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HomeMy WebLinkAbout00-03489 ",' '" '" . . '" ~~-~ - -.1, < . .~^ --,,< '" '" '" '" ,.,,.,'" '" '" '" "''''''' '" '" '" '" "'''' '" '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY '" '" . '" '" '" STATE OF '" '" '" . . '" DOROTHY TULLY-HANLE '" '" '" VERSUS '" '" MICHAEL B. HANLE . '" '" '" '" '" '" '" . . AND NOW, PENNA. No. 2000-3489 DECREE IN DIVORCE 17th/-. z , ' , 7-00/ , IT IS ORDERED AND DECREED THAT DOROTHY TULLY-HANLE , PLAINTIFF, . . AND M'ICH1\EL B. H1\NLE , 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 C7~, PROTHONOTARY '" '" '" '" "',., '" "'''' '" '" '" '" '" '" "'''' ~,. . '" '" . . . . . . . . . . . . . . . . '" . . '" '" '" '" '" '" '" '" '" '" J. . '" . '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" . '" '" . . '" '" '" '" '" '" . '" '" iY$J 1,- .- ,~_, .,. 0.. y . .~ , .~1'7 - .~:!IIII_o - ~ -~ "..,..,.......' " ..'""~'r"dWIl"il.."II1.InlnLi LLT.~)I]lIrr In ~m.' ',\.~ .. , //)"30'0/ &v/ I"~ ~ :#'4~ /';;30,,:7/ /'l~.e ~~' 4 ~ _,_, ".".1'1.-- ~~~*~lliI___..,..., ~~ """'1l''''!I~ \""""'T',", "~"l'!~~ ~~ ~'"- DOROTHY TULL Y-HANLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, v. : NO: 00-3489 : CIVIL ACTION - LAW MICHAEL B. HANLE, : IN DIVORCE Defendant. PRAECIPE TO TRANSMIT THE 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 Section 3301(c), 3301(d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: June 23, 2000, by Sheriff's Service, a copy of which is attached hereto. 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: 10/06/01 By Defendant: 09/21/01 (b) (1) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the Notice ofIntention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (l)(i) of the Divorce Code: / /' ,.~. , - ~~m~.\j!;il;,1il>!.iiWJ~"'J~~;i<i,,"'''!!-'.loC>@'''-''''I''_<'''''''~~.-' ht'_ -~ fiI!.~k. ~--~ ;",,,,,,..~ - ~-,-..;...~. 0 C, 0 c -offi 'T) 0 .'" ~g) C':) :J:-n --I iTit_ i3:;: -am "_I ~:jJ::J ~4 ,._~ , ;,:::0 ",,"- :::ie> 3Eo II' ::iI:' (--J ::D 5>0 - "7(') C - Onl Z .. ';:;l =< .,. ::0 --..I -< <" 'w_ ...."', .' .' DOROTHY TULLY -HANLE, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 60- .3'tf9 (!,'Ut.tT~ CIVIL ACTION -LAW v. MICHAEL B. HANLE, IN DIVORCE 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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 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 niE RiGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THlS 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 LffiERTY AVENUE Carlisle, P A 17013 (717) 249-3166 - i__ , I" -...",..~ ,,,,,",,,,-,. DOROTHY TULLY -HANLE, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA :NO: 01J- .j'l1'1 &;xJ/~ v. : CIVIL ACTION - LAW MICHAEL B. HANLE, : IN DIVORCE Defendant. COMPLAINT IN DIVORCE. AND NOW, comes the Plaintiff, Dorothy Tully-Hanle, by and through her attorneys, Mancke, Wagner, Hershey & Tully, and files the following Complaint in Divorce: 1. The Plaintiff, Dorothy Tully-Hanle, is an adult individual currently residing at 11 Clemson Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant, Michael B. Hanle, is an adult individual currently residing at 1340 N. 6th Street, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. " ; I ~~ ~. -'~L,-. " -: 4. Plaintiff and Defendant are husband and wife having been married on September 7, 1993, in Camp Hill, Cumberland County, Pennsylvania, 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. There were no children born unto the marriage. 7. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 8. Plaintiff has been advised of the availability of counseling and that she has the right to request that the Court require both parties to participate in counseling. 9. The Plaintiff avers as grounds on which this action is based are: A. That the marriage is irretrievably broken; and B. That as of August, 2000, the parties will have lived separate and apart for a period of at least two (2) continuous years. -2- ~~ - ~.~ - ;.J ~Ili '~ ~ WHEREFORE, Plaintiff, Dorothy Tully-Hanle, prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, Mancke, Wagner, Hershey & Tully By ../...-: 2- ~ ,,/ ~~. ~.",. / P.,'c d Wagner, Esquire 1. . #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: t.J 5/~D I I -3- ~ _.=--~. I' iWr ~1 '~'""""j,~ ." VERIFICATION I verify that the statements made in the foregoing document 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. }< Q')0I..AkL~ '1 '\A:. OR..a - \...t ~ DATE: '-'('n,,, ~ \(", CJ.c-oo - ,'I 'J._ SHERIFF'S RETURN - OUT OF CASE NO: 2000-03489.0 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTY o TULLY-HANLE DOROTHY VS HANLE MICHAEL B R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HANLE MICHAEL B but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN serve the within COMPLAINT - DIVORCE/NOTIC County, Pennsylvania, to On July 7th, 2000 , this office was in receipt'of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Deputize Dauphin 18.00 9.00 10.00 25.50 .00 62.50 07/07/2000 MANCKE, WAGNER, ~ R. Thomas ~li e . Sheriff of Cumberland County HERSHEY, TULLY Sworn and subscribed to before me this day of A.D. Prothonotary ~ DOROTHY TULLY-HANLE : IN THE COURT OF COMMON PLEAS CUMBERLAND cOUNTY , PENNSYLVANIA Plaintiff, v. NO. 3489 - 2000 CIVIL ACTION - LAW MICHAEL B. HANLE, IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 8, 2000. 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. 4. 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. 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: Dl'*. l.n) ~O , ~~M~J~ Dorothy Tull - anle - lit' , e~'-~" , '-, D~-"{;.~~_jtim#J;WD;,1~lOi~!M..~~-~",,_JIJill!l~~"a-""r ..... ''''""'''iIil~'Ui.i:~~''=_._-~~~;&.''''''''''. '~__' "C'" ~ ~"' ~., ,~. "-~--"" -~ - ~. , ,,~,'~--'- -~- ., .~"-' ,~ '-~ d _ ,,~ ~_ ." O. f! '~~~Il!lIW~1lI C') c:;;> 0 c s: '1 -Om C:J :~ mrT"' <:") 4;:n Z" f --I ::0 r-- zc~ <T]m (I),.>:;:"' ~.... -f'r-, ;;S;",o C)L 0 -.,(,) ;<: ;1:- ...L'Ti ~(') :x (J:D )>>2 ZO OfTl ~ ::- );;! ~.J ~ _1l\IIiII->', i I I IM~";'- DOROTHY TULLY-HANLE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 3489 - 2000 CIVIL ACTION - LAW MICHAEL B. HANLE, IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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 . divorce decree decree will be prothonotary. I understand that I will not be divorced until a is entered by the Court and that a copy of the sent to me immediately after it is filed with the 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. c;0c~~ ~- ~ Q, Dorothy TW-L y-Hanle DATE: ~~, b )~c"'V'. , ,~, -A m~'"""~~.~~ffi!l.H~lW'!li:;-,;jHjIW~_ili~-"~d-. "'-~. ~~ ,~~ - < ~.. . ,~ . " ~ .- ," , o '"r._<, ~, ->.- .. ~- '~Iil:ilIiliWllili<lllloi ~- ......, ._-1 () 0 0 C 'T1 s: 0 ~-l "OIJJ n ~,. ~rn --I ::D ' "r- ZS;: '.Urn ~ ~~ -.J "9 L. /.) . G ;'=10 <:: :> -,-t-r1 ~() ::J: [s~r: 5>8 - zC, - ofn ~ ::- ~ -.J -< .~. .1'0'-,,;, ' , ,,,,e_ DOROTHY TULLY-HANLE, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLANDr COUNTY, PENNSYLVANIA v. NO. 3489 - 2000 MICHAEL B. HANLE, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 8, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: q/:):I/O/ ~B~ Michael B. Hanle , .&i'- ""~ ~'o-._ '-~ < . "~^~'.~1Iii/iai ',1 LI1i~'_~li'!1l ", 0,' ,.<., 0 ,,~,,_ ,__, _.->:," ,,,. '-...jl'~'_.'. ,,~ ,~~ -'''~~' ~ 0' .' . ~ " r~ ~ " 1iIII-- ." _.~. 0 C::, 0 C "OfJ5 C:) ",) f11n'l (J .:rf-..~ 2:' -of 7::r., m-!.J r'- 60S;: .-oIT'i ~;;-.::; -~ :00 <:0 (),1., :!>. .-;~ ~O :::ll: :r::-r; O:n };:O _. 70 C:: Brn 2: ,t- it =< -..J -< " 1-- ""'-, . . DOROTHY TULLY-HANLE, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 3489 - 2000 MICHAEL B. HANLE, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 1/;)J/O( ~J~ MICHAEL B. HANLE , .""""",",._-Ulliitd~flEIllffiIMll~~<ll<u:_~.-f - 0 . ",~ - " ,-"~ ",,",,, ~ ... ',' 0 0 C?, C s: 0 n'; "'Uto n ;~, -n mm -I Z::D mr- i3C -.J ;Q? :::;:2 :::::;(~ kG :> :"~:+i :PC' :x z.- -' ::::0 5>8 ~rn ~ ~ .g:- ~ -.JI . (tIfite of tqc ~1rcr-fff ~i I William T. Tully Solicitor Ralph G. McAllister Chief Deputy Michael W. Rinehart Assistant Chief Deputy Mary Jane Snyder Real Estate Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax:(717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania HANLE-TULLY DOROTHY vs County of Dauphin HANLE MICHAEL B Sheriff's Return No. 1411-T - -2000 OTHER COUNTY NO. 00-3489 AND NOW: June 23, 2000 at 9:25PM served the within COMPLAINT IN DIVORCE upon HANLE MICHAEL B by personally handing to HIM 1 true attested copy (ies) of the original COMPLAINT IN DIVORCE and making known to him/her the contents thereof at 1340 N. 6TH STREET HARRISBURG, PA 17101-0000 ili', '~:.~~= So Answers, Jf~ Sworn and subscribed to before me Sheriff of PROTHONOTARY By Sheriff's Costs: $25.50 PD 06/22/2000 RCPT NO 138203 ET/TS J 1 -,._ ~~, --- , 'Li'lf{, . In The Court of C8IDon Pleas ofCumberlW County, Pennsylvania . Dorothy Tully-Han.le. VS. Michael B. Hanle No. 20-3489 Civil Now, 6/19/00 , 200 (i "I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk oithe Plaintiff. r~~' SheriffofCurnberland County, PA Affidavit (If Service Now, ,20_, at o'c.lock M. served the within upon at by handing to a copy ofthe original and made known to the contents thereof. So answers, Sberiff of County, P A Sworn and subscribed before me t':1is _ day of 20 '- COSTS SERVICE MILEAGE A..FFIDA VIT $ $