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Home My WebLink About01-03498i GOLDBERG, KATZMAN S SHIPMAN, P.C. PAUL J. Esaosmo - I. D. #25454 ATTORNEYS FOR PLAINTIFF 320 MARKET STREET STRAWBERRY SQUARE P.O. Box 1 268 HARRISBURG, PA 17108-1268 (71 7) 234-4161 E` BARRY F. HOLLAND, V. WANDA L. HOLLAND, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF CIVIL ACTION - LAW NO. 01-3'19P CtU??? rr? IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WI5H 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 15 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 THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (71 7) 249-3166 BARRY F. HOLLAND, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW WANDA L. HOLLAND, NO. ol- gy9f DEFENDANT IN DIVORCE WAIVER OF COUNSELING BARRY F. HOLLAND, BEING DULY SWORN ACCORDING TO LAW, DEPOSES AND SAYS: I . I HAVE BEEN ADVISED OF THE AVAILABILITY OF MARRIAGE COUNSELING AND UNDERSTAND THAT I MAY REQUEST THAT THE COURT REQUIRE MY SPOUSE AND I TO PARTICIPATE IN COUNSELING. 2. 1 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 THAT MY SPOUSE AND I PARTICIPATE IN COUNSELING PRIOR TO A DIVORCE DECREE BEING HANDED DOWN BY THE COURT. I VERIFY THAT THE STATEMENTS MADE IN THIS WAIVER ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECTTO THE PENALTIES OF 1 8 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: BARRY .HOLLAND GOLDBERG, KATZMAN S SHIPMAN, P.C. PAUL J. EsPoslTo - I.D. #25454 ATTORNEYS FOR PLAINTIFF 320E MARKET STREET STRAWBERRY SQUARE P.O. Box 1 268 HARRISBURG, PA 17108-1268 (71 7) 234-4161 BARRY F. HOLLAND, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V, CIVIL ACTION LAW T WANDA L. HOLLAND, NO. JI- 3y 9 P C?c,r Q /-w- DEFENDANT IN DIVORCE COMPLAINT IN DIVORCE BARRY F. HOLLAND, IS AN ADULT INDIVIDUAL, WHO CURRENTLY RESIDES AT 659 CUMBERLAND POINT CIRCLE, MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA. 2. DEFENDANT, WANDA L. HOLLAND, IS AN ADULT INDIVIDUAL WHO CURRENTLY RESIDES AT 1 949 MULBERRY STREET, HARRISBURG, DAUPHIN COUNTY, PENNSYLVANIA. 3. PLAINTIFF AVERS THAT HE HAS BEEN A BONA FIDE RESIDENT IN THE COMMONWEALTH OF PENNSYLVANIA FOR A PERIOD OF AT LEAST SIX (6) MONTHS PREVIOUS TO THE FILING OF THIS COMPLAINT. 4. THE PARTIES WERE MARRIED ON APRIL 24, 1983, IN DAUPHIN COUNTY, PENNSYLVANIA. 5. THERE HAVE BEEN NO PRIOR ACTIONS OF DIVORCE OR ANNULMENT FILED BY EITHER OF THE PARTIES HERETO. 6. PLAINTIFF HAS BEEN ADVISED OF THE AVAILABILITY OF COUNSELING AND THAT PLAINTIFF HAS THE RIGHT TO REQUEST THAT THE COURT REQUIRE THE PARTIES TO PARTICIPATE IN COUNSELING. 7. THE DEFENDANT IN THIS ACTION 15 NOT PRESENTLY A MEMBER OF THE UNITED STATES ARMED FORCES OR OF ANY OF ITS ALLIES. 6. PLAINTIFF REQUESTS THE COURT TO ENTER A DECREE OF DIVORCE. COUNT I 9. THE AVERMENTS OF PARAGRAPHS I THROUGH 8 HEREIN ARE HEREBY INCORPORATED BY REFERENCE THERETO. 10. THE MARRIAGE IS IRRETRIEVABLY BROKEN._ COUNT II II. THE AVERMENTS OF PARAGRAPHS THROUGH 10 HEREIN ARE HEREBY INCORPORATED BY REFERENCE THERETO. 12. THE AVERMENTS OF PARAGRAPHS I THROUGH 12 HEREIN ARE HEREBY INCORPORATED BY REFERENCE THERETO. 1 3. PLAINTIFF AND DEFENDANT HAVE ACQUIRED PROPERTY, DURING THEIR MARRIAGE UNTIL THE DATE OF THEIR SEPARATION, WHICH PROPERTY IS MARITAL. 14. PLAINTIFF REQUESTS THIS COURT TO PRESERVE HER RIGHT TO HAVE ALL MARITAL PROPERTY OF THE PARTIES EQUITABLY DISTRIBUTED. WHEREFORE, PLAINTIFF PRAYS YOUR HONORABLE COURT TO: (A) ENTER A DECREE IN DIVORCE, DIVORCING THE PLAINTIFF FROM THE BONDS OF MATRIMONY HERETOFORE EXISTING BETWEEN PLAINTIFF AND DEFENDANT; (B) ORDER EQUITABLE DISTRIBUTION OF MARITAL PROPERTY; AND (C) ORDER SUCH OTHER RELIEF AS THE COURT DEEMS JUST AND REASONABLE. RESPECTFULLY SUBMITTED, GOLDBERG, KATZMAN & SHIPMAN, P.C. BY &dzxa2? PAUL ARES2 SITO, ESQUIRE 320 K STREET POST OFFICE BOX 1 268 HARRISBURG, PA 1 701 8- 1 268 SUPREME COURT ID #25454 ATTORNEYS FOR PLAINTIFF VERIFICATION I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C. S. Section 4904 relating to unsworn falsification to authorities. Date: BARB HOLLAND E5 GO ? \C) \ ?Q c? CD .S ` CI3 ?- G ? j i - 4C_ vYi ..?c{ii v ? ca Goldberg, Katzman & Shipman, P.C. Paul I Esposito, Esquire - I.D. #25454 320 Market Street Post Office Box 1268 Harrisburg PA 17108-1268 Attorneys for Plaintiff BARRY F. HOLLAND, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-3498 Civil Term WANDA L. HOLLAND, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN ) Personally appeared before me, a Notary Public, in and for said Commonwealth and County, PAUL J. ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on June 7, 2001, he sent a certified copy of a Complaint in Divorce by certified mail, return receipt requested, restricted delivery, to Wanda L. Holland, 1949 Mulberry Street, Harrisburg, PA 17104, and the return receipt card signed by Wanda Holland, and shown as being delivered June 20, 2001, is attached hereto and made a part hereof. Sworn to and subscribed before me this 2nd day of,)`dy, 2001. My Commission PAUL J?P' SP ITO, ESQUIRE Notarial Seal FMYonvirnission CtoriaY. Chambers, Notary Public Harrisburg, Dauphin County CExpires Apr. 7, 2003 ¦ 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 this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 1?ctxfY?Sr ? 4? I O?-l 2. Article --IC PS Form (Copy from service label) -3'Aco- a?o a-ZX5 89= A. Received by (Please Print Cfearly) B. Date of Delivery >? i? ?frr9v lz- C. Signature y - 0 Agent ,. ! 4 Addressee 0. Is delivery address differknt from item 57 d, Yes If YES, enter delivery address below: ? No 3 Service Type Certfied Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail 0 C.O.D. 4. Restr toted Delivery? (Extra Fee) // yy July 1999 - Domestic Return Receipt 102395-00-M-0952 f' r .: SP . _ loll, f Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel For Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLLAND Plaintiff V. NO. 01-3498 Civil Term WANDA L. HOLLAND Defendant CIVIL LAW - DIVORCE PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Theresa Barrett Male, Esquire on behalf of the Defendant in the above-captioned action. J Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Defendant Date: July 31, 2001 Paul J. Esposito, Esquire I.D. #25454 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17198-1268 (717) 234-4161; (717) 2344161 (facsimile) CA BARRY F. HOLLAND, Plaintiff V. WANDA L. HOLLAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3498 Civil Term CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about July, 2000, and have continued to live separate and apart for a period of at least three years. 2. The marriage is irretrievably broken. 3. 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. 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 unworn falsification to authorities. Date: JA-? ///7003 ?C5 Ir® I % Cl? Pv N 0 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Petitioner COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLAND Plaintiff V. WANDA L. HOLLAND Defendant N0.01-3498 Civil Term CIVIL ACTION - DIVORCE ORDER OF COURT MAR 10 2004 AND NOW, March 2. 2004, upon consideration of the foregoing petition, the Court ISSUES a Rule on plaintiff and defendant to show cause why the petitioner is not entitled to the relief requested. The Rule is returnable within ten (10) days of service. BY THE COURT: Distribution: ,/Oaul J. Esposito, Esq., P.O. Box 1268, Harrisburg, PA 17108-1268 v'Wanda L. Holland, 1949 Mulberry St., Harrisburg, PA 17104 7 &-fheresa Barrett Male, Esq., 513 N. Second St., Harrisburg, PA 17101 03 -1??'? I i1_ED 200tl IIJAIR t :7 Pt 4: E 7 f .? p3 S3 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Petitioner COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLAND Plaintiff V. WANDA L. HOLLAND Defendant NO. 01-3498 Civil Term CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, March 2004, the Court GRANTS Theresa Barrett Male, Esquire, leave to withdraw as counsel for Defendant in this proceeding. BY THE COURT: J. Distribution: Paul J, Esposito, Esq., P.O. Box 1268, Harrisburg, PA 17108-1268 Wanda L. Holland, 1949 Mulberry St., Harrisburg, PA 17104 Theresa Barrett Male, Esq., 513 N. Second St., Harrisburg, PA 17101 u ? ? y Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Petitioner COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLAND Plaintiff V. WANDA L. HOLLAND Defendant NO. 01-3498 Civil Term CIVIL ACTION - DIVORCE PETITION FOR LEAVE TO WITHDRAW AS COUNSEL 1. Defendant retained Petitioner to represent her in this proceeding. 2. On March 2, 2004, Defendant informed Petitioner that Defendant is terminating the representation. Wherefore, Petitioner respectfully requests the court to grant her Petition to withdraw as counsel for Defendant. 0 Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 Petitioner Date: March 5, 2004 PROOF OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R.C.P. 440: Service by first-class mail addressed as follows: Paul J. Esposito, Esquire 320E Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiff Wanda L. Holland 1949 Mulberry Street Harrisburg, PA 17104 Defendant IL z Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Petitioner Date: March 5, 2004 s? N O 0 .° -Ti m y? rn r_n 4V '' BARRY F. HOLLAND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01-3498 WANDA L. HOLLAND, : CIVIL LAW Defendant : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please enter the appearance of ivfarianne E. Rudebusch, Esquire on behalf of the Defendant in the above referenced matter. Dated: Respectfully Submitted, Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 (717) 657-0632 Id. No. 63522 WITHDRAWAL OF APPEARANCE Please withdraw the appearance of Theresa Barrett Male, Esquire on behalf of the Defendant in the above referenced matter. Dated: Respectfully Submitted, Theresa Barrett Male, Esquire 513 North 2"d Street Harrisburg, PA 17101 (717) 233-3220 Id. No. 46439 ?6 ?-? ?? ?? c? r. r? -,? ---s .=?5 y te - - ?.,3 t ? ; r '-' _ _ ? ? a O ?-? _ ?' . , -:? c? Curtis R. Long Prothonotary office of the Protbonotarp Cumberranb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 1) 1 - a L/ gA CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573