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HomeMy WebLinkAbout99-05851 Yz vp:r I y ?z S+, f ti Y Y Y.R "arS ix f(a'e M h. .i4 ' A rYµy: U ?> {r:1 J?U r { yDw' t t x t " c ry?? F i i l? T 1?}? `A 'ifY o oc cry ,-ae•..:e•, <. ,,; .,r,. •:r.•: •ar:.r• .r.• rte. , ?. <? • •r•' -3r y Wv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. f i i H { Donna-Hughes ......... Plaintiff Versus Martin...T._: Hughes.Defendant .__ DECREE IN DI V 0 R C E AND NOW, ........... 4?r!a" ?.. , 19.it is ordered and ! R decreed that ...... ???o.Q ..... H?.f. ?q-' ..................... plaintiff, and ............!?74*:tin .. 1-. . . !?!!fj?t? ..................... 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; v .............................iuE ........................................., 3 .......... . ............................................................. By The Court: Attest. f Prothonotary v .IG ar.• •:W •71'i ^.I"r W. •iri ;V' 'Xi ;?: .r. .?. •r• <?• :?• :?• ;?:• •:6• t%• c%?r• •s• :@ <A• •:?} :1.. .;A •.:{R; , ?4:•. N.. ' ,,•, Cww DONNA HUGHES, Plaintiff V. MARTIN T. HUGHES, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99-5851 CIVIL TERM 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: September 23, 1999, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the plaintiff, January 15, 2000; by the defendant, December 22, 1999. 4. Date of execution of Waiver of Notice of Intention To Request Entry of a Divorce Decree: by the plaintiff, January 15, 2000; by the defendant, December 22, 1999. 5. Date and manner of service of plaintiffs Affidavit of Consent on defendant: January 20, 2000 by first class United States mail. 6. Related claims pending: none. Date January 20, 2000 Todd Greene Ce ' ied a aAnt m THOMAS M. PL CE ROBERT E. RAINS Supervising Attorney DONALD MARRITZ FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ly-<j IL".. i' y. v C E )2f N J? w o U ,r DONNA HUGHES : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW :IN DIVORCE MARTIN T. HUGHES Defendant : NO K!05"CIVIL TERM 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, 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, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. DONNA HUGHES, Plaintiff V. MARTIN T. HUGHES Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99- / CIVIL TERM The plaintiff, Donna Hughes, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Donna Hughes , who currently resides at 657 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Martin T. Hughes, who currently resides at 1465 Trindle Road, Apartment D, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on August 8, 1991, in Craven County, North Carolina. 5. Plaintiff and defendant have lived separate and apart since March of 1998. 6. There have been no prior actions of divorce or for annulment between the parties 7. Defendant is a member of the Armed Forces of the United States of America, specifically the United States Marine Corp. 8. The marriage is irretrievably broken. 9. 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. WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the marriage. Date 11231ff Todd Greene Certified Legal Intern THWASM. PEWS ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 I verify that the statements made in the foregoing Divorce Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ( lz51 <:? 1 Donna Hughes fi 4 w5% oc. cv =?. 7 fj i.i 4- r , > . J 7 :. ui °_ N N -7Z LL 5i1 ? Cil? 2 F v o U ON Ol 7 A ? aY i1.. MARTIN T. HUGHES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99-5851 CIVIL TERM CERTIFICATE OF SERVICE e Ir a a 4 0 I, hereby certify that on September 23, 1999, I served a true and correct copy of the Divorce DONNA HUGHES, Plaintiff V. Complaint on Martin T. Hughes, residing at 1465 Trindle Road, Apartment D, Carlisle, Pennsylvania, 17013, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Martin T. Hughes on the 29" day of September, 1999, as evidenced by Mr. Hughes' signature on the attached return receipt. Z 332 848 793 US Postal SeMdn ; Receipt for Certified Mail No Insurance Coverage Provided. YVIIVI U.IV11111tl111tlYU11tlI mmi oe&ruveme Nto r 'r,t. 1} SimM 81AUMer 14 Toivdk RooA ?. 0 Post OMro, Sole, d ZIP Cade Carlisk, Ph 11 13 Postase $ 5s Ceeihed Fee Spedal Delhery Fee Ibeulged Defvery Fee / Halem flxdq Shared ro ' WTIpm80w De1venM aeon R$Ce0 A gtoWhom, . Dete,BMAweslMdw TOTAC P' a i Pu dt,Este I 5 ry ? ? ? r 1 , :/ Todd Greene Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 ' Sorry We Missed Youl We IP Deliver for You -? /Ill l y W. C prim IAvalnbn Tor Pkk-up After 'AQ061 office (See back) Date: If eheeked, you or your agent must be proem at time of delivery ps?nm 7 rider For Dallvery: (Enter total numberolitems Racer Art Is Numbers) 17y Large deb'veradbyzioNkIPOP, 3??-_-- { ....... _Rri9ieend ______________________________ Ykg, etc. _ Eapnu k6a M'••a ____________________ Cal •naetbdNrwm na nurerewrda/'unbJ - Insuled __________________________________________________ '' Ruuknd d•umrvdesan Rotate Racei pt • bkobal ____________________________________________________ v emery \. J di _ for merchandise Perishable XG Density ery r Item _ Recorded _ confirmation Other: Delivery Slgnrilu, Customer matured nu Achd Firm 00 -Confirmation {•//IelL%'< ? Postage Due O COD O (ousi me s • N v,- Final NOllee: Ankle are D•I r y Dafe C S be returned to "rider W [ PS Form 3849, February 1998 ellvwy Notlael Reminder/Ne"Itta r , We will redeliver OR you or your agent can pick up yourmail at the post fence. (Bring flee form andpvdper ID. If youragvvrf will pick up, sign below in item 2, end enter agents name hare)' 1. Customer'. a. Check all that apply in CARLISLE 17013 -section 3: b Sign in section 2 of low; and 66 W. LDUther Street ' c. Leave that notice where the M-F 5:00 l0 4:30 Sal. 9.12 carrier can see it 717-243.3531 2. Sign Hera to Authorize Redelivery, orto Authorize an Agent to Sign for You tlory Asllwry ? 30 Redeliver(Enrerdayofweek) lA j`, lAeo,V if least avo delivery days Tor redelivery of fall your Post Nat / r /J / Gf e?'y , olace to arrange delivery.! ---- ? Leave item at my address Delwary Addreaa $,,eoly where to leave; example 'pomn•. 'srae aoor'.) (This option is notavoilab osbcMcMd on the front Ironf re rs juiri tubing your signature ?II II IIIIII?III III I?I IIII IIII at time of delivery.) n Refused c Fervent O Saturn 5200 0003 :1005 0525 PS Form 3849, February 1999 (Reverse) N t `' nl n t=: Ll . cl? f? (L C DONNA HUGHES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE MARTIN T. HUGHES, Defendant : NO. 99.5851 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on September 23, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 alter service of notice of intention to request entry of the decree. I verify that the statements umdc In [his off idavii are true and correct. I understand that false statements herein are made subject to the penallics of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date 1 d? ??Yll Donna Hughes q 1JJn U ?C U G V e•' cn n= VZ l?J O > N ri r 71 I o CD U DONNA HUGHES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE MARTIN T. HUGHES, Defendant : NO. 99-5851 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on September 23, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 unworn falsification to authorities. Date L,2 9 Z' M /tin T. Hughes Y p? ? F u?C o l? ter. ? :c ?.>?: a ' N =' C O v DONNA HUGHES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE MARTIN T. HUGHES, Defendant NO. 99-5851 CIVIL TERM 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: W Donn Hughes Plaintiff ?; ? G CC?'' ? ???FT' Z +ct J . ? 1 r ' L' ]'" ? ?' N ? ? CrJ ii ?' •.!lU ?n? r "? C1 U ? DONNA HUGHES, Plaintiff V. MARTIN T. HUGHES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE NO. 99-5851 CIVIL TERM WAIVER-OF NOTICE OF ETENTTON TO HBO EN RY OF F em §pTq A DTVOR r nvnp7pc 'D R rT 3301(C) OF THE DIVORCE COVE 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. and correctly Ithat the understand statements that t false e stin this atements affidavit herein are emadee subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: d.,2 *endant ghes } O C ? urn :_ b: 7 ILI L_ C O U DONNA HUGHES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : IN DIVORCE MARTIN T. HUGHES, Defendant : NO. 99-5851 CIVIL TERM CERTIFICATE OF SERVICE I, hereby certify that on September 23, 1999,1 served a true and correct copy of the Divorce Complaint on Martin T. Hughes, residing at 1465 Trindle Road, Apartment D, Carlisle, Pennsylvania, 17013, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Todd Greene Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 p_c? ,... X74 Q i j c,. drt G O U r.._:. - ...:...-....- DONNA HUGHES, Plaintiff V. MARTIN T. HUGHES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99-5851 CIVIL TERM CERTIFICATE OF SERVICE I, Todd Greene, a Certified Legal Intern, hereby certify that on January 20, 2000,1 served copies of Plaintiffs Affidavit of Consent, Waiver of Notice of Intention to Enter Divorce Decree, Praecipe to Transmit Record and Vital Statistics Form on Martin T. Hughes, residing at 1465 Trindle Road, Apartment D, Carlisle, Pennsylvania, 17013, by first class United States Mail. l? Todd Greene Certified Legal Intem FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 a, 1. ?? tT Win.. N X77 1 _ _ r?• ;ii.u 2 U O U