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IN THE COURTf OF COMMON PLEAS
OF CUMBERLAND COUNTY
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Lyleanne Hertzler
STATE OF
PENNA.
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Plaintiff
NO. 00-4804 Civil Term
DECREE IN
DIVORCE
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,Jod( ,IT IS ORDERED AND
VERSUS
Mark H. Hertzler
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Defendant
Lyleanne Hertzler
, PLAINTIFF,
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AND NOW,
AND
Mark H. Hertzler
, DEFENDANT,
. ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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DECREED THAT
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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PROTHONOTARY
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l.yleallne Hertzler,
Plaintiff
SS# 162-54-2498
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
V.
NO. 00-4804 Civil Term
Mark H. Hertzler,
Defendant
SS# 209-46-0106
CIVIL 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: Section 3301 (c) of the Divorce Code.
2. Date and manner service of the Complaint: A complaint in Divorce
under Section 3301(c) of the Divorce Code was filed on July 6, 2000, and
service was obtained upon the defendant on July 14, 2000, by United States
First Class Mail, certified number P 016 244 726.
3. Date of execution of the Affidavit of Consent and Waiver of Notice
of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of
the Divorce Code:
by Plaintiff: July 2, 2001
by Defendant: July 2, 2001
Time Stamped date of Waiver of Notice of Intention Request Entry of a
Divorce Decree required by Section 3301 (c) of the Divorce Code:
by Plaintiff: July 17, 2001
by Defendant: July 17, 2001
4. Related claims pending: There are no related claims pending.
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Jame 'A. Miller, Esquire
Market Street
Camp Hill, PA 17011
(717) 737-6400
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Lyleanne Hertzler,
" SS#162-54-2498
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 0("\ - .LIPO'l ~o;l~~
Mark H. Hertzler,
SS#209-46-0106
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
You have been sued in Court. If you wish to defend against the claims
set forth in the following papers, 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 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 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 Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, .LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNlILMENT 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, PA 17013
(717)249-3166
James A. Mill ,Esquire
Attorney f laintiff
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Lyleanne Hertzler, .
SS#162-54-2498
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. bV- <fro,!, ~ T~
Mark H. Hertzler,
SS#209-46-0106
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Lyleanne Hertzler, who currently resides at 543 Lamp
Post Lane, CampHill, Cumberland County, Pennsylvania, 17011.
2. Defendant is Mark H. Hertzler whose last known address was 4
Hummel AVenue, Lemoyne, Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on October 18, 1998, in
Dauphin County, Pennsylvania.
5. There have been no prior actions for divorce or annulment
between the parties,
6. The Plaintiff is a citizen of the United States of America.
7. The Defendant is not a member of the Armed Services of the
United States of America.
8. Plaintiff avers that there is one child of the parties under the age of
eighteen, namely Sean M. O'Brien, D.O.B. August 1, 1987.
9. The Plaintiff has been advised of the availability of counseling and
that the Plaintiff may have the right to request that the Court require the parties
to participate in counseling.
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COUNT 1
REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
10. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
11. The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff requests this Honorable Court to enter a decree
dissolving the marriage between Plaintiff and Defendant.
Respectfully Submitted,
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.g SENDER:
'I "l7:i . Complete items 1 andlor 2 for additional servlceg. I also -wish to receive the
, <0 .. Complete items 3, and 4a <& b. r following services {for an extra
1J'!. .. Print yaur name <lnd address em the reverse of this torm so that we can I feel:
t return this card to you. ,
~ .. Attach this form to the front of the mailpiece, or on the back If space I 1. 0 Addressee's Address
f'~'le3 not permit. _
~ ~""Write "RetuTl'l Receipt Requested" on the mallpiece below the article number.
"'" II The Return Receipt will show to w"f'lom thfl article was delivered and the date
::: ' '-delivered
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2. 0 Restricted Dellvery
Consult ostmaster for fee.
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14b. S~rv)ce Type
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DOME~ TIC R;!TURN RECEIPT
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Lyleal1ne Hertzler,
SS#162-54-2498
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 00-4804 Civil Term
Mark H. Hertzler,
SS#209-46-0106
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE OF DIVORCE COMPLAINT
I, James A. Miller, Esquire, hereby certifY that on July 14, 2000, I served the
Defendant, Mark H. Hertzler, with a certified copy of the divorce complaint as evidenced
by the attached United States First Class Mail return receipt card number P 016 244 726.
DATE: Tuesday, July 18, 2000
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James A. 'Her, Esquire
5 \3 h Second Street, Suite 100
.... JltnTIsburg, P A 1710 I
~(717)236-5161
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L YLEANNE HERTZLER,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-4804 CML TERM
MARK H. HERTZLER,
Defendant
IN DNORCE
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 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:
1 01
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Lyleanne Hertzler,
Plaintiff
SS# 162-54-2498
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
V.
NO. 00-4804 Civil Term
Mark IH. Hertzler,
Defendant
SS# 209-46-0106
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOT~CE 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 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 herein in this affidavit are true and
correct. I understand that false statements are made subject to the penalties of
18 Pa. C.S. A. Section 4904, relating to unworn fal . . 'on of author" .
Date: 1Jr}1 ~/
Mar
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Lyleanne Hertzler,
Plaintiff
SS# 162-54-2498
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
V.
NO. 00-4804 Civil Term
Mark Iff. Hertzler,
Defendant
SS# 209-46-0106
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on July 6, 2000, and service was obtained upon the defendant on July 14,
2000, by United States First Class Mail, certified number P 016244726.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing the Complaint and service
upon Defendant of the same.
3. I consent to the entry of a Final Decree in Divorce after service of notice
of intention to request entry of the decree.
4. 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. I further understand that the Court maintains a list of
marriage counselors in the Prothonotary's Office, which list is available to me
upon request. 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 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.A. Section 4904, relating to unswornfClI~lf_ tion to a th r"'
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LYLEANNE HERTZLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-4804 CML TERM
MARK H. HERTZLER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
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July 6, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. ~ 4904 relating to unsworn
falsification to authorities.
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