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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
PENNA.
STATE OF
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VERSUS
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DECREE IN
DIVORCE
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DECREED THAT ~ fY7 _ &larch-oJ..
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AND
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IS ORDERED AND
, 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;
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. {)()-Z"J]o
MINDY M. HARDSOCK,
Plaintiff
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
1. Ground for divorce: irretrievable breakdown under Section 3301[c] of the Divorce
Code.
2. Date and manner of service of the Complaint: . 'I.ft 7 faD bv certified mail. ~ 1- f',J..J ~
3. [Complete either paragraph (a) or (b).]
(a) Date of execution of the affidavit of consent required by Section 3301 [c] of
the Divorce Code: by Plaintiff: '1 1 (A (au ; by Defendant:
OJ~"'tr "r L-coa ,
(b) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of
the Divorce Code:
and, date of service of the Plaintiff's Affidavit upon the Defendant:
4. Related claims pending: All economic claims have been settled. There are no
custodv matters.
S. Date and manner of service of notice of intention to file praecipe to transmit record, a
copy of which is attached, if the decree is to be entered under Section 3301(d)(1)(I) of
the Divorce Code.
Jerry
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MINDY M. HARD SOCK,
Plaintiff
NO. 60 - .;l/JO
Cu~(T~
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
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 otherreliefrequested in these
papers by the Plaintiff. You may lose money or property or other rights important to you.
When the grounds 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 at the Cumberland County Court House, Carlisle, Pennsylvani~ 17013.
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 TillS 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
ASSISTANCE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
(717) 249 3166 or 1 800 990 9108
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
NO. {.IV - :l/3{) c.:;;J J~
MINDY M. HARDSOCK,
Plaintiff
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this
day of
, 1996, comes the Plaintiff,
MINDY M. HARDSOCK, by and through her attorney, Jerry W. Brown, Esquire, and
files the following Complaint in Divorce averring as follows:
1. The Plaintiff, MINDY M. HARDSOCK, is an adult individual currently residing at
4601 South Clearview Drive, Camp Hill, Cumberland County, Pennsylvania 17011.
2. The Defendant, MICHAEL J. HARDSOCK, is an adult individual whose permanent
residence is at 129 East Portland Street, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
3. Defendant is currently serving in the Uuited States Army, on active duty, and is
stationed at Fort Wainright, Alaska. Defendant's address at this duty station is:
Private Michael J. Hardsock
Bravo Company
172nd Support Battalion
3707 Neely Road
P.O. Box 63
Fort Wainright, Alaska 99703-9115
4. The parties have no minor children.
5. Plaintiff and Defendant were married on or about December 29, 1998, in
Mechanicsburg, Cumberland County, Pennsylvania.
6. Plaintiff and Defendant separated on or about October 1, 1999.
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7. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately prior to the filing of this
Complaint.
8. There have been no prior actions of divorce or annulment between the parties.
9. 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.
10. Both the Plaintiff and Defendant are sui juris and are citizens of the United States.
11. The Plaintiff avers that the grounds on which the action is based are that the marriage
is irretrievably broken.
WHEREFORE, Plaintiff requests that this Honorable Court enter a Decree in
Divorce, in accordance with section 3301(c) or (d) of the Divorce Code (23 Pa.C.S. Sec.
101 et seq.).
Respectfully submitted:
Je W. Brown, Esquire
4 1 South Clearview Drive
amp Hill, PA 17011
(717) 299-0971 (ext. 134)
ID No. 65345
Attorney for the Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
MINDY M. HARDSOCK,
Plaintiff
NO.
vs.
CIVIL ACTION - LAW
MICHAEL J. HARD SOCK,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing COMPLAINT
upon the person and in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, as follows:
By deposit in the U.S. Mail, 1st class, postage prepaid, certified and restricted
delivery, and addressed as indicted below:
Private Michael J. Hardsock
Bravo Company
l72nd Support Battalion
3707 Neely Road
P.O. Box 63
Fort Wainright, Alaska 99703-9115
Respectfully submitted:
DATE:
<f h /00
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. Brown, Esquire
outh Clearview Drive
CHill, PA 17011
(71 ) 299-0971 (ext. 134)
ill No. 65345
Attorney for the Plaintiff
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VERIFICATION
I, MINDY M. HARDSOCK, state that I am the PLAINTIFF in the foregoing
COMPLAINT and that the facts set forth therein are true and correct to the best of my
knowledge, information, and belief. I realize that false statements herein are subject to
the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904.
rimJd~1k1A~.hA~ b
Y. SOCK "'-.
Date: If! [) 1 .10
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 00 - G(3 0
MINDY M. HARDSOCK,
Plaintiff
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l( c) of the Divorce Code was filed on_
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2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and the date of service of the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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. C.S.
Section 4904 relating to unsworn falsification to authorities.
DATE: _\ \- ~~-a)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
MINDY M. HARD SOCK,
Plaintiff
NO. C!O -2, i 30
VS.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
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2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and the date of service of the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 malle subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn faJsific~tion to authorities.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 0 Cl - Z l 3. C)
MINDY M. HARDSOCK,
Plaintiff
VS.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 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! 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 the foregoing 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.
DA TE:.JJ - \'6-C'C)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MINDY M. HARDSOCK,
Plaintiff
NO. 00" 2 ( ? 0
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF.INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 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,
lawyers's fees or expenses if! do not claim them before a divorce is granted.
. '
3. I understand that I will not be divorcyd 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 the foregoing 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 falsifiGation to authorities. '
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Michael J. rdsock, Defendant
DATE:/OC r: ;;:a;o
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MINDY M. HARDSOCK,
Plaintiff
NO. CI 0 - Z l '3 0
VS.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO
PA. R. CIV.P.1920.4
I, Jerry W. Brown, Esquire, being duly sworn according to law, deposes and says
that he mailed a copy of the Complaint in Divorce filed in this matter by certified mail,
return receipt requested, addressee only, to the Defendant, to Private Michael J.
Hardsock, Bravo Co., 172nd Support battalion, 3707 Neely Road, P.O. Box 63, Fort
Wainright, Alaska 99703-9115, on Ap^ , )
, i'.....w . The return
receipt signed by the Defendant is evidence of delivery to her and is attached as Exhibit
"A".
Jerry Wi rown, Esquire
460 I uth Clearview Drive
Cam ill, PA 17011
Phone 717-737-9041
ill No. 65345
Attorney for Plaintiff
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hem 4 it Restricted Delivery is desired. .,.
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SO that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
1. Article Addressed to:
D. Is delivery add different from item 1?
If YES, enter clef/very address below:
3. Service Type
~ified Mail
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PS Form 3811, JUly 1999 ,
Domestic. Return Receipt
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EXHIBIT "A"
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MINDY M. HARDSOCK,
Plaintiff
NO.
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
AFFIDAVIT OF MARRIAGE COUNSELING
I, MINDY M. HARDSOCK, being du1y 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 that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Office of the
Prothonotary, which list is available to me upon request.
3. Being so allvised, I 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 malle subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MINDY M. HARDSOCK,
Plaintiff
NO. 00 -<. I 3 "
vs.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
AFFIDAVIT OF MARRIAGE COUNSELING
I, MICHAEL J. HARDSOCK, 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 that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Office of the
Prothonotary, which list is available to me upon request.
3. Being so advised, I 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.
Section 4904, relating to unsworn falsification to aut.'1crities.
~P,-O#~
Michael J. ardsock
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MINDY M. HARD SOCK,
Plaintiff
NO. 00 -Z \ 30
VS.
CIVIL ACTION - LAW
MICHAEL J. HARDSOCK,
Defendant
IN DIVORCE
AFFIDAVIT
I, MICHAEL J. HARDSOCK, being duly swom according to law, deposes and says:
1. That I hereby waive my right to contest this matter in accordance with the Soldier's
and Sailor's Relief Act of 1940,50 U.S.C.A App. g 520.
2. I understand that false statements herein are mooe subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unswom falsification to authorities.
DATE:
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