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LISA J. HARTMAN,
Plaintiff
: IN THE OJURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 2001- I~if' CIVIL TERM
.
.
EDWARD A. HARTMAN,
Defendant
.
.
: IN DIVORCE
NOl'ICE ro 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 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 oc 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:
CIlMBERLAND COONTY COURT HOOSE, CARLISLE, PENNSYLVANIA 17013.
IF YOU DO Nor 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 Nor HAVE A
LAWYER OR CANNor AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOV TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND OJUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249-3166
TOLL FREE: 1-800-990-9108
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LISA J. HARTMAN , : IN THE CCURT OF COMMON PLEAS OF
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 2001- JJ...3 f CIVIL TERM
.
.
.
EDWARD A. HARTMAN , :
Defendant . IN DIVORCE
.
ccm>LAINT
Plaintiff, Lisa J. Hartman, by her attorney, Dawn S. Sunday sets forth
the following:
1. plaintiff is Lisa J. Hartman, who currently resides at 217 W.
Siddonsburg Road, Dillsburg, York County, pennsylvania.
2. Defendant is Edward A. Hartman, who currently resides at 217 W.
Siddonsburg Road, Dillsburg, York County, Pennsylvania.
3.
Commonwealth
Complaint.
Plaintiff and Defendant have been bona fide residents of the
for at least six months irrnnediately preceding the filing of this
4.
plaintiff and Defendant were married on August 13, 1992 in Antigua.
5. There have been no prior actions for divorce or for annulment
between the parties.
6. Plaintiff avers, as the grounds upon which this action is based,
that the marriage between the parties is irretrievably broken.
7. 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.
8. Plaintiff requests that the Court enter a Decree of Divorce under
Section 3301(c) or 3301(d) of the Pa. Divorce Code.
Respectfully Submitted,
[)~~-
Dawn S. Sunday, Esquire
Attorney for Plaintiff
ID# 41954
39 West Main Street
Mechanicsburg, PA 17055-6230
(717) 766-9622
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VERIFlCATIOO
I verify that the statements made in this Complaint are true and
C<lrrect.
I understand that false statements herein are made subject to the
~nalties of 18 Pa. c.s. ~4904, relating to unsworn falsification to authorities.
3/ J J ;2,00 I
Date I I .
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