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HomeMy WebLinkAbout03-0552DANETTE A. HANZEL, Plaintiff V. JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND 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 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, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAVVYER'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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 DANETTE A. HANZEL, : Plaintiff : V. .. : JOHN R. HANZEL, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (~3- ~,C'S'~, CIVIL ACTION - LAW IN DIVORCE parties. 6. 7. COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Danette A. Hanzel, who currently resides at 421 Reno Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is John R. Hanzel, who currently resides at York County Prison, 3400 Concord Road, York, York County, Pennsylvania 17402. 3. Plaintiffand Defendant have been bona fide residents ofthe Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 14, 1998 in New Cumberland, Cumberland County, Pennsylvania. There have been no prior actions of divorce or for annulment between the The Plaintiff is a citizen of the United States of America. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The 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. 10. Plaintiff requests the Court to enter a Decree in Divorce. Date: Respectfully Submitted, L.53~rence/~.~eary, Esqui/ Attorney/for' Plaintiff / 108-112'~/alnut Street,/ Harrisburg, PA 17101-1609 (717)238-4798 (717)238-4793 - Fax Pa.I.D. No. 25827 VERIFICATION I verify that the statements made Jn the attached Divorce Complaint 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 faJsification to authorities. Danette A. Hanz~l ~ DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA. R. CIV. P. 1920.4 COMMONWEALTH OF PENNSYLVANIA · · SS. COUNTY OF DAUPHIN · Lawrence J. Neary, 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 at York County Prison, on February 7, 2003. The return receipt signed by a prison official is evidence of delivery to him and is attached hereto as Exhibit A. Sworn to and subscribed before me this ~0'*~' day of ~\c.~c._% ,2003. Not~J Publi~ Harrisburg, PA 17101-1609 (717)238-4798 (717)238-4793 - Fax DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $2.30 $1.75 $ 4.65 fRecipient's Name (Please Print Clearly) (to be completed by g~hz~- -.-.~,~---~.~e. ~__-I a~aa~e #-7-2 -9-7- ! .............. Street, ~p~. No.; or ~[J ~ox fro. - ........... I York County Prison, 3400 ConCord Rd. York, PA 17402 · Complete items 1, k, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: York County Prison John R. Hanzel Inmate#72971 3400 Comcord Road York, PA 17402 A. Received by (Please Pnnt C/early) B. Date of Delivery item 17 [] Yes -- enter delivery address below: [] No ~pe I [~ Certifi~l Mail [] Express Mail J [] Registered [] Return Receipt for Memhand se ~ [] Insured Mail [] C.O.D. [ 4. Restricted Delivery? (Extra Fee) --~ -~ 2. Article Number (Copy from sen/ice label) 7000 0600 0028 3149 0763 PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, : Defendant ' IN THE cOURT OF COMMON PLEAS CUMBERLAND cOUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint under section 3301(c) of the Divorce Code. Date:_~) J {°1 hn R. Hanzel / York County Prison Inmate No. 72971 3400 Concord Road York, PA 17402 DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on February 5, 2003. 2. The marriage of the 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. 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: '~J~/~ U//~ ~ Danette A. Ha~ DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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: Danet~e A. Hanzel ~ DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on February 5, 2003. 2. The marriage of the 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. 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. J~hn R. Hanzei / DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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: DANETTE A. HANZEL, Plaintiff V. JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-652 Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THEPROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: Code. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce 2. Date and manner of service of the Complaint: On February 7, 2003, the Defendant, John R. Hanzel, in York County Prison, was served with the Complaint by certified mail no. 70000600002831490763 with a return receipt date of February 10, 2003 as set forth in the Affidavit of Service filed in this case. An Acceptance of Service was also filed which was signed by the Defendant, John R. Hanzel on March 10, 2003. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff May 26, 2003; by Defendant May 16, 2003. 4. Related claims pending: None 5. Date Plaintiff's and Defendant's Waiver of Notice were filed with the Prothonotary: filed contemporaneously herewith Date: Respectfully Submitted, L~v~nce J./N/6ary, Esquire/ At'[forney for(Plaintiff ~ 108-112 Walnut Streef~_,/ Harrisburg, PA 17101-1609 (717)238-4798 (717)238-4793 - Fax IN ThE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. DANETTE A. HANZEL, Plaintiff VERSUS JOHN R. HANZEL, Defendant NO. 03-552 civil Term DECREE iN AND NOW, DECREED That AND DIVORCE DANETTE A. HANZEL JOHN R. HANZEL ARE DIVORCED FROM THE BONDS OF MATRIMONY. __, It IS ORDERED AND , PLAINTIff, ., DEFENDANT, 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 DANETTE A. HANZEL, Plaintiff JOHN R. HANZEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-552 Civil Term CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Defendant in the above matter, having been granted a final Decree in Divorce on the 16th day of June, 2003, hereby intends to resume and hereafter use the previous name of Danette A. Bartholomew and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S.A. §704. Danette A. Hanzel TO BE KNOWN AS: Danette A. Bartholomew COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF DAUPHIN : On the //v,~ day of ~'C~/~,~ ,2004, before me, a notary public, personally appeared Danette A. Hanzel,0aka Danette A. Bartholomew, 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 seal. (N~ary Public ~ My Co'~nmission Expires: I