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HomeMy WebLinkAbout03-1827CHARLES B. HUMES Plaintiff V. SUSAN C. HUMES, Defendant · CIVIL ACTION - LAW · IN DIVORCE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM LAW OFFICES SNEIBAKeR. BRENNEMaN & SPARE 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 of divorce or annulment may 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 rou, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may · equest 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 LOST 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNEL~AN & SPARE, BY~-nt~f~ P.e. LAW OFFICES SNELBaKER, BRENNEMAN & SPARE CHARLES B. HUMES : Plaintiff : V. .' SUSAN C. HUMES, : Defendant : COURT OF COMMON PLEAS OF CtnVm~^$~ CO~r¥, P~NNS¥~V~ $O.~l~'3 irat3 CIVIL TERM CIVIL ACTION- LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff CHARLES B. HUMES is an adult individual residing at 500 South Arch Street, Borough of Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant SUSAN C. HUMES is an adult individual residing at 206 North Arch Street. Borough of Mechanicsburg, Cumberland County, Pennsylvania 17055. 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 September 2, 1989 in Dauphin 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 of the marriage averred in Paragraph 4, above. 6. Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto 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, Plaintiff CHARLES B. HUMES requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony and to order such other relief as this Court deems just and reasonable. SNELB~BRE~_~ & SPARE, P.C. By: ~ 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Charles B. Humes Date: /~..,'/' ~/ ,2003 -2- VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I anderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. §49049 relating to unswom falsification to CHARLES B. HUMES ,2003 LAW OFFICES SNELE~AKER. BRENNEMAN ,& SPARE CHARLES B. HUMES : COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2002 : CIVIL ACTION - LAW SUSAN C. HUMES, : Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT CHARLES B. HUMES, 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. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE 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:/~'71 sl5 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES B. HUMES, ) Plaintiff ) ) v. ) ) SUSAN C. HUMES, ) Defendant ) No. 2003 Civil 1827 CIVIL ACTION - DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter the appearance of: Daniel M. Myshin, Esq. 4800 Linglestown Road, Suite 305 Harrisburg, Pennsylvania 17112-9507 as Attorney for Defendant, Susan C. Humes, in the above captioned case. Dated: June 12, 2003 D Attorney for Defendant] Pa Supreme Court ID #40366 4800 Linglestown Road, Suite 305 Harrisburg, PA 17112-9507 Telephone 717-541-5451 IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY, PENNSYLVANIA CHARLES B. HUiVlES, ) Plaintiff ) ) v. ) ) SUSAN C. HUMES, ) Defendant ) No. 03-1827 CWIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the above captioned Complaint in Divorce. I certify that I am authorized to accept service on behalf of Defendant, Susan C. Humes. June 12, 2003 D~e 4800 LinglestownRoad, Suite 305 Harrisburg, PA 17112-9507 Telephone: 717.541.5451 02/Humes/Accepmnce of Service June 12,2003 LAW OFFICES SNELBakER, BRENnEmAN & Spare CHARLES B. HUMES Plaintiff SUSAN C. HUMES, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, NO. 03-1827 CIVIL ACTION - LAW CIVIL IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 22, 2003. 2. A Complaint in Divorce under §3301(c) of the Divorce Code was 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 false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relatin falsification to authorities. Date: September lO, 2003 Charles B. Humes LAW OFFICES SNELBAKER, BRENNEMAN & SPARE CHARLES B. HUMES Plaintiff SUSAN C. HUMES, Defendant : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVAI~IA / : NO. 03-1827 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S 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 conceming alimony, division of property, lawyer's fees, or expenses ifI do not claim them before a divome 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 tree 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: September, 1~3 2003 LAW OFF{CES SNELBakEr. BrENNEMAN & SPARE CHARLES B. HUMES Plaintiff SUSAN C. HUMES, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAtlA NO. 03-1827 CIVIL TERM CIVIL ACTION - LAW 1N DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 22, 2003. 2. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on A The marriage of plaintiff and defendant is irretrievably broken and ninety (91 days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divome 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 false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to un falsification to authorities. ril Date: September~ , 2003 Susan C. Humes 1AW OffICES SNELBAKEr. BRENNEMAN & SPARE CHARLES B. HUMES Plaintiff SUSAN C. HUMES, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1827 CIVIL ACTION - LAW IN DIVORCE CIVIL TERM DEFENDANT'S 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 fights concerning alimony, division of property, lawyer's fees, or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divomed 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. § 4904 relating to unsworn falsification to authorities. Date: September, ~ 2003 Susan C. Humes LAW OffICES SNELBAKER. BrENNEMAN & SPARE CHARLES B. HUMES Plaintiff SUSAN C. HUMES, Defendant COURT OF COMMON PLEAS OF / CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1827 CIVIL TERM CIVIL ACTION - LAW I IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County Please transmit the record, together with the following information, to the Court for of a divorce decree. 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of Complaint: by Acceptance of Service for Defendant on June 13, 2003. (See Praecipe filed on June 13, 2003). 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) ot Divorce Code: by the Plaintiff: September ,2003; by the Defendant: September 4. Date of execution of Waiver of Notice in Section 3301 (c) Divorce: by the Plaintiff: September/o , 2003; by the Defendant: September,t?, 2003.. Related pending claims: None. SNELBAKER Date: S~l~maber ,2003 BRENNEMAN & SPARE, P.C. ~s for Plaintiff IN THE COURT OF COMMON PLEAS CHARLES B. HUMES, Plaintiff, VERSUS SUSAN C. HUMES, Defendant OF CUMBERLAND COUNTY STATE Of ~~~ PENNA. NO. 03-1827 CIVIL TE~ DECREE IN DIVORCE and NOW,~~ Charles B. Humes DECREED THAT AND Susan C. Humes 2003 , it IS ORDERED AND ., PLAINTIFF, , 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 F~NAL ORDER HAS NOT YET BEEN ENTERED; None. PRO]'