ -r.",l.'/ :%~)) '::?::.\;;\ Q\ -P' '::l "5'^, -::.~".. cB 5 ~ .... .. .. u.. :+.:+.:f.:+:tf.:+.:f.:f. :Ii :+. :+. :+. :+. :+. Of. +. +. ++ .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. u.. .. .. ...... .... ..u :f.:f.+:f.:f.+'+++:f.:+'+'++++++:f.:f. IN THE COURT OF COMMON PLEAS STATE OF .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. JEFFREY SCDTl' DAVIS VERSUS SHANNON RAE DAVIS .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. "'Of Of.:+. + :+. :+.:+. Of AND NOW, DECREED THAT OFCUMBERLANDCOUNTY PENNA. No. 02-2422 CIVIL 1 9 DECREE IN DIVORCE ~j'e-W /'/" 2005, IT IS ORDERED AND JEFFREY SCDTl' DAVIS , PLAINTIFF. AND SHANNON RAE DAVIS , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT :+. Of +. :+':+.:f. ~()IJ~ +'+'+:+. '+''F.:+. J. .. .. .. .. .. . .. .. PROTHONOTARY .. .. .. .. :f.:+.:+.:+.+++++ :+.++:+.+:+.:+.+++++~ +:+.+:+.++ :+''+':+';1'+ +:+. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ~/l ~ ~. ~ ~K, jc?~ P -o>-~~-fl- ~~ -.Jc'{} 5o,o:~~b '. ..,~ ' . ..~. .- '. ..... e5 ,c:p:-- JEFFREY SCOTT DAVIS SHANNON KAE DAVIS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 02-2422 ACTION IN DIVORCE SECTION 3301(d) vs. NOTICE OF INTENTION TO REOUEST ENTRY OF ~3301(d) DIVORCE DECREE TO: JEFFREY SCOTT DAVIS, Plaintiff You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the g3301(d) affidavit. Therefore, on or after August 25.2005 , 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 ofthe 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. Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (717) 249.3166 or (800) 990-9108 (in PA only) f-.) c::.~> C) ',.~l -'1'1 ~;.._n .-1 :r: ["11 r,j d (",.)