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Home My WebLink About01-04873 IN THE COURT OF COMMON PLEAS CHRISTINA S. SEIFERT, Plaintiff NO. 4873 2001 VERSUS JOHNNO R. HILLS Defendant DECREE IN DIVORCE AND NOW, a.) y vet , Z00Z IT IS ORDERED AND DECREED THAT CHRISTINA S. SEIFERT , PLAINTIFF, AND JOHNNO R. HILLS 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 spa, CHRISTINA S. SEIFERT, VS. JOHNNO R. HILLS, To the Prothonotary: IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Defendant NO. 01-4873 CIVILTERM PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) X93Ct"(4 of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: October 19, 2001 by Registered Mail 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff July 8, 2002 ; by defendant July 27, 2002 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 8, 2002 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: August 5. 2002 ?? ?JC 9c c25:? Att ey for Plaintiff / Defendant C) r z -c^ u x? ? - -i '- a fn -4 4J- yu*- CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.0 /- Ll9-73 IN DIVORCE 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 the 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 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, Pennsylvania (717) 249-3166 Anthony L. DeLuca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. (31-q$73 IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is Christina S. Seifert, who currently resides at 156 Brindle Road, Mechanicsburg, Cumberland County, Pennsylvania, since August 9, 2001. 2. Defendant is Johnno R. Hills, who currently resides at 6 Arundel Street, Maidstone, Kent ME14-2RS United Kingdom since June, 2001. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 24, 2000 at Mechanicsburg, Cumberland County, Pennsylvania. 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. Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date: v ,2 Q 1 Christina S. Seifert, Plaintiff jot 110 ony L. D a, Esquire Attorney for PI tiff 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 CHRISTINA S. SEIFERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW JOHNNO R. HILLS, : NO. D I ^ y ?z_3 Defendant : IN DIVORCE In sernrdance with R C. P 1930 4 (d_ I, Johnno R. Hills, Defendant in the above-captioned action in divorce, do hereby voluntarily accept service of the Complaint filed to the above- captioned action and acknowledge receipt of a copy thereof. Date of Acceptance of Service: ga Johnno R. Hills vin ? ? ?TI'o ?.SE? 1L ; -iQ 2Mk^ _ Mailing Address c7 C ? en nor:` ;-? -1 G: C7 ? m CIi ? 4J V ?. CHRISTINA S. SEIFERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW JOHNNO R. HILLS, NO. 01-4873 Defendant : IN DIVORCE 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904 relating to unswom falsification to authorities. Date ?" V GUS (J?SL Christina S. Seifert, Plaintiff - r F _ 34 CHRISTINA S. SEIFERT, Ptaintiff VS. JOHNNO R. HILLS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-4873 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE I . I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. § 4904 relating to unswom falsification to authorities. Date: O J 1 V d fJCI o} Christina S. Seifert, Plainti L? 3?{ CHRISTINA S. SEIFERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW JOHNNO R. HILLS, NO. 01-4873 Defendant : IN DIVORCE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says that he mailed by REGISTERED LETTER, a true and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Defendant at his residence and that Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A". By: Anthony L. D uca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 Sworn to and subscribed before me this c?4day of $ , 2002. 4e' otary Public NOTARIAL SEAL MARJORIEA. DeIUCA, Notary PubUc South Middleton Twp., Cumberland Co. Commission Expires Nov. 1, 2003 a pry-,. x= f' may:- tjr III I CHRISTINA S. SEIFERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW JOHNNO R. HILLS, : NO. 01-4873 Defendant : IN DIVORCE 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904 relating to unsworn falsification to authorities. Date: -AQA 'ne.)- Jo o R. i s, efendant C_ ?? rJ 1 -C C7J ".?.F .,:. ,Y»tASVS• ki9%bka`'!b'.`i''?F:t'.1' kf I CHRISTINA S. SEIFERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW JOHNNO R. HILLS, : NO. 01-4873 Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2, 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. 3, I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. § 4904 relating to unsworn falsification to authorities. Date: -417 ? 1 n: Johnno R. i s, a endant 0 a Z r ?'? : C e?/7 /.S?YiI la S'^ SP T?ait? VS. In the Court of Common Pleas of Cumberland County, Pennsylvania No. - 0 (- ! 1?-rz? Civil. 19 , Ai ?/ 6 ice/ y w C??rf 6(7.V'4 '-A4!`' i i I( =To Prothonotary Attorney for Plaintiff ??- -ir\:- No. Term, 19 CWP,i dt?SYl.'J?1rV'A v$. PRAECIPE 19