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HomeMy WebLinkAbout02-3921DEBORAH ANN SHOEMAKER, Plaintiff LLOYD EVERETT SHOEMAKER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- ...~',g/ CIVIL TERM 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. 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 DEBORAH ANN SHOEMAKER, Plaintiff LLOYD EVERETT SHOEMAKER, JR., Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Deborah Ann Shoemaker, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Deborah Ann Shoemaker, is an adult individual who currently resides at 67 Country View Estates, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Lloyd Everett Shoemaker, Jr., is an adult individual who currently resides at 91 Ridge Road, Newville, Cumberland County, Pennsylvania 17241. 3. The Defendant and the Plaintiff 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 Plaintiff and the Defendant were married on June 14, 1980 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Deborah Ann Shoemaker, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Date: ,AUG 1,4 2002 Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Cra'lisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX 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 unsworn falsification to authorities. DEBORAH ANN SHOEMAKER, Plaintiff DEBORAH ANN SHOEMAKER, Plaintiff Vo LLOYD EVERETT SHOEMAKER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-3921 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 13th day of September 2002, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Deborah Ann Shoemaker, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Lloyd Everett Shoemaker, Jr., by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on September 12, 2002. Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX .o · Complm tt'elTm 1, 2, and 3. Abo coml~ Item 4 If Restricted Deilvery is desired. so that we can return the card to you. · Attach this card to the back of the mallpiece, or on the front if space permits. 1. Alllcle ~ to: LLOYD E. SHOEMAKER, JR. 91 RIDGE ROAD ~lVl'l'Z,~, PA 17241 y ( D. Isdeilv~/addm~dlfflentfromttaml? [:]Ye~ If YES, enter deiive~ address below: [] No 1'3 Irl~ Mail ::]:)ELI " 2. ArUc~Num~er 700 0000 307[ 2786 (Trar=~' fnwn ~erv/ce/abe0 [] Exm Ivleil [] C.O.D. PS Form 3811, August 2001 Domestic Return Receipt DEBORAH ANN SHOEMAKER, Plaintiff LLOYD EVERETT SHOEMAKER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-3921 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 16,2002. A complaint in divorce under §3301(c) of the Divome Code was filed on August 2. The marriage of the 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. § 4909 relating to unswom falsification to authorities. DEBORAH ANN SHOEMAKER, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(e) 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 fights 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 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, § 4909 relating to unswom falsification to authorities. DEBORAH ANN SHOEMAKER, Plaintiff FEB 1 DEBORAH ANN SHOEMAKER, Plaintiff LLOYD EVERETT SHOEMAKER, JR., Defendant IN TtIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3921 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 16,2002. A complaint in divorce under §3301(c) of the Divorce Code was filed on August 2. The marriage of the 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. § 4909 relating to unswom falsification to authorities. Date: -C~//./'~//~-~ ~ ~c~': ~0 ~. EVERETT Sh6EM^KER, JR[Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE LrNDER §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 divorced until a Divorce Decree is entered by the Court and 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. § 4909 relating to unswom falsification to authorities. ERE'IT SHOEMAKER, Jl~,/Defendant DEBORAH ANN SHOEMAKER, Plaintiff LLOYD EVERETT SHOEMAKER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-3921 CIVIL TERM : : CWIL ACTION - LAW : 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 § 3301(c) g.~31(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on September 12, 2002 by certified mail, restricted delivery to Defendant, Lloyd Everett Shoemaker, Jr. 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 the Plaintiff: February 12, 2003; by the Defendant: February 13, 2003. (b) (1) Date of execution of the Plaintiff's Affidavit required by § 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 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, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by § 3301(c) of the Divorce Code: by the Plaintiff: February 12, 2003; by the Defendant: February 13, 2003. Date: February 17, 2003 Thomas S. Diehl, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ¢~~, PENNA. DEBORAH ANN SHOEMAKE~~ Piaindff VERSUS LLOYD EVERETT SHOEMAKER, Defendant NO. JR., 2002-3921 DECREE 1N DIVORCE AND NOW, ,1~ )) LL~ 2 ~ , 'Z¢0.'~ , IT IS ORDERED AND DEBORAH ANN SHOEMAKER DECREED THAT , PLAINTIFF, LLOYD EVERETT SHOEMAKER, JR. AND __, 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; NONE. BY THE COURT: ("/- ' ~ ~_; I. - ~ PROTHONOTARY