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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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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 !
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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;
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.......... . .............................................................
By The Court:
Attest.
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Prothonotary
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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
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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
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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
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I, hereby certify that on September 23, 1999, I served a true and correct copy of the Divorce
DONNA HUGHES,
Plaintiff
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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.
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US Postal SeMdn ;
Receipt for Certified Mail
No Insurance Coverage Provided.
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Todd Greene
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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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
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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
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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
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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
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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
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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.
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Todd Greene
Certified Legal Intem
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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