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Home My WebLink About00-06410 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - , 1 -~- " " . . "':f. ;+: "'Of. '" . '" :Ii "'''' '" "''''''''''''' "';+:'" '" "'''' '" :Ii "'''' '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KURT .T _ HRNDI.EY, Plaintiff NO. 2000-6410 CIVIL VERSUS MARY BETH HENDLEY a/k/a MARY ELIZABETH HENDLEY, Defendant DECREE IN DIVORCE AND NOW, o~ ,,'1 e. ':3'~ . 2001 , IT IS ORDERED AND DECREED THAT KURT J. HENDLEY , PLAINTIFF, AND MARY BETH HENDLEY a/k/a MARY ELIZABETH HENDLEy DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTIQN FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. The Post-Nuptial Aqreement dated June 30, 2001 is hereby incorporated but not merged into this Decree. By T AIT"Tct~ '" '" :Ii '" Of. ;+:if. '" . . . . . . if. '" :Ii'" '" PROTHONOTARY I I ,:....;1 . ~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . ,-~ - ~<- ^ ,-,-- ~ -^ ,~ -,< "-^ -"~-"'~ ,-, -,'~-- <,. -', ,-,,,, "" '. ". -"''1'' "J"~ ,"',' '__'-"~h,."'-~,_" ="~'-d' -., -- "'"",""~..-.,,,~,,,<-;, ". ;-~""~."""'-~"'-< ~ ~ /tJ.~s ttJl 10 ~5',cj/ ....... .;,. w~~~~ $4-~ 7ff~~2 ~ L c:p. ".....' "",'~"P,"!l!~P~~!!l:II,- ,~",,,,,~I!'.ffl~I'P.~. ~~~~IJll!!l~. . , :~ U1, '"~ n~ -'~~' LAW OFFICES SNELBAKER. BRENNEMAN & SPARE KURT J. HENDLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-6410 CIVIL TERM CIVIL ACTION - LAW MARY BETH HENDLEY a/k/a MARY ELIZABETH HENDLEY, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please 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 330 I ( c) of the Divorce Code. 2. Date and manner of service of Complaint: by certified mail, restricted delivery on Defendant on September 23,2000 (see Affidavit of Service filed herewith). 3. Date of execution ofthe Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: October 12,2001; by the Defendant: July 31, 2001. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: October 12, 2001; by the Defendant: July 31, 2001. 5. Related pending claims: None. SNELBAKER, BRENNEMAN & SPARE, P. C. Dme: October 18, 2001 BY.~ }l orney r Plaintiff ~4"'<-- ~ ". '.'~l.ijJi~-'''~~_~~~:~~.ll~ll!JI1iIi'('"''''^ "" "1.,,,. "'=~'w .-- >" ~~~I " ~" "" H~ 0 co 0 c: 'TO ;g: Cl ""OeD (, mrT< --l - z-r-' .;"'r-; _--,,_I N zr" "-' UJ. )" p,:, -<z -,9 ~C' ",. ~~ f?' ;E;o ::K /--(1 9? ::Pc: ~ z r:- ~ ::;! 0"' ~ , ,- , ,. ~ 'c,,""<-' KURT 1. HENDLEY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No;).oCX){oLfIO CIVIL TERM CIVIL ACTION - LAW MARY BETH HENDLEY, Defendant IN DIVORCE NOTICE 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P.C. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE BY:~ Atto neys Plaintiff LAW OFFICES SNELBAKER, BRENNEMAN 8: SPARE "-""-- ,~"~,,,,-.- ~'J KURT 1. HENDLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. ()(J- (, 'Ill) CIVIL TERM CIVIL ACTION - LAW v. MARY BETH HENDLEY, Defendant IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Plaintiff KURT J. HENDLEY is an adult individual residing at 110 B West Vine Street, Shiremanstown, Pennsylvania 17011. 2. Defendant MARY BETH HENDLEY is an adult individual residing 60 Clay Road, Mertztown, Berks County, Pennsylvania 19539. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on May 17, 1980, Lehigh County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date ofthe marriage averred in Paragraph 4, above. 6. Neither party is a member of the armed forces of the United States of America. 7. The marriage is irretrievably broken. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE 8. 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. 9. The Plaintiff requests this Court to enter a decree of divorce. WHEREFORE, KURT J. HENDLEY requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. SNELBAKER, BRENNEMAN & SPARE, P.C. BY:~~ Philip H. S are, Esq ire - 44 West Main Street Mechanicsburg, P A 17055-0318 (717) 697-8528 Attorneys for Plaintiff KURT J. HENDLEY Date: ~ /1 ' 2000. -2- VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: q /; 9j 2000. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE LAW OFFICES SNELBAKER, BRENNEMAN & SPARE KURT J. HENDLEY, IN THE COURT OF COJMM:ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. (JO-(''fll) CIVIL TERM CIVIL ACTION - LAW MARY BETH HENDLEY, Defendant IN DIVORCE AFFIDAVIT KURT 1. HENDLEY, 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 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. Ii 4904 relating to unsworn falsification to authorities. ate~ f I q I 0 0 LAW OFFICES SNELBAKER, BRENNEMAN 8: SPARE KURT 1. HENDLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-6410 CIVIL TERM CIVIL ACTION - LAW MARY BETH HENDLEY a1kJa MARY ELIZABETH HENDLEY, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on September 20, 2000. 2. The marriage of the Plaintiff and the 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. 4. 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. S 4904, relating to unsworn falsification to authorities. Date: October 12,2001 4~~ (Plaintiff) , I t:l " -y"C ,~ LMIi19iIll!iilliiltl~I_ii:ffi,.;i~",~1Ii",,",,~~~~liiidI:1liiJ1'i:l_tllillllillll"""" _ '<-", _~_."', _ ", ___ ~ ..1.., . , ~- ~ .. ~ , (") 0 C-:. c -n :? 0 ""Ocr n ~6, -l '---, J-J ..-- LI- N ,., ~1~ N - ':':":} !;2C ~, :,.::~C:) -~+ ~O ::I:: t 'l+"~. 5>8 co ::2.S?' 0'" ~ --j .,.. )> (Jl ::D -< ~~ ~~ . LAW OFFICES SNELBAKER. BRENNEMAN & SPARE '-'- " ,^:",,-~,..--- -- 1-1 -, ;;1 KURT J. HENDLEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. MARY BETH HENDLEY, : NO: 2000-6410 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301(c) of the Divorce Code was filed on September 20, 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 ofthe 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. S 4904 relating to unsworn falsification to authorities. ~~~-M M y Beth Hendley 'j Date: 7/3 J ,2001 I I .~''''- ~ ..~ -, _,~ "~'N ;'P ~ ,", __..ui.ilillooIiiill"dMill~~~.r.iIliiMt'~~^"',"r_"""V~ -~h-- .v-""_1IiI ,~~ ~,~c--;,,~e<='__.,'. ,,1'."," "-'\_~--' ,;_~"_ ~-,~ - ~- ",,' -",-.", "-,".~,,;.J -,- C') (',: ;;:0. ~~fT -:;7 -~ ~~~ -</' r:::c:-' ~,'- ~t~ Pc: z =< - ,,"'"'" -~ , C-.',' :::;l> ...) -:,-) \=, , - . ) c18 ~ -< 1'0 ::;:) .~ LAW OFFICES SNELBAKER, BRENNEMAN & SPARE KURT 1. HENDLEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. MARY BETH HENDLEY, : NO: 2000-6410 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE Defendant DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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 ofthe decree will be sent to me immediately after it is filed with the prothonotary. 4. 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. S 4904 relating to unsworn falsification to authorities. Date: 7 hl.hl ( { ~ ~Mf%. ~~;/I~~Lt~ M~ Beth Hendley r "'~ ~'-- .;, ' '-~" '.iJ~~~~r<ill~i""...r_"iI'-!i"'fumiGbi0;4_~.diii'I -"~ -~~--"" v",,___,~1 , ' ,. ,~, ""'''1' p" ~,^~- --,~ :~ .! r) C ~.".., ~fF (0_:- -<-:. r:: C~: -;:;:;; 2.C... --=:(") )>C 2: =< C) ~ ~s W c..."") :_-~') - -.~ ~ j,"~) "---o:;rn ""' ,~ 5...7 -< r;;> .:;) .~ . LAW OFFICES SNELBAKER. BRENNEMAN & SPARE KURT 1. HENDLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-6410 CIVIL TERM CIVIL ACTION - LAW v. MARY BETH HENDLEY alkJa MARY ELIZABETH HENDLEY, Defendant IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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. 4. 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. S 4904 relating to unsworn falsification to authorities. Date: October 12,2001 0.",.- "L..;.......~.;.......!h~~.,~w.d..!~lJOIi;;;~N~"""""- - 0 ~'::;r ,-~ , , , --, - ~ '^ ~ .~ . 0 0 C) c: -n s: Cl "'U('"~: n t;2ru -i , - -,,,' N ,_,;,..'..i zr' ciP""" r.....) "--' "-:" 1 ~Z .;() ,<C' ="" ~J.~ :!.\ ~O ::ii:: ;~?-t) 5>0 9? :;:'-'~rn c:: ~ ~ """ -'> C;1 ~ LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ""~~'>1",_i KURT J. HENDLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000-6410 CIVIL TERM CIVIL ACTION - LAW v. MARY BETH HENDLEY a/k/a MARY ELIZABETH HENDLEY, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND ) Philip H. Spare, Esquire, being duly sworn according to law deposes and says: that he is a principal in the law firm of Snelbaker, Brenneman & Spare, P. C., being the attorneys for Kurt J. Hendley, Plaintiff in the above captioned action in divorce; that on September 22, 2001, he did send to Defendant Mary Beth Hendley a/k/a Mary Elizabeth Hendley by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7099 3400 0004 5009 7520; that both the Complaint and cover letter were duly received by Mary Beth Hendley a/k/a Mary Elizabeth Hendley, the Defendant herein, as evidenced by the return receipt card for said certified mail dated September 23,2001; that a copy of the aforementioned cover letter dated September 22, 2001 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for I, --' , LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ... . I Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B"; and that the foregoing facts are true and correct to the best of his knowledge, information and belief. Sworn to and subscribed before me this 13th day of August, 2001. ko~;}~ Notary PuBlic Notarial Seal . Mel: Susan L..~ ~ Public .... =tt,ioro. Cumb8rI_C,<l!Jl!Jy "">" ". '~Nov.24.2003 -'~~ot."""".. . " " ~P~hil. S <- IP . pare -2- LAW OFFICES SNEL8AKER. BRENNEMAN & SPARE CJ ru LSl I"- lr CJ C! LSl ~ '-~- ....L ~~>~_ Beth Hendle Postage $ h""'r ,~~ Certified Fee .::r R~turn Receipt Fee C (Endorsement Required) Q CJ Restricted Delivery Fee (Endorsement Required) 1. 40 1.25 2.75 $ S:c:rs' CJ Q =r m Name (Please Print Clearly) (to be completed by mailer) lr 'Si;;;;;:AP;A2;f;r~'B~~}.h..J::!~!lg.leY"""""""'......m...... a- ~ 'C;;y,'siai"~~4'hlgy...RQgd.mm.......................... "'m... Her . Z 0 Total Postage & Fees " Complete items 1, 2, 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 tiffis card to the back of 'the mail piece, or on the front if space permits. 1. J\rticle Address'ed to: MalfY' Beth Hendley 60 Clay Road Hertztown, PA 19539 Is deli ry address different from item If YES, enter delivery address below: 3. Service Type XM::ertified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C,Q.D. 4. Restricted ~elivery? (Extra Fee) 0 Yes 2. Article Number (Copy from service Jabelj ". ' 109~.~f~~ 0904 ~pO~ 7520 '''$ Folm i3811 \ ~ull i 999 . : I OJn\e.lic Return Receipt EXHIBIT B I ii II I I , 102595-99-M-1789 '-.-,-,.- ,~""'=-"~ ilIlliliiiWlllllll@lilliil ,_ ..0 ..>< ~,,", ~..' ,~"". _, .'"",",~~!i:!;dU;,li'Iil_;lU]f>-~^- li~jr - .',-'h_ ,,~ ,,' "0 ___"m '-~ .1 ,"" ~~,"",' 'h ~ _~ C') (:) (J ~; 'Tl J-;.s -0 CJ._ rn '. ,) -- -/ L.. - -, /:.. , '~_... C'--,' C' - r~-:: , '---,. ----" " / ( J:;-' C I"'..) i ~ :--:' J;'