The URL can be used to link to this page

Home My WebLink About00-06200 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF SCOTT D. HALDEMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 -Lo2fJ1J CIVIL TERM DEBRA S. HALDEMAN, Defendant : : IN DIVORCE NOTliCE 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 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 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 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT H~VE 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, Pennsylvania 17013 717-243-3166 ~-'-""'l'~'''~ '-~"'''-;1,'''-'--~~-' '. ~<;<",'-' '"""I" " ~",,^ ,--.'1'-' ,-~ SCOTT D. HALDEMAN, Plaintiff : IN THE COURT OF COMMON P"EAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 00 . G,J.1J1J CIVIL TERM DEBRA S. HALDEMAN, Defendant : IN DIVORCE COMiPLAINT IN DIVORCE. UNDER SECTION 3301 ~ OF THE DIVORCE CODiE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Scott D. Haldeman, an adult individual residing at 120 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The defendant is Debra S. Haldeman, an adult individual residing at 120 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on October 15, 1995, in Ocean City, Maryland. r, ,~r,''',c' 'H<~' .' ~ ,__."~",,,"f',~':.'''',~, ,~,~, """~~"..' . . .,. '."',"" " 'J ,., ~' 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. August 12-, 2000 /Mof?}~m [& HAROLD S. IRWIN, Attorney for Plainti 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID NOl. 29920 !i~"~,,, ,<, ,-;!,q,.",o,~__~.,,,,,,,, '''',. ",~"','''''~~',','',,-,.,.=i''"',,,'','", '. ~ "" r " ,~ ,~ 0 SCOTT D. HALDEMAN, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION. LAW = NO. 00. t.;;hrt) CIVIL TERM DEBRA S. HALDEMAN, Defendant = IN DIVORCE PLAI'NTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's Office, 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. August 17, 2000 koo)~ ../" . SCOTT D. HALDEMAN, Plaintiff r~ ~ ~1J c:; ~ <>0 "' ~"- ~: .il ,il :i ,~l "- -- ~., " -I It~,. ,~ ~ 'r.. ,1,. "~'-!""""""t" , lj,i!Jp~,'r' " C) ~;~ ~r,',:: .,::~~ '.. ' 2~~' ~c 7':" ~~(" --s,.: .c:::~: -1 -' -, , "/) "11 "0 t\,) ~"" :- ~D ~ (-' :::;:-j :':i"J ~ Jt .. '- "- (;' ~~ i.. C' e '- <:::J ~, ..".-".,~..j'lImf~"- ~ HAROLD S. IRWIN, III ESQ. ATTORNEY ID NO. 82585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF SCOTT D. HALDEMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 00 - 6200 CIVIL TERM DEBRA S. HALDEMAN, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PUR.SUANT TO PA. R.C.P. RULE NO. 1920.4 <ID.l1illl NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about October 5,2000, by certified mail "restricted delivery", addressed to the defendant at York County Children & Youth, 100 West Market Street, York, Pennsylvania 17401, Certified Mail Receipt No. 7099-3220-0011-0097-6680. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification t authorities. Harold . Irwin, III Attorney for plainti Ocotber 9, 2000 'fi~__ . "'-.~",., ,":",:.":."~.~,,_,",,..,.. i\~":',''''~':'I;,''''' ".---.", ,.'-",' 'C7~'- "'"",--,<. .""__ '"""""~.~'"','. ,":>" "r,""<'J"''"':''''''7"_''~--~'~T,':'' --,-" "-"" ' " . Complete items 1, 2, and' 3: Also complete item 4 if Restricted Delivery is desired. . _ Pril)t YQ,y[,name and address on the reverse SO that we c_an return the card to you. . Attach this card to the back oHhe mail piece, or on the front if space permits. 1. Article Addressed to: ;te);/l1. S -Ik/de./Yl..a...n d,lo y0r'K t!.(:j Children- \& tOD W' I!1..tv*- -e.-I- 0fre if York, f) 17<{O/ ,,~ . D. Is delivery address different from item 1? If YES, enter delivery add'fss below: 3. SelViee Type ~ertified Mail b ~Reglstered D Insured Mail D Express Mail ~ Return Receipt for Merchandise CJ C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Copy from service !abeQ _ /YO tOft{ '-ngica~Oiti[)O 'ti/; '"' O(J97 T!!f..'W.[O, . p's Fpttj138~ 1~ JUiYi 1~~9. " . PI'~~ Return Receipt Ves il; '; 102595-99-M-1789 i ___~__+~L_~__~_~, l"- ll'" ,0 '0 Cl ~ rJ)e.bro.-,$ -t-J.oJdcrYLCUI ... .50 /. L/o j. d.s-- ;;, 76 ,95 Postage $ '7) I'Vorc.e... , I 'f Certified Fee Return Receipt Fee r-=I (EndO(8ement Required) 0-'1 C Restricted DeUvery Fee CJ (Endorsement ReqUired) Postmark ) ",re (!omp 10..) rl"T Total Postage & Fees $ o ru IlJ Name (Pleas~rlnt Clearly) (To be completed by m~er) rn Si,.~Pi.-Ni>~-tp~-/lJ!l0::YJ.-~,---ra!-.-tb-------,----'m--- g: ____lf2.Q_____~__!}:!/y:!r.f:.:.t__s.t:_,___"m_n_'__'___n'm___n_______, ~ CItY,State, 'Po' 7</01 . ">,:,.:'! d - , , ,~'- i>,-~.,~"'_"---'\f"'^.""'~'-',,, '" __"l,_, "'" \~ ""-:'1 ,_,~ r~~'.' "" _'H=""" ~~.~ ~>_'" ~" , , \ i ! Iii ~! Ii "J t;,i ~i ~! 1",,1 il !L ~"', '; '" ~ I'" ,,'~ '," ,," . J" --~ ,,,_ .._,__" ,. __,~ "~"".",-,^",.~,, ,,'m'1~'''' ,!",~:..""~ "~:.~:",",, , . ~~, '. "" '. . ',,,- .!l'nmP.,. -~ ~" Cj ~ -c~ .. L-: 1- :: .-c: c r ,-t.' ~.,. ,-' ~~t~ :j I~'~n 'till n H