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HomeMy WebLinkAbout02-3496IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jodie Lynn Shearer Plaintiff Bradley David Shearer Defendant CIVIL ACTION NO. 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 plainti~ You may lose money or proper~j or other rights important to you. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jodie Lynn Shearer Plaintiff CIVIL ACTION NO. 0,a. 3¥q~,, 0~ Bradley David Shearer Defendant COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE Plaintiff is Jodie Lynn Shearer, who currently resides at 129 Beacon Drive, Harrisburg, Dauphin County, PA since April 1, 2002. 2. Defendant is Bradley David Shearer, who currently resides at 615 Gates Lane, Enola, Cumberland County, PA since May 28, 1999. Defendant, Bradley David Shearer has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiffand defendant were man'ied on September 25, 1999 at Enola, Cumberland County, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and that plaintiff may have the right to request that the corot require the parties to participate in counseling. 8. Plaintiffrequests the court to enter a decree of divorce. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. ~ 4904 relating to unsworn falsification to authorities. ~-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jodie Lynn Shearer Plaintiff Bradley David Shearer Defendant CIVIL ACTION AFFIDAVIT OF CONSENT 1. A complaint in divorce under 3301(C) of the Divorce Code was filed on (date0~ 2. The Marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed fi.om 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 decree. 4. I understand that I may lose rights concerning alimony, division of property, or expenses ifI 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. CS. @ 4904 relating to unsworn falsification to authorities. Ph Sworn and subscribed Before me this~)~ day O~. \~ - ,2002 Jy~ln Sh~are~ - uarrie Jean Singer, Notary Public Lower Paxton 1'w~ Oa.uph n Cou,',~ ,.!..~ ~C°mmlssion Expires September ~:'~02 ,,,~.uer' Pennsylvania, Association of No~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY', PENNSYLVANIA Jodie Lynn Shearer Plaintiff Bradley David Shearer Defendant CIVIL ACTION NO. 0o2. AFFIDAVIT OF CONSENT 1. A complaint in divorce under 3301(C) of the Divorce Code was filed on (date). 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 ora final decree of divorce after service of notice of intention to request entry of decree. 4. I understand that I may lose rights concerning alimony, division of property, or expenses ifI do not claim them before a divorce is granted I verify that the statements made in this affidavit are tree 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. Bradley Da{,id 81~arer Defendant Sworn and subscribed ~e~for~e me thi~cgday ~)~ , 2002 %..N ary lie - Carrie Jean ~nger, Nolary Public ,,Lower. Paxton_l'w~). Dauphin County ~ommlsslon ~-xpires September 7, ~ ,,~.,o~r, ~'ennsylvanla, Assoc ation of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jodie Lynn Shearer Plaintiff Bradley David Shearer Defendant CIVIL ACTION NO. 0.~. 5'/0c. ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) OF THE DIVORCE CODE I. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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. ~ 4904 relating to unsworn falsification to authorities. Plai'~ Lynn Shea~r' Sworn and subscribed \me this~,Q~,J day ,~ ,2002 j"' No.iai Seal I Canie Jean Singer, Notary Public I · ~ower Paxton Tw~. Oauph n County I My ~.;ommission Expires September 7, 2002 I Member, Pennsylvania, Association of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jodie Lynn Shearer Plaintiff Bradley David Shearer Defendant CIVIL ACTION NO. O2. ~9~, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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 ifI 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 of18 Pa.C.S. @ 4904 relating to unsworn falsification to authorities. lei Dfivid aTer Defendant Sworn and subscribed B~f__qr..e me th~is~Oday Carrie Jean ~inger, Notary Public I · _Lower.Paxton Tw~. Dauphin County I .,ray ~ommissJon Expires September 7, 2002 I i',1~,h~, Pennsylvania, Association of NotalJos~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jodie Lynn Shearer Plaintiff CIVIL ACTION NO. 2002-03496 Bradley David Shearer Defendant AFFIDAVIT OF SERVICE I, Jodie Lynn Shearer hereby state that I served a copy of divorce papers to the defendant, Bradley David Shearer by personally giving them to him at 615 Gates Lane, Enola, Cumberland County, PA on July 23, 2002 at approximately 2:15pm. I verify that the statements made in this affidavit are tree 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. aintiff vorn and subscribed ffore.me this~2 ~'~day of c-~N'O~ry Public - ~o~at a~ Seal" ' Ohafles Frank Class Ill, Nota~ Public Lowe[ Paxton Twp., Dauphin County My Commission Expires Ap[. 30, 2003. vania AssociatiOnMernbe[ Pennsyl o! JODIE L. SHEARER, Plaintiff Vo BRADLEY D. SHEARER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-3496 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July 23, 2002, and served on July 25, 2002. 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 THE FOREGOING 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: it BRADLEY D. SHE~ARER, Defendant JODIE L. SHEARER, Plaintiff BRADLEY D. SHEARER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-3496 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that i will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: BRADLEY D. SHEA~RER, Defendant JODIE L. SHEARER, Plaintiff Vo BRADLEY D. SHEARER, Defendant · 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-3496 CIVIL TERM : 1N DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July 23, 2002, and served on July 25, 2002. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ] I- OF 18 Pa.C.S. §4904 SHEARER, Plaintiff RELATING TO JODIE L. SHEARER, Plaintiff BRADLEY D. SHEARER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-3496 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES UNSWORN FALSIFICATION TO AUTHORITIES. DATE: /I- o7_._ OF 18 Pa.C.S. §4904 RELATING TO SHEARER, Plaintiff JODIE L. SHEARER, Plaintiff BRADLEY D. SHEARER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-3496 CIVIL TERM : IN 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 §330 l(c) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Acceptance of Service on July 25, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: November 20, 2002 by Defendant: November 14, 2002 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Date defendant's Prothonotary: November 20, 2002 Waiver of Notice in §3301 November, 2002 Mary~atas, EsquXiee GRIFFIL~& ASSOCIATES Attorney for Plaintiff (c) Divorce was filed with the IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY ST/~TE OF ..~_ PENNA. JODIE L. SHEARER Plaintiff VERSUS BRADLEY D. SHEARER Def~nd~nP NO. 2002-3496 CIVIl, TE~M DECREE IN DIVORCE , it IS ORDERED AND DECREED That Jodie L. Shearer AND Bradley D. Shearer , PLAINTIFF, , 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 ENTERED; PROTHONOTARY