HomeMy WebLinkAbout01-04715[N THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
4'
STATE OF PENNA.
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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,
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PROTHONOTARY
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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
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K NE F. LEWIS, ESQUIRE
Attorney for Plaintiff
1101 North Front Street
Harrisburg, PA 17102
(717),234-3136
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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.
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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
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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.
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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.
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DATE: U ~ ~ ~~~~ ~ ~ ~ ,~ ~
KRISTEN M. HILDEBRANDT
210 Senate Avenue
Apartment #418
Camp Hill, PA 17011
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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
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