HomeMy WebLinkAbout03-2378JASON S. HUTCHISON,
Vo
REBECCA HUTCHISON,
Plaintiff
Defendant ·
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
TO:
Rebecca Hutchison
! 805 Walnut Bottom Road
Newville, PA 17241
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.
When the ground for 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 the Cumberland County Courthouse, One Courthouse Square, 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 LAV,~ER ~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, Pennsylvania 17013-3387
PHONE: (717) 249-3166
267991-1
JASON S. HUTCHISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v. · CIVIL ACTION - LAW
· NO. 02 --
REBECCA HUTCHISON, ·
Defendant · IN DIVORCE
COMPLAINT IN DIVORCE
1. The Plaintiff, Jason S. Hutchison, is an adult individual currently residing at 1267
Newburg Road, Shippensburg, Cumberland County, Pennsylvania, 17257.
2. The Defendant, Rebecca Hutchison, is an adult individual currently residing at
1805 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania, 17241.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
at least six months immediately prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 16, 2001, in Cumberland County,
Pennsylvania.
5.
Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
6. Plaintiff's Social Security Number is 178-64-5098 and Defendant's Social Security
Number is 198-68-2752·
7. There have been no prior actions of divorce or for annulment between the parties.
8. 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.
267991-1
o
10.
11.
12.
Defendant.
There were no children bom of this marriage.
The marriage is irretrievably broken.
The parties have been living separate and apart since March 15, 2003.
Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and
WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and enter any
such other Orders as are appropriate and just.
Dated:
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By
Andrew ~. Spears, Esquire
Attorney I.D. No. 87737
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
267991-1
VERIFICATION
I, Jason S. Hutchison, hereby certify that the facts set forth in the foregoing Complaint in
Divorce are tree and correct to the best of my knowledge, information and belief, and that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom
falsification to authorities.
a~ S. I~utchison --
267991-1
JASON S. HUTCHISON,
REBECCA HUTCHISON,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. rD3-- .-L377
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Andrew C. Spears, Esquire, counsel for Plaimiff, Jason Hutchison, in the above
captioned action, hereby certify that a true and correct copy of the Complaint in Divorce was
served upon Defendant, Rebecca Hutchison, via regular mail and certified, return receipt
restricted mail on June 5, 2003. Attached hereto, marked as Exhibit "A", and incorporated herein
by reference is a copy of the return receipt card for said service.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Dated:
By
Andrew C. Spears, Esquire
Attorney I.D. No. 87737
P.O. Box 5300
3211 North Front Street
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
283198-1
Return Reciept Fee
(Endorsement Required)
Restricted DeUvery Fee
(E ~p~oraemept Required)
JASON S. HUTCHIS~
REBECCA HUTCHI~
I. An Am~
was filed on May 19, 2(
2. The mt
have elapsed from the
3. I cons.
Intention to Request En!
I verify that the
false statements herein
falsification to authoriti(
Dated:
ON,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAN
CiVIL ACTION - LAW
NO. 03-23,8 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
nded Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code
03 and served upon Defendant on June 5, 2003.
'iage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days
rte of filing and service of the Complaint.
to the entry of a Final Decree of Divome after service of Notice of
, of the Decree.
~tements made in this Affidavit are tree and correct. I understand that any
re made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom
,WJason S. Hutchisoh
A
JASON S. HUTCHIS,
REBECCA HUTCHI
W2
ENTRY
1. I consen'
2. I under
lawyer's fees or experts{
3. I underst
and that a copy of the de
I verify that the
false statements herein ~
falsification to authoriti
Dated:
290114
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAB
CIVIL ACTION - LAW
NO. 03-2378 CIVIL TERM
IN DIVORCE
iVER OF NOTICE OF INTENTION TO REQUEST
A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE
to the entry of a final decree of divome without notice.
:and that I may lose rights concerning alimony, division of property,
; ifI do not claim them before a divorce is granted.
md that I will not be divorced until a divorce decree is entered by the Court
Fee will be sent to me immediately after k is filed with the Prothonotary.
statements made in th/s Affidavit are tree and correct. I understand that
re made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom
,J-~n S. Hutchison
JASON S. HUTCHISOI
REBECCA HUTCHIS£
I. An Ame]
was filed on May 19, 20.
2. The man
have elapsed from the d~
3. I conse=
Intention to Request Eni
I verify that the
false statements herein.
falsification to authoriti~
Dated'~. //~
/
290114-1
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-2378; CIVIL TERM
IN DiVORCE
AFFIDAVIT OF CONSENT
tded Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code
)3 and served upon Defendant on June 5, 2003.
[age of Plaintiff and Defendant is irretrievably broken, and ninety (90) days
1e of filing and service of the Complaint.
to the entry of a Final Decree of Divorce after service of Notice of
r of the Decree.
atements made in this Affidavit are tme :and correct. I understand that any
u:e made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom
z [Rebecca HutcI~i~onV/ - /
JASON S. HUTCHISO7
REBECCA HUTCHIS(
Plaintiff
}N,
Defendant
IN THE COLIRT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANLt
CIVIL ACTION - LAW
NO. 03-2378 CIVIL TERM
IN DIVORC, E
W~
ENTRY OF
1. I consenl
2. I unders
lawyePs fees or expense
3. I unders~
and that a copy of the d~
I verify that th~
false statements herein
VER OF NOTICE OF INTENTION TO REQUEST
A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE
to the entry of a final decree of divorce without notice.
rand that I may lose rights concerning alimony, division of property,
ifI do not claim them before a divorce is granted.
md that I will not be divorced until a divorce decree is entered by the Court
:cree will be sent to me immediately after !it is filed with the Prothonotary.
statements made in this Affidavit are tree and correct. I understand that
are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom
falsification to authoriti ,~s.
Dated:~¢/! ~l ~
290114-1
~Rebecc~/- '- a Hutchiso~/ -
JASON S. HUTCHISON,
V.
REBECCA HUTCHISON,
Plaintiff :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-2378 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORI3
TO THE PROTHONOTARY:
Kindly 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 3301(c) of the Divorce Code.
Date and manner of service of Complaint: A omplamt in Divorce was filed on
C '
May 19, 2003, and served on Defendant, Rebecca Hutchison, on June 5, 2003, by
certified mail, return receipt requested, restricted delivery. An Affidavit of Service
was filed on June 24, 2003.
Complete either paragraph (a) or (b):
(a) Date of execution of Plaintif£s and Defendant's Affidavits of Consent
required by Section 3301(c) of the Divorce Code:
Plaintiff: Jason S. Hutchison, October 15, 2003, filed October 29,
2003;
Defendant:
2003
Rebecca Hutchison, October 11, 2003, filed October 29,
(b)(1) Date of execution of Plaintiff's Affidavit required by Section 3301(d) of the
Divorce Code: NA
Document #.. 247892.1
(2)
Date of filing and service of the Plaintiff's Affidavit upon the respondent:
Filing: NA
Service: NA
Complete the appropriate paragraphs:
(a) Related claims pending: None
(b) Claims withdrawn:
(c)
(d)
(a)
(b)
None
Claims settled by agreement of the parties: All
State whether any written agreement is to be incorporated into the Divorce
Decree: N/A
Date and manner of service of the Notice of Intention to File Pmecipe to
Transmit Record, a copy of which is attached, if the Decree is to be entered
under Section 3301 (d)(1)(i) of the Divome Code:
Service: NA
Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed w/th the
Prothonotary: October 29, 2003
Date Defendant's Waiv · '
er ofNotme ~n §3301(c) Divorce was filed with the
Prothonotary: October 29, 2003
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By__
Andrew C. Spears, Esquire
Attorney I.D. No. 87737
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Document #.. 247892.1
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF PENNA.
JASON S. HUTCHISON
Plaintiff
VERSUS
REBECCA HUTCHI SON
Defendant
NO. 03-2378
PLEAS
AND NOW,
DECREED THAT
DECREE IN
DIVORCE
Jason S. Hutchison
AN D Rebecca Hutchison
ARE DIVORCED FROM THE BONDS OF MATRIMONy.
'"7--~, IT IS ORDERED AND
PLAINTIFF,
DEFENDANT,
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
~OTHONOTARy