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HomeMy WebLinkAbout01-04715[N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 4' STATE OF PENNA. -.,. N O. 01-4715 Civil Term VERSUS KRISTEN M. HILDEBRANDT DEGREE IN DIVORCE AND NOW, I ~ , ~d~~ IT IS ORDERED AND DECREED THAT DONALD P HILDEBRANDT ,PLAINTIFF, AND KRISTEN M_ HTT.DF.RRANDT DEFENDANT, 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 By T ATTEST: (/__n//, ,J, 7~ PROTHONOTARY ~~ ~rv ~a~~~~ se~wrta~+m~.aerynz ~a;~RefaENM3~ _ ..-,. DONALD P. HILDEBRANDT, Plaintiff v. KRISTEN M. HILDEBRANDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4715 Civil Term CIVIL LAW - DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: 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(d) (11 of the Divorce-Code. 2. Date and manner of service of the Complaint and Plaintiff's Affidavit upon Defendant: Acceptance of Service sianed ~15/O1. 3. Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: 8j8/O1; filed 8 9 O1. 4. Related claims pending: NONE 5. Date of Defendant's Counter-Affidavit (indicating no opposition to entry of divorce decree and that Defendant does not wish to make any claims under the divorce code): 8 15 O1. DATED: 8/20/01 ~/ K NE F. LEWIS, ESQUIRE Attorney for Plaintiff 1101 North Front Street Harrisburg, PA 17102 (717),234-3136 ..,-,-. r> _.._ <- -oii. rc-ir:~- - _-- ~_r- - ~- _ <- ~- rr._: -. c ~ : . .-. ~~ ri - rri , 3. _.. .. ~ ,. .. -. ... i~d=Mh M4 .µµ'_ '~91?M :goFF#iRU'~a~&145`~~'FS Nb'InTe~. __ .... ~ r. r KENNETH F. LEWIS, ESQUIRE I.D. X69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, Plaintiff V. KRISTEN M. HILDEBRANDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,nnPENN~S-Y/L-VANIA CIVIL LAW - DIVORCE NOTICE TO 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 or visitation of your children. 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, Hanover t: High Streets, Carlisle, PA 17013. TF 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 (717) 249-3166 1-800-990-9108 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,nnPENNSYLVANIA v. NO. UL' ~'@'~~S l.lV~~~~ KRISTEN M. HILDEBRANDT, Defendant CIVIL LAW - DIVORCE COMPLAINT IN DIVORCE Request for a No-fault Divorce Under 63301(d) of the Domestic Relations Code 1. Plaintiff is DONALD P. HILDEBRANDT, an adult individual with a mailing address of P.O. Box 130, Gibbon Glade, Fayette County, PA 15440. 2. Defendant is KRISTEN M. HILDEBRANDT, an adult individual residing at 210 Senate Avenue, Apartment #418, Camp Hill, Cumberland County, PA 17011. 3. Defendant has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 31, 1997 in Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage 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. There are no minor children born of the marriage. 9. Plaintiff and Defendant have been living separate and apart since January 9, 1999. Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(d) of the Domestic Relations Code. r DATEp: 8/8/01 K NE F. LEWIS, ESQUIRE Attorney for Plaintiff I hereby verify that the statements made in the foregoing document 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: 8/8/01 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. KRISTEN M. HILDEBRANDT, Defendant CIVIL LAW - DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Plaintiff avers that Defendant is not in the Military Service or in any branch of the armed forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. I hereby verify that the statements made in the foregoing document 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: S/8/O1 KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. KRISTEN M. HILDEBRANDT, Defendant CIVIL LAW - DIVORCE AFFIDAVIT ONDER SECTION 3301fd!) OF T8E DIVORCE CODE 1. The parties to this action separated on January 9, 1999 and have continued to live separate and apart for a period of at least two 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 unsworn falsification to authorities. Dated: 8/8/O1 DONALD P. I DEB NDT \~ / ~ ~ ~ "t ~ `" C: ca 7 c -- ~; -~ ,,, -~ -; ~- , %' c. t~ rn ~ 3 ~ _ :,> ,~ ~ cn ~J KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, Plaintiff v. KRISTEN M. HILDEBRANDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O~`~7~$ CjY~~ ler~+ CIVIL LAW - DIVORCE COIINTER-AFFIDAVIT UNDER SECTION 3301(dI OF THE DIVORCE CODE 1. C)aeck either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail do do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter- 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. Q n l e' DATE: (1 -/~ "" C ~ ` STEN M. HI B NDT, D fendant NOTICE: IF YOII DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MARE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COIINTER-AFFIDAVIT. C"? c_: c- -- T C' '_a flii _- ; ;.7 _ t= C ±~J ~~ ~ ~. ~- Ci (_> ~„ C,' ~; L '33 `A'; - cn =,. KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO.OI'~{'~~S UviI~L(M KRISTEN M. HILDEBRANDT, Defendant CIVIL LAW - DIVORCE ACCEPTANCE OF SERVICE X accept service of the Complaint in Divorce, along with Affidavit of Non-Military Service and Counter-Affidavit. ~( ~~ DATE: U ~ ~ ~~~~ ~ ~ ~ ,~ ~ KRISTEN M. HILDEBRANDT 210 Senate Avenue Apartment #418 Camp Hill, PA 17011 t°; ! '~,_ ~ ~ -~::r (77 G7 ; ~i G~ `J j~L.i -;'r'S L Ca f may' ~;1 ~~~ C~'v "i~ ' Kam- r ~ rwx,s .„:. ~,~m,.~,~x~ew~~~ ~:~,-:.~~,~~:~.;.. w Donald P. Hildebrandt, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND CO., PENNSYLVANIA v. Kristen M. Hildebrandt, Defendant NO. 01-4715 CIVIL ACTION -LAW IN bIVORCE NOTICE OF ELECTION TO RESUME MAIDEN NAME Notice is hereby given that a fmal decree in divorce being granted, hereby elects to resume her prior name of Kristen M. Rovito, and gives this written notice of her intention in accordance with the provisions of 54 Pa.C.S. Section 704. 'sten M. Hildebrandt to be known as K Kr sten M. Rovito COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~C.e1rc.(~.-~~~ ss. On the day of ~e~e-r , 2001, before me, a Notary Public, personally appeared Kristen M. Hildebrandt, t/b/k/a Kristen M. Rovito, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Public NoParlal Seal Deborah L. Brenneman, Notary Public Camp Hill Boro, Cumberland County My Commission Expires June 18, 2002 Member, Pannsylvania Association of Notaries ~. C~ 1 \y v ~i ~~ r~ r- i7C'3 f7lF" _..., 1:.:' C~5 ~: -<.<' C [_: ~~ ~' C; T r.7 f`^~ _~ f::~ _~, :~, Y4l C,~ c. t_.'J~ -=; Y ,__, Nt 77