HomeMy WebLinkAbout03-2022IN THE COURT OF COMMON PLEAS OF CUMBE~ COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
)
)
VS.
AMANDA HORN
NOTICE TO DEFEND AND CLAIM OF 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 Petitioner. 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
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OR DIVORCE OF
ANNULMENT IS ENTERED, 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.
COURT ADMINISTRATION
COURT ADMINISTRATOR'S OFFICE
Cumberland County Courthouse
One Courthouse Sq~ //
Carlisle, PA~3 J
Teleph ..............
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN
VS.
AMANDA HORN
)
)
_COMPLAINT IN DIVORCE
The Plaintiff, PAUL HORN, hereby seeks a divorce from the Defendant, AMANDA
HORN, and in support thereof makes the following averments:
1. The Plaintiff is PAUL HORN, adult individual, and United States Citizen, who
currently resides at 118 Willow View Drive, Carlisle, Cumberland County, Pennsylvania
17013.
2. The Defendant is AMANDA HORN, adult individual, and United States
Citizen, who currently resides at 3350 City Rd. 21, Elizabeth, Colorado 80107.
3. Plaintiff has been bona fide resident of the Commonwealth of Pennsylvania
for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on .February 20, 2003_ in Castle Rock,
Colorado.
5. There have been no prior actions of divorce or for annulment between the
parties in this or any other jurisdiction.
6. The Plaintiff avers as the ground on which the action is based that there has
been an irretrievable breakdown of the marriage relationship of the parties.
7. Plaintiff has been advised as to the availability of counseling and that she may
have the right to request that the Court require the Parties to participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of divorce frOm the
bonds of matrimony existing between Plaintiff and Defendant.
742 ~
cust Street
ia, PA 17512
84-4422
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct to the best of my knowledge and information. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn
falsification to authorities.
PAUL HORN
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3302(c) or Section 3302(d) of the
Divorce Code was filed on April 29, 2003.
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 sexvice 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. Section 4904
relating to unsworn falsification to authorities.
Dated: 2L ~) o~
PAUL H O'I~LN TM
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 3302(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.
Dated: ~_7___z2,~ c> .~ ~"~,-~._~
' PAUL HORN
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3302(c) or Section 3302(d) of the
Divorce Code was filed on April 29, 2003.
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 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. Section 4904
relating to unsworn falsification to authorities.
Dated:~__
ioRN
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 3302(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 mc 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.
Dated:~,C3 °~ ~ ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
WAIVER OF RIGHTS UNDER "SOLDIERS AND SMLORS" CIVIL RELIEF ACT
OF 1918, RE-ENACTED 1940
I, AMANDA HORN, Defendant in the above-captioned matter, do hereby
acknowledge that I am in the Armed Forces and presently serve in the United States Air
Force. I acknowledge, by signing below, that I understand the rights and terms of the
Soldier and Sailor's Act of the United States of America, and I hereby waive said rights and
do hereby request the Cumberland County Court of Common Pleas to enter thc No-Fault
Divorce Complaint and Decree in the above-captioned matter. I further acknowledge that
I have been advised by counsel and attached hereto is the Certification of legal counsel
evidencing that I have reviewed these documents with legal counsel, and that I am fully
informed of my rights under the Soldiers and Sailor's Act and do desire to proceed to have
the Divorce concluded.
IN WITNESS WHEREOF, I have hereunto set my hand and seal to this Waiver this
day of ~?d~/z~- , 2003.
WITNESS:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
ATFORNEY ACKNOWLEDGEMENT
- /._~'. ~"VE~/~,~ r~. L.O~t~D ~Tg?an Attorney with the United States Air
Force, do hereby acknowledge that I have reviewed the attached document and Waiver with
AMANDA HORN and have advised AMANDA HORN of her rights under the Soldiers and
Sailor's Act.
~_~,I ha'~e hereunto set my hand and seal to this acknowledgement this /~ ~'--~day of
'~,'~, 2003.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
PRAECIPE
I, AMANDA HORN, Defendant in the above-captioned matter, do hereby accept
service of the Divorce Complaint this ~ O day of ['~'hC~ ,2003.
To:
Dated:
Prothonotary
'~Y: ~ ~
-~tl~~ Esqrare
PAUL HORN
VS.
AMANDA HORN
Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
)
)
) No. 03-2022
)
)
PRAECIPE TO TRANSMIT RECORD
1. Ground for divorce: irretrievable breakdown under Section 3302(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: May 20, 2003 - First Class Mail
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required by Section 3302(c) of the
Divorce Code: by Plaintiff Aug 22~ 2003 ; by Defendant Sept. 15~ 2003
(b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3302(d) of
the Divorce Code:
(2) Date of filing and service of the Plaintiff's Affidavit upon the respondent:
4. Related claims pending: No other claims are pending.
5. Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention~.Ao.fiie..~aecipe to transmit
record, a copy of which is attached: ,~-f ' ~ .
(b) Date plaintiff's Waiver of Notice in~5~on 3302(c) Divorce ~s filed with the
Prothonotary: Sept. 4, 2003 . ~ '' /
Date Defendant's Waiver o,~otice in Section 3302(c) ])i~ce w~sffciled-with the
prothonotary Sept 26~ 2003 ~,~/~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION ~ LAW
PAUL HORN )
)
vs. ) No. 03-2022
)
AMANDA HORN )
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I am this day serving a true and correct copy of the
Praecipe to Transmit in the above-captioned matter upon the person and in the manner
indicated below, which service satisfies the requirements of Pa. R.C.P. 1920.42.
Service by first class mail as follows:
Dated:
Amanda Horn
17655 Henderson Pass #235
San Antonio, TX 78232 /~
~ O~~US~~N~)EL
L, Esquire
Columbia, PA 17512
(717) 684-4422
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF .~ PENNA.
PAUL HORN
VERSUS
AMANDA HORN
NO. _ 03-2022
DECREE IN
DIVORCE
AND NOW, October
DECREED THAT PAUL HORN
AN o AMANDA HORN
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 FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
, 2003 , IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
BY THE COURT:
PR~ IONOTARY