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HomeMy WebLinkAbout99-03782 1:5 ??r ;o ? .? • to • :e• •:? • :? • :? • r,• re, _y:• .;?. t? • •:?: •:e• IN THE COURT OF OF STATE OF PENNA. COMMON PLEAS CUMBERLAND COUNTY 8 WILLIAM L. HOLLENBACH Plaintiff Versus WENDY E. HOLLENBACH Defendant `lt.....99-3782 ................. DECREE IN I V O R C AND NOW,. ... . , , , 19? . it is ordered and . L. . HOLLENBACH . decreed that . . . . . . W . I . LLIAM .. ................. . . . Plaintiff, and , , , , • • , , . , , . , , , , , , WENDY... E.. HOLLENBACH. .......... . . . .. , defendant, are divorced from the bonds of matrimony. ti v `F. 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 ........................................................................... ................................................... B T e o r i st: • J. Prothonotary i i ii s ?y i i i /?. g. 99 5;6? cur-?.f ? O WILLIAM L. HOLLENBACH, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) CIVIL ACTION - LAW WENDY E. HOLLENBACH, Defendant ) NO.99-3782 CIVIL TERM 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(c) x33tDF('dj fof the Divorce Code. (strike out inapplicable section) 2. Date and manner of service of the Complaint: July 13, 1999, by certified mail, restricted delivery mailed to the Defendant. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff 10 / 15 / 9 9 ; by Defendant 10/19/99 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (2) date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Relatedclaimspending: There are no outstanding issues 5. Complete either paragraph (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 Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Mailed to Prothonotary 10/25/99 Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Mailed to Prothonotary on 10/25/99 WILLIAM L. HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. WENDY E. HOLLENBACH, CIVIL ACTION -LAW Defendant NO. 99- ,3 .2 CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in foregoing pages, you must take prompt action. You are warned that if you fail to do so, thtehe case may proceed without you and a decree in 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: Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 17013 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 17013 Telephone: (717) 249-3166 WILLIAM L. HOLLENBACH, IN TLIE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW WENDY E. HOLLENBACH, Defendant NO. 99- CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. WILLIAM L. HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. WENDY E. HOLLENBACH, CIVIL ACTION -LAW Defendant NO. 99- CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW comes the above-named Plaintiff, WILLIAM L. HOLLENBACH, by his attorney, Michael L. Bangs, Esquire, and makes the following Complaint in Divorce: 1. The Plaintiff is WILLIAM L. HOLLENBACH, an adult individual who currently resides at 1604 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is WENDY E. HOLLENBACH, an adult individual who currently resides at 4175 Mountain View Road, Apt. 110, Mechanicsburg, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 27, 1995, in Las Vegas, Nevada. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling, 8. The Plaintiff requests this Court to enter a Decree of Divorce in this matter pursuant to Section 3301(c) of the Divorce Code. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. Section 4904 (unworn falsification to authorities). Date WILLIAM L. HOLLENBACH MICHAEL L. BAN Attorney for Plainti 302 South 18th Stre t' Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 is It l rol y N On 3 ? z d wry= n a f y H n - V WILLIAM L. HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW WENDY E. HOLLENBACH, Defendant NO. 99- 3782 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL MICHAEL L. BANGS, being duly sworn according to law, deposes and says as follows: 1. That he is the attorney for the Plaintiff herein. 2. That on July 7, 1999 , he delivered to the U.S. Postal Service in Camp Hill, Pennsylvania, as certified mail (Receipt No. Z 07 5 084 72 9 ), return receipt requested, addressed to the Defendant herein, a true and correct copy of the Complaint in Divorce filed in the above-captioned action duly endorsed with a Notice to Defend and Claim Rights. 3. Said return receipt card is attached hereto as Exhibit A showing a date of delivery to theDefendantof July 13, 1999. MICHAEL L. BA Sworn to and NdtANAL SFAL Y&MY S. CH"SUM, Nabh? FubCx Lower A= rwp., C?-ryex?ind r avrk/ My Commk"" k+plrer fAcy 10, 20M E X H I B I T A '$3 •c SENDER: lain 1.wor 2 tar eaawalw Nrnc... I also wleh to receive the •CatipMe Nms 9. N, and 40. folWng services (for an ywr name wed address m"maN of Nh form w Met"M mtm see eXtre fee): =Cf. pee to tM hoM of the rtiallp4N, son the back sepeN dm not 1. CI-Addrassaill's Address q aR/dta'RNOm Reoe1pfRpawfsd'm"md;embd0wthe NlkNreenbea 2. Restricted DelNe 5 e7tts Reim ReoNpt We show to whom the arlds me deavNad and the date 4b. Service Tyre 91.15 W6UAITAIW UI 60 ?F IID ? Registered r f] EEtrreee Mail kj?NAUIc5ta(,, PA 11bw ?ReiumRsoeiptfa 7. Date of Delivery? "'I b "' 5. Received By. (Print Name) fl r n r ) ?t 6. Signature: (Add NdrAyenQ SLIVERY ? ` 8 PS Form 3811. December 1994 Domestic Retum e ?a 3 Y t, I-D Ul n '? 3 w z n ? . ? y a m Z Y Z W xri 4 •Dn F. N .i U WILLIAM L. HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW WENDY E. HOLLENBACH, Defendant NO. 99- 3782 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT June A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 22, 1999 and was served upon the Defendant on or about July 13 , 1999 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint and the date of service of the Complaint on the Defendant. 3. I consent to the entry of a final Decree in Divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. 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. 5. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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 unswom falsification to authorities. Date WILLIAM L. HOLLENBACH tL t„? ?.? . .. t r ' c:., ?i WILLIAM L. HOLLENBACH, Plaintiff VS. WENDY E. HOLLENBACH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99- 3782 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. Section 4904 relating to unswom falsification to authorities. /dam/ 'AT ?-.r7 i6'? F Date ?- WILLIAM L. HOLLENBACH ? ? to i??' ;1 _ ? ??`?' .. i :? - ., c ., C- ?. c.: U r, Cr' ? <% WILLIAM L. HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW WENDY E. HOLLENBACH, Defendant NO. 99- 3782 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tiled on June 22, 1999 and was served upon the Defendant on or about July 13 , 1999 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint and the date of service of the Complaint on the Defendant. 3. I consent to the entry of a final Decree in Divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. 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. 5. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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 unswom falsification to authorities. Date WIENDY E. HO LENBIll ACH ;? _ ?:, _. ??? ??: ' ? ; " _: ,: . - , , . . ' ; ?-= ? . ?_ LJ C1 UI WILLIAM L. HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW WENDY E. HOLLENBACH, Defendant NO. 99- 3782 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENSION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301fc1 OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. Section 4904 relating to unworn falsification to authorities. h- I q -9q l C.QE44b--p o tiIc.aA k Dated WENDY E. HO LENBACH ?: ?, ,, ;' : ?-, ,: ; _. _? •. ?_ :: _? ,,, ?. ", ;_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs. 40l (1 vib9n Defendant File No. Qq - 3-7j.). IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that above matter, having been granted a day of (II h L?il? 19 qq prior surname of ?°r- this written notice pursuant to the the Plaintiff /Defendant in the Final Decree in Divorce on the hereby elects to resume the and gives provisions of 54 P.S. S 704. DATE: rd ?nj Pbh?yia.-In S igaa ture Signature o name being resumed COMMONWEALTH OF PENNSYLVANIA: . SS. COUNTY OF CUMBERLAND 2" On the ,25 day of Fnyaar 19 , before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Emma K. Weitzel. Notary pupil 11 Carlisle Bore. Curnbena id County My Commission Expires June 1.2DO2 Member, Pennsylvania Assoc lalian al NDIatIBi -. ??. ?, . ` _.>