The URL can be used to link to this page

Home My WebLink About95-05078 ~ j r c " ~ . 1 '! 7- El a E- E L ~ I I ~ j 01 I I Ooj t-l o l li) to i 0-) . . 0, ~ ~~~~~~~~~~~~~~~~~*~*.*~-**--~-~ ~ .- .,-' --'.._".._-"."---,,. - - . - . - .... - ..--...----- ----~. 8 ~ 8 :1 IN THE COURT OF COMMON PLEAS : ~ OF CUMBERLAND COUNTY ~ 8 ~ 8 ~ ~ 8 8 STATE OF '~~ PENNA. . 8 - 8 ~ 8 8 8 8 8 . ~ ~-_.*---------------- 8 JOHN C. .MAYBERRY, " ~ Plaintiff i\: (),95"'S078 8, Y('I'~lIS 8 . SHAWN K. MAYBERRY, ~ Defendant w '=' S 8 DECREE IN DIVORCE ~ ~l . " 8 ~ ~ AND NOW, . .. .. .. ..1~ ~~.. .. ?,d.. . .. . " 19. ~~.. " it is ordered and decreed that ..,.... ~~~~, ~~. ~~BE~~Y. , , , . . , . . , . . , . . . . , . , . , , , , '. plaintiff, and, . , .. .. .. . , , . .. ..&Ijl\\ffl .11.. ,I1l\XI!F;~'(. . , . , , . . , . , , . .. .. . .. . ", defendant, are divorced from the bonds of matrimony. 8 " ~ 8 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; ..' ~ " '-' ,;" ~ iIIOhL.. ~ ........ -.'... ......... ,........... n v7't~_ c'/JrJL ^":I~~UG# F IJ~1. ~~,..~ J, ~J;W( K J9~ '().;L / . T~olhonolAry " 8 ................................. . ~ 8 ~ ~ ~ f! :;- ~ '.:.,: ~: :.::.' ~ I, 8 ~ . I. I' 1~ I: iN l~ f,:. i~ i. !. is I, .~ '~ I~ :'." ,.... )~ S ~ ~ ~ ~ /' 31 t)(, ad, "0/1 M;wb ~ tt-4 ~ J '31 .9? 7l~tu m$ z2 a!; dJd~ JOHN C. MAYBERRY, Plaintiff vs. SHAWN M. MAYBERRY, Defendant -- ..- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW IN DIVORCE NO. 95 2S6e CIVIL TERM 5075' WAIV~NT~F NOTICE OF INTENTION ~ R~OUEST E~RY ~F A DIVORCE DECREE UNDE .3301 (C) 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 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. 4904 relating to unSWorn falsification to authorities. Date: ~l1M.-mm~_ SHAWN M. MAYB RY vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW ~~. DIVORg~ 1995 - f)cJ 7 ?J ~ {.Q./vrl-J JOHN C. MAYBERRY, Plaintiff SHAWN M. MAYBERRY, Defendant 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 YOll 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. 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 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 Carlisle, PA 17013 (717) 240-6200 JOHN C. MAYBERRY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NO. CIVIL CIVIL ACTION - LAW IN DIVORCE SHAWN M. MAYBERRY, Defendant COMPLAINT IN DIVORCE The Plaintiff, JOHN C. MAYBERRY, by his attorney, William A. Duncan, sets forth the following cause of action. 1. Plaintiff is JOHN C. MAYBERRY, a sui juris individual who currently resides at 260 Dorwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is SHAWN M. MAYBERRY, a sui juris individual who currently resides at 260 Dorwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on October 16, 1993 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. D (1).) 1995 ate: .-.-, \;\ (~ an, Esquire laintiff COMMONWEALTH OF PENNSYLVANIA: ss. COUNTY OF CUMBERLAND I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge 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 authorities. Date: 4ft?... , 1995 JOHN C. MAYBERRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NO. CIVIL CIVIL ACTION - LAW IN DIVORCE vs, SHAWN M. MAYBERRY, Defendant AFFIDAVIT JOHN C. MAYBERRY, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (ee/DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.4904 relating to unsworn falsification to authorities. Q!/::Jvt vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW IN DIVORCE NO. 95 ~S62 CIVIL TERM 50~ JOHN C, MAYBERRY, Plaintiff SHAWN M. MAYBERRY, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 201(c) of the Divorce Code was filed on S'c'l)\!\M.V;~\\ 1 7~ , 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. I verify that the statements made in this affidavit are true and correct. I understand that false statements herei are made subject to the penalties of 18 Pa. C.S. sect' n 4904 r lating to unsworn falsification to authoritie l'J1 Date: <~~}tA,UA-Qt~ I ~ ,Ilq(; JOHN C. ~~ JOHN C, MAYBERRY, Plainliff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW SHAWN M. MAYBERRY, Defendanl : NO. 95-5078 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT AND ACKNOWl.EDGEMENT I. A Complainl in Divorce under Section 3301 (c) of the Divorce Code was filed on September 22. 1995, and I acknowledge receipl of a copy of the same. which was served on me by service to my Attorney of Record, Taylor P. Andrews, Esquire, as evidenced by the Acceptance of Service daled and filed Seplember 27, 1995, 2. The marriage of Plaintiff and Defendanl is irretrievably broken and ninety (90) days have elapsed from the dale of filing the Complaint. 3. I consenllo the enlry of a final decree of divorce. 4. I understand thaI I may lose rights concerning alimony. division of property. lawyer's fees or expenses if I do nOI claim them before a divorce is granled, 5. I have been advised of the availability of marriage counseling, and do not request thaI the Court require thaI my spouse and I participale in said counseling. I verify thaI the stalements made in this Affidavil are lrue and correcl. I understand that false statements herein are made subjecllo the penallies of 18 Pa. C,S. ~904, relaling 10 unsworn falsification 10 authorities. Dale:~Wd-j /~ N?~- j -;rhrl(rt---YJ{ .~ (. Shawn M. Mayberry, JOHN C. MAYBERRY, Plaintiff V. SHAWN M. MAYBERRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACfION - LAW : NO. 95-5078 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accep1 service of the Complain1 in Divorce on behalf of the Defendant, SHAWN M. MA YBERR Y, in the above-captioned action and I certify thaI I am authorized to do so. DATE: / ? -2 7-5~- By: y r p, Andrews, Esq. orney for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVlINIA JOHN C, MAYBERRY Defendant CIVIL ACTION - LAW 9S" NO. "-5078 CIVIL TERM IN DIVORCE v, SHAWN M. MAYBERRY NOTICB 01' BLBCTION TO RBTAJ:B IlAIDBN NAIOI Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 30th day of January, 1996, hereby elects to retake and hereafter use her previous name of SHAWN MICHELE SUTI'ON. MfUJJ1.- !IliWJJ. fvl~~ L> SHAWN IIICHBLB IlAYB Y TO BE KNOWN AS: flrWJL.YYllflJ). ;~~thiJ ( SHAWN IIICBBLB iI COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND on the ~:.!< day of i'f'tJ..,~, 1996, before me, a Notary Public, personally appeared SHAWN IIICHBLB ~IRRY, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and official seal. IlO'fAllIAL SIAL 'UII~ 1. '.IMII, ....a., PtMc C....1t ........, C IIfLlllI" c:..., .. c......... 'aL 1,_ '-..// } V.~.d'/.I /"'-..~, ".~ /., .--1' ,A-~ ~~A,~ Notary Public