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Home My WebLink About06-6604IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF, VS. JUSTIN L. SHERIFF, Plaintiff Defendant Civil Action - Law No. 0to -4VYI Divorce C&D TO: JUSTIN L. SHERIFF, Defendant 432 Virginia Road Mechanicsburg, PA 17050 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 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, 1 Courthouse Square, Carlisle, PA 17013-3387. 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 Telephone 717-240-6195 FITH, ST CKLER, LERMAN, S O CALKINS BY: PET D. O S, ESQUIRE I. D. No. 0747 110 South No rn Way York, PA 174 Telephone (7 ) 757-7602 AVISO PARA DEFENDER Y RECLAMAR DERECHOS Usted ha sido demandado en la corte. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar acci6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decisi6n puede tambien ser emitida en su contra por cualquier otra queja o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County. Court Administrator Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013-3387 Telephone 717-240-6195 SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE 1NMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Adams County, Pennsylvania, is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact the county at (717) 334-6781. For those with a hearing impairment, please contact the Deaf Center at (717) 334-6781 ext. 213. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF, Civil Action - Law Plaintiff 't CLJ VS. No. 06-666 JUSTIN L. SHERIFF, Defendant Divorce C&D TO: JUSTIN L. SHERIFF, Defendant 432 Virginia Road Mechanicsburg, PA 17050 NOTICE AS TO COUNSELING You are hereby notified that counseling is available and may be requested by either party. Upon written request made to the Domestic Relations Office of Cumberland County, 13 North Hanover Street, Carlisle, PA 17013 both parties will be provided a list of qualified professionals who give counseling service. GRIFFITH, gRICKLER/LEFMAN, BY: _I V- I" k y'f _P1 PETER . SO OS, ESQUIRE I. D. No. 0747 110 South No ern Way York, PA 17 Telephone ( r17) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF, VS. JUSTIN L. SHERIFF, Plaintiff Defendant TO: JUSTIN L. SHERIFF, Defendant 432 Virginia Road Mechanicsburg, PA 17050 Civil Action - Law No. Divorce C&D COMPLAINT This ?aT.= day o la - '2006, comes the Plaintiff, VALEN E. SHERIFF by k' - 4m her attorneys, GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, by Peter D. Solymos, Esquire, and files this Complaint in Divorce, whereof the following is a statement: 1. Plaintiff is VALEN E. SHERIFF, an adult, who resides at 215 Catalpa Lane, Red Lion, PA 17356. 2. Defendant is JUSTIN L. SHERIFF, an adult, who resides at 432 Virginia Road, Mechanicsburg, PA 17050. 3. Plaintiff and Defendant have resided within the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint, and are both citizens of the United States of America. 4. The Plaintiff and Defendant were married on August 28, 2004 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. No children were born as a result of the marriage. COUNTI Divorce - 3301(c) - No-Fault 7. Paragraphs 1-6 are incorporated by reference. 8. The marriage between the parties is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code, divorcing Plaintiff and Defendant. COUNT II 3301(d) 10. Paragraphs 7-9 are incorporated by reference. 11. The marriage is irretrievably broken. 12. The parties were separated on June 30, 2006, and have remained separate and apart. 13. The Petitioner requests that a Decree in Divorce be granted under Section 3301(d) of the Divorce Code in the event they remain separated for two years or greater. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301(d) of the Divorce Code, divorcing Plaintiff and Defendant. GRIFFITH, STRICKLF*jR, LERMAN, S LYMOS ? 4 1, BY: PE R D Attorney o YMOS, ESQUIRE Plaintiff Supreme Court I.D. No. 07475 110 South Northern Way York, PA 17402 Telephone No. (717) 757-7602 VERIFICATION I verify that the foregoing facts are true, upon my personal knowledge or information and belief. This verification is made subject to the penalties of 18 Pa.C.S. '4904, relating to unsworn falsification to authorities. Date: 1 J C? ?rG VALEN E. SHERIFF 6 rv CD n ?-n CJl } t? ti }C ;3 VIA ?L.J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF, Civil Action - Law Plaintiff vs. No.: 0w I ? ?6 q JUSTIN L. SHERIFF, Defendant Divorce ACCEPTANCE OF SERVICE I, JUSTIN L. SHERIFF, the undersigned in the above-captioned divorce action, hereby accepts service of the Divorce Complaint filed herein by Plaintiff, Valen Sheriff. ///15- 16 Date Date SHERIFF WITNESS: ? ? COQ ? q ;'fwl ? i c cj, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF, Plaintiff Civil Action - Law VS. JUSTIN L. SHERIFF, Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK No.: 2006-6604-CIVIL TERM Divorce AFFIDAVIT OF SERVICE ss Before me, a Notary Public in and for said Commonwealth and County, personally appeared PETER D. SOLYMOS, ESQUIRE of the law firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, who being duly sworn according to law deposes and says that he caused to be served upon Justin L. Sheriff, Defendant, a copy of the Complaint for No Fault Divorce by causing a copy of said Complaint to be personally served on Defendant, as per Pa.R.C.P. 440, service being effectuated on said Defendant on November 15, 2006, as evidenced by a copy of the Acceptance of Service attached hereto. GRIFFITH RKLEY;/LERMAN, SOLY & CA KIN / BY: -/A/ L4 1 PETE)ft D. S S, ESQUIRE Attorney Plaintiff Supreme ourt I.D. # 07475 110 South Northern Way ADAMS, Pennsylvania 17402 Telephone: (717) 757-7602 SWORN AND SUBSCR before me this of; f t z XNV .'*- NOTARY PUBL B? t o day /200 v? Gt; qj) OI - "Q '- C? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF * Civil Action Law Plaintiff V. * Case No.: 2006-6604 Civil Term JUSTIN L. SHERIFF * Divorce Defendant AFFIDAVIT OF CONSENT UNDER 23 Pa. R.C.P. 3301(c) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 11/15/2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. 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. §4904 rutting to unswom falsification to authorities. ;71b, L. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C. §4904 t'ng t unsworn falsification to authorities. f JUS L. S FF n?-s ? ? . -' ?? ? -n r-_ . , .- - ,..? . ? ? ? cs? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF * Civil Action Law Plaints * Case No.: 2006-6604 Civil Term V. JUSTIN L. SHERIFF * Divorce Defendant AFFIDAVIT OF CONSENT UNDER 23 Pa. R.C.P. 3301(c) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 11/15/2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. 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. §4904 relatiQP9 unsworn falsification to authorities. V WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 904 relati uns o falsification to authorities. ff t-9 VAL SHERIF C= eo -e) (7° -' ? rr? r?.: ? -rz Cn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALEN SHERIFF, Civil Action - Law Plaintiff VS. No.: 2006-6604-CIVIL TERM JUSTIN L. SHERIFF, Defendant Divorce 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. Ground for divorce: irretrievable breakdown under (13301(c) of the Divorce Code. (strike out inapplicable section) 2. Date and manner of service of the Complaint: 11/15/06 via personally served. 3. (Complete either paragraph (a) or (b)) (a) Date of execution of the affidavit of consent required by 13301(c) of the Divorce Code: by Plaintiff 02/16/07; by Defendant 02/16/07 (b) (1) Date of execution of the affidavit required by '3301(d) of the Divorce Code: (2) (I) Date of filing of Plaintiff's affidavit upon respondent: (ii) Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: None - no claims raised. 5. (Complete either paragraph (a) or (b)) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in 13301(c) Divorce was filed with the Prothonotary: simultaneously herewith. Date the Defendant's Waiver of Notice in '3301(c) Divorce was filed with the Prothonotary: simultaneously herewith. GRIFFITH, STRICKLERhh LERMAN, sel-T' OS & Cif KINSj BY: PETER ttor YMOS, ESQUIRE At?n r Plaintiff Suprem Court I.D. # 07475 110 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 re co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. VALEN SHERIFF VERSUS JUSTIN L. SHERIFF No. 2006-6604-CIVIL TERM DECREE IN DIVORCE ci•,A. ?? AND NOW, IT IS ORDERED AND DECREED THAT VALEN SHERIFF , PLAINTIFF, AND JUSTIN L. SHERIFF ARE DIVORCED FROM THE BONDS OF MATRIMONY. 7 DEFENDANT, 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 6Atoo' PROTHONOTARY ??? ? ??? _ ??, -??? ,? ?? <?- ?i ??? ? ??''? ? -? Q_ C ?/- F ?.,,? , ? ?•'r. i 4 CUMBERLAND IN THE COURT OF COMMON PLEAS OF QOUNTY PENNSYLVANIA CIVIL DIVISION VALM SHERIFF Plaintiff vs IN DIVORCE JUSTIN SHERIFF Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/59MRM in the above matter, having been granted a Final Decree in Divorce on the 16th day of 2007 March , hereby elects to resume the prior surname of VALEN ELIZABETH COVER and gives this written notice avowing/her intention pursuant to the provisions of 54 P.S. 704. i DATE: 08/02/2007 ?al' Signatu e ELIZABETH SHERIFF Signature of name being resumed VALEN ELIZABETH COVER COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF YORK On the A6 day o , before me the Prothonotary / a Notary Public, personally appe red the above affliant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand,mpd official Notarial Seal - Dawn M. Foehrkolb, Notary Public Springettsbury 7\vp., York County My Commission Expires Oct. 13, 20107 File No. 06-6604 or Notary Public Member, Pennsvivs11? Rcgnriation of Notaries 0 -n C Cl " -rZ tttF yf" -o O C C- 90 41 CJD U3