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HomeMy WebLinkAbout06-6650Jodi Shinault, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW : IN DIVORCE Terrance Shinault, Defendant : N0.06- (o(osU CIVIL TERM 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County 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 our office. 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. Jodi Shinault, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE Terrance Shinault, Defendant : N0.06- ~ G So CIVIL TERM DIVORCE COMPLAINT The plaintiff, Jodi Shinault, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S ~§& 3301 (aZ(6) 3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Jodi Shinault ,who currently resides at 222 1/2 South Enola Drive Enola, Cumberland County, Pennsylvania 17025 since on or about June 1, 2004. 2. Defendant is Terrance Shinault, who Plaintiff believes is currently residing at 7073 Carlisle Pike, Lot 80 Carlisle, Cumberland County, Pennsylvania 17013, since on or about June 10, 2006. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on June 1, 2000 at Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since June 10, 2006. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Defendant has offered such indignities to Plaintiff, who is the innocent and injured spouse, as to render Plaintiff s condition intolerable and life burdensome. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Samara Gomez Certified Legal Intern ~/1 ~a~~ ?.C - ROBE E. RAINS THO S M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date J di Shinault Jodi Shinault, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~. :CIVIL ACTION -LAW IN CUSTODY Terrance Shinault Defendant NO. 06-L~UCIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Jodi Shinault, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ~~ ~ ~ Respectfully submitted, Samara Gomez Certified Legal Intern ROBER THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~ (_ -. i ~J ~ c_ ; `[..j ~ ;- ,..._ --t ,'["i -~- ~-- t .,. ~, ~. -.i -.. Jodi Shinault, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Terrance Shinault, Defendant : N0.06-6650 CIVIL TERM CERTIFICATE OF SERVICE I, Samara Gomez, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Terrance Shinault, residing at 7073 Carlisle Pike Lot 80, Carlisle, Pennsylvania 17013 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Terrance Shinault, as evidenced by the attached green card, which was received signed by the defendant in the office of the Family Law Clinic on or about December 5, 2006. 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F..~ ~,,~ 2. 705 0340 0003 2632 6017 PS Fo~rr~6"F#,"f'~01~ WMM~Oa M11Mrn IIw~1pt yam-M-~~o ; _.u . _ . ___ _ _ _ _ JODI SHINAULT, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION-LAW TERRANCE SHINAULT, :DIVORCE Defendant No. 06-6650 CIVIL TERM PETITION TO DISMISS COMPLAINT Plaintiff, Jodi Shinault, by and through her attorneys, the Family Law Clinic, hereby requests that the Court dismiss without prejudice the Complaint for Divorce filed November 17, 2006 in the above captioned case. In support of her Petition, Plaintiff avers as follows: 1. Plaintiff filed a Complaint for Divorce under Sections 3301 (a)(6), 3301(c) and 3301(d) with this Court on November 17, 2006. 2. Plaintiff has informed the Family Law Clinic that Plaintiff and Defendant have decided to reconcile the marriage. 3. Plaintiff has informed the Family Law Clinic that Plaintiff does not wish to pursue this action and requests that the Complaint for Divorce be dismissed without prejudice. 4. The Family Law Clinic has not sought concurrence of opposing counsel pursuant to Local Rule 206.2, because Defendant is not represented by legal counsel in this matter. 5. No judge has ever been assigned to this case. WHEREFORE, Plaintiff requests that the Court dismiss without prejudice the Complaint for Divorce filed November 17, 2006. Respectfully Submitted, Samara Gomez Certified Legal Intern ,~ Megan iesmeyer, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 AUTHORIZATION TO WITHDRAW DIVORCE COMPLAINT I, Jodi Shinault, hereby instruct the Family Law Clinic to withdraw my divorce case filed in Cumberland County, Docket No. 06 - 6650. I understand this means that my divorce action will be terminated and there will be no further proceedings on that action. I understand that if I want to bring another divorce action at some point in the future, I must begin the action from the beginning. ~ ~ ~~ Date i Shinault VERIFICATION I verify that the facts and statements in the attached Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Samara Gomez Certified Legal Intern ..,., ~ -~ .. »3 . -'~ i,~ ~` :tiJ -: _- ,.. ~` _.~ .1 "^"' Jodi Shinault, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6650 CIVIL TERM Terrance Shinault, Defendant : IN DIVORCE DISCHARGE OF ATTORNEY I, Jodi Shinault, discharge the Family Law Clinic from representing me as my attorney in the above captioned case. Date: ~ 1 7 di Shinault (-.' ~ i3 ~ '~ .. ; ~ d - . _ _ :,5...~ r~Ti .~ ~ f V lJ agJ.s ~ a .._-~« i ~.1 ~ T ~ • • ~~ ~~ : _7 ~ --G ~ NAY 8 S 2DD7 JODI SHINAULT, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION-LAW TERRANCE SHINAULT, :DIVORCE Defendant No. 06-6650 CIVIL TERM ORDER OF COURT AND NOW, this ~~ day of ~ , 2007, upon Plaintiff's Petition to Dismiss Action, it is hereby ordered and directed as follows: Plaintiff s Complaint for Divorce filed November 17, 2006 is dismissed without prejudice. J. f y, } ~i~f~~13~~t~I~d ~. ti.~ { ~ !90 ~Cr ~~/~ L~UZ Jodi Shinault, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW DIVORCE Terrance Shinault, Defendant N0.06 - 6650 CNIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn ,Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the May 30, 2007 Order of Court dismissing the Plaintiff's Complaint for Divorce on Terrance Shinault, residing at 7073 Carlisle Pike, Trailer 80, Carlisle, Pennsylvania 17015, by depositing a copy of the same in the United States mail, postage prepaid. Certified Legal Int Megan~'Riesmeyer Supervising Attorney Holly O. aughn er FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717} 243-2968 Fax: (717) 243-3639 ~'~ ~ t - ° ~ ~;:. ~'" .r ; ~ ' ~'S L ~' ~: ,..~ ~D