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Home My WebLink About99-03966 `?? h ?? 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. X111 it No. ?9 CL(O /?99_ VERSUS DECREE IN DIVORCE AND NOW, DEC 2-6CC?, IT IS ORDERED AND ,PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS 6FMATRIMONY. 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; E P llJ.9ez) lira Cv era"vof e? Ri Jrl :.Rupp & Meikle FAX [40. : 730 0214 Oct.. 30 2000 03:40PM PG C: \Corel\Suite8\wpdocs\domestic\Hardy\COUNSEL. AFF MARY BETH HARDY : IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TODD D. HARDY. Defendant NO.: 1999-3966 CIVIL CIVIL ACTION - LAW IN DIVORCE COUNSE M AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and J participate in counseling prior to a divorce decree being handed down by the Court. 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. Date: TODD D. HARDY, Defendant i`. LS, ? ?' _ =' l 1 1.. I ,`,.1 i) .... `., :i.IJ C1 :? _ .., U FROM Rupp 3 Meikle FAX NO. : 730 0214 Oct. 30 2000 03:39PN P3 I it C:\Corel\Suiteg\wpdocs\domestic\Hardy\COUNSEL. AFF i MARY BETH HARDY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v NO.: 1999-3966 CIVEL TODD D. HARDY, CIVIL ACTION - LAW IN DIVORCE Defendant j I COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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- Date: ? MARY B TH HARDY, Pl t tiff 4 ;?? i? Cw - ` _ i..` „J ?.J `_ r' 1 MARY BETH HARDY Plaintiff TODD D. HARDY, V. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1999-3966 - CIVIL . IN 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 3301(er of the Divorce Code. ( X ) Section 3301(c) ( ) Section 2. Date and manner of service of the complaint: r ,,^ta+nr t..nP ?a 1999 Acceptance of Service - August 27, 1999 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, ^'^°^"'ber 6 2000 by defendant, ^' hff f 2000 (b)(1) Date of execution of plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of service of plaintiffs affidavit upon defendant: 4. Related claims pending Date: Rupp & Meikle, P.C. Attorney I.D. #34832 355 North 21st Street, Suite 205 Camp Hill, PA 17011 (717) 761-3459 Counsel for Plaintiff CERTIFICATE OF SERVICE I, Richard C. Rupp, Esquire, do hereby certify that I am serving a true and correct copy of the foregoing Praecipe to Transmit Record upon the person named below by placing the same in the United States Mail, First Class, Postage Prepaid on the date stated below. Date: (( x Richard C. Rupp, Esquire Attorney I.D.# 34832 355 North 21st Street, Suite 205 Camp Hill, Pennsylvania 17011 (717) 761-3459 ?r (Y)r. 7-D?4d - (4a qq(C Px)51 cr LeyAc)( ne, N I -70q-3 ?? ?'= :i `? - . ?. __ .? MARY BETH HARDY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO.: 1999-,3P66 TODD D. HARDY, : CIVIL ACTION - LAW IN DIVORCE Defendant 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. Ajudgment 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the 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 17013 TELEPHONE: (717) 249-3166 MARY BETH HARDY Plaintiff V. TODD D. HARDY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 1999 - 396:6 CIVIL ACTION - LAW IN DIVORCE COMPLAIN T AND NOW, comes Plaintiff, Mary Beth Hardy, by her attorney, Richard C. Rupp, and files this Complaint in Divorce, based upon the following: 1, 2. 3. 4. 5. 6. 7. 8. Plaintiff, Mary Beth Hardy, is an adult individual residing at 3 Richland Lane, Apt. T-7, Camp Hill, Cumberland County, Pennsylvania 17011. Defendant, Todd D. Hardy, is an adult individual residing at 6117 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. Plaintiff and Defendant have been bona fide reside:.ts in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. Plaintiff and Defendant were married on November 19, 1993, in Mechanicsburg, Pennsylvania. There have been no prior actions for divorce or annulment between the Parties. Plaintiff and Defendant are both citizens of the United States of America. Defendant is a member of the Armed Services of the United States or any of its allies. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff avers that there are no children of the Parties under the age of 18. 10. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the Parties participate in counseling. 11. Plaintiff and Defendant separated on February 26, 1999. 12. Plaintiff asks the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. Respectfully submitted, Attorney for Plaintiff 2 Sup. Court I.D. No.: 34832 355 North 21st Street, Suite 303 Camp Hill, PA 17011 (717) 761-3459 VERIFICATION I, MARY BETH HARDY, verify that the statements in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. MARY ETH HARDY Date: LI - I (U - (i c I ?? ^? ? ?? h ? MARY BETH HARDY Plaintiff V. TODD D. HARDY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 1999-3966 CIVIL CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, TODD D. HARDY, the Defendant in the above referenced Divorce Action, do hereby accept service of the Complaint in Divorce filed by my wife. DATE: Z.o 7" -!j TODD D. HARDY, Defendant as 9t W } c u ?. C-D U i7 ? FROM : Rupp & Meikl.e MARY BETH HARDY Plaintiff V. TODD D. HARDY. Defendant FAX NO. : 730 0214 Oct. 30 2000 03:39PM P4 f IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 1999-3966 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 28, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Section 4904 relating to unsworn falsification to authorities. TODD D. HARDY, Defendant it ?? ,` r- _ . ?i ;- , _ -; . , FROM : RuPP & Meikle MARY BETH HARDY Plaintiff V. TODD D. HARDY, Defendant FRY NO. : 730 0214 Oct. 30 2000 03:39F-M P5 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 1999-3%6 CIVIL CIVIL ACTION- LAW IN DIVORCE WAIVER OF NOTICE OF I NTION TO b°OMT ENTRY F A DIVORCE DECREE UNDER cErTrnt,r t3n1(C) OF THE DIVORCE CODE 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 if 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 unsworn falsification to authorities. Date: ? . TODD D. HARDY, Defendant •- r> >- i;; ?. - , . ? ?,. )- -- ? -'? ? -- n ? ?. - r:: =i 7 J :_t? Li FROM : Rupp & Meikle MARY BETH HARDY Plaintiff V. TODD D. HARDY, Defendant FRX NO. : 730 0214 Oct. 30 2000 03:38PM PI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.. 1999-3966 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 28, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Section 4904 relating to unsworn falsification to authorities. Date: :> ;? ?,. .. ;:;°,' - ,.. _ ' o =? = , _? FROM : Rupp & Meikle FAX NO. : 730 0214 Oct. 30 2000 03:36PM P2 MARY BETH HARDY Plaintiff V. TODD D. HARDY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.., 1999-3966 CIVIL CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF I bMON TO REQUEST ENTRY OF A DIVORCE DECREE UNDER-SEC n-ON 330110 OF THE DIVORCE CODE 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 if 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 unsworn falsification to authorities. Date: ko-e-?bkl _`0 ?((j r y MAR TH HARDY, Plaint ff ., ? .. ; ,, ._ ,=: ? - _? __ -,