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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