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HomeMy WebLinkAbout02-4906 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROSEMARY L. HUBBLE Plaintiff VS. WILLIAM M. HUBBLE Defendant CIVIL ACTION--LAW NO. 200;[- qqo~ CIVIL TERM IN DIVORCE COM?I ,AINT UNDER ,qECTION ~301 (c) OF TIlE DIVORCE CODE Plaintiff is Rosemary L. Hubble, who currently resides at 40 Eberly Road, Newburg, Cumberland County, Pennsylvania. Defendant is William M. Hubble, who currently resides at 3 Jean Avenue, Newville, Cumberland County, pennsylvania. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of pennsylvania for at least six months immediately previous to the filing of this complaint. The Plaintiff and Defendant were married on June 14, 1989, in Newville, Cumberland County, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. Date: October ~ , 2002 The marriage is irretrievably broken. 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. Plaintiff requests the Court to enter a decree in divorce. Steven J. Fishman, ID#16269 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717)249-6333 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. Cons. Stat. Ann. §4904, relating to unsworn falsification to authorities. Rosemary L. Hubble IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROSEMARY L. HUBBLE Plaintiff CIVIL ACTION--LAW VS. NO. 2002- "/q66 CIVIL TERM WILLIAM M. HUBBLE Defendant 1N DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ,~rd day of October, 2002, I William M. Hubble, Defendant above, hereby accept service of the Complaint filed m the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. William M. Hubble ROSEMARY L. HUBBLE, Plaintiff Vo WILLIAM M. HUBBLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-49'06 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE IINDER SECTION 3301 (C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on October 8, 2002. 3,2002. Defendant acknowledges receipt and accepts service of the Complaint on October 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: January 8, 2003 WILLIAM ROSEMARY L. HUBBLE, Plaintiff Vo WILLIAM M. HUBBLE, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-4906 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE IINDER ~ECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on October 8, 2002. 2. Defendant acknowledged receipt and accepted service of the Complaint on October 3, 2002. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: January 8, 2003 ROSEMAR~L. HUBBLE ROSEMARY L. HUBBLE, Plaintiff VS. WILLIAM M. HUBBLE, Defendant : 1N THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-4906 : 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: Code. 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce 2. Date and manner of service of the Complaint: acceptance of service signed by Defendant October 3, 2002, filed in the Office of the Prothonotary on October 8, 2002. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on January 8, 2003; and Defendant on January 8, 2003. 4. Related claims pending: .None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not applicable. Respectfully submitted, Steven J. Fishman, Esquire, ID#16269 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717) 249-6333 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. N o. 4906 2002 ROS]~LARY L. HUDDLE VERSUS WILLIAM M. HUBeRT,V, AND NOW, DECREED THAT DECRee IN DIVORCE 2003 __, IT IS ORDERED AND , PLAINTIFF, AND W/T,T,LAM M. HUDDLE , 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; ATT E ST~ J. PROTHONOTARY m d z CRAIG S. JUMPER, Plaintiff VS. BRENDA L. JUMPER, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 4906 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE OF INTENT AND COUNTER-AFFIDAVIT AND NOW, this March 3, 2003, I, Jane Adams, Esquire, hereby certify that on February 26, 2003, a certified true copy of the NOTICE OF INTENT AND COUNTER- AFFIDAVIT were served on DEFENDANT via certified mail, return receipt requested, addressed to: Brenda J. Jumper 714 W. Louther St. Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: ~. D. ~od. a7n~'6~squire 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF CRAIG S. JUMPER, Plaintiff VSo BRENDA L. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 4906 Civil Term ACTION IN DIVORCE ,,,TO: NOTICE OF INTENT TO RE UEST ENTRY OF DIVORCE DECREE ..Brenda L. Jumper 7~14 W. Louther St Carlisle, Pa. 17013 DATE: February_ 19, 2003, You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after March 12 2003 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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, Pa. 17013 (717) 249-3166 CRAIG S. JUMPER, Plaintiff VS. BRENDA L. JUMPER, Defendant · IN THE COURT OF COMMON PLEAS.'. "CUMBERLAND COUNTY, PENNSYLvANiA · No. 02 - 4906 Civil Term · ACTION IN DIVORCE COUNTER-AFFIDAViT UNDER SECTION 3301(d) of the DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree· ,b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) __(i) The parties to this action have not lived separate and apart for a period of at least two years. ___(ii) The mhrriage is not irretrievably broken· 2. Check either (a) or (b): __(a) I do not wish to make any claims for economic relief. I understand that I may lose fights concerning alimony, division of property, lawyer's fees, and expenses ifI do not claim them before a divorce ih granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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. Date: Brenda L. Jumper, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit.