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Home My WebLink About99-05983 1 r? ?O h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TAMMY L. HALTER. Plaintiff No. 99-5983 CIVIL TERM VERSUS GLENN E. HALTER, Defendant DECREE IN DIVORCE AND NOW, MAY 3 2000 , IT IS ORDERED AND DECREED THAT TAMMY L. HALTER ,PLAINTIFF, AND GLENN E. HALTER ,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. BY THE COURT: PROTHONOTARY aA4 31 r r J TAMMY L. HALTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 99-5983 CIVIL CIVIL ACTION - LAW GLENN E. HALTER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this (`s day of May, 2000, upon consideration of Plaintiffs BY THE COURT, pmecipe to transmit record, and it appearing that Count II of the complaint respecting various economic issues has not been withdrawn and remains pending, and that this divorce action has not been bifurcated, a divorce decree will not be issued at this time, without prejudice to the parties' rights to file a new praecipe at such time as the economic claims have been withdrawn or resolved on the record. John J. Baranski, Jr., Esquire For the Plaintiff :rlm K3 JOHN J. BARANSKI, JR. SUPREME COURT 10 NO 82505 35 EAST HIGH STREET, SUITE 202 CARLISLE PA 17013 (717) 2435090 TAMMY L. HALTER, Plaintiff V. GLENN E. HALTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 - 5983 CIVIL TERM :IN DIVORCE PRAECIPE TO TRANSMIT RECORD Please 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: On or aboulOctober 6, 1999 defendant was served by certified mail, restricted delivery, with a copy of the divorce complaint. See Affidavit of Service filed by plaintiffs counsel. 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 the plaintiff: April 18, 2000 By the defendant: May 4, 2000 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A; and (2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 4. Related claims pending: None. 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: N/A (b) Dale plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: May 11, 2000 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: May 11, 2000 ?-+ May 25, 2000 / JOH J. BARANSKI, JR., ESQUIRE Attorney for Plaintiff JOHN J. BARANSKI, JR. ATTORNEY W. NO 8585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-8090 ATTORNEY FOR PLAINTIFF TAMMY L. HALTER, Plaintiff YS. GLENN E. HALTER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 5983 CIVIL TERM IN DIVORCE Praecipe to Withdraw Count 11 of Plaintiffs Complaint in Divorce To the Prothonotary: Please withdraw Count II of plaintiffs complaint in divorce as all economic issues have been settled pursuant to a Marital Settlement Agreement dated May 4, 2000. Respectfully May 25, 2000 JO)fN J. BARANSKI, JR. Attorney for Plaintiff 35 East High Street, Suite 202 Carlisle, PA 17013 (717) 243-8090 Supreme Court ID No. 82585 ?? ?. ?= ,,, . ?_,; `<??, ?' ?: ? ,,, ?. , ;. ' ` JOHN J. BARANSKI, JR., ESQUIRE LAW OFFICE OF HAROLD S. IRWIN, III ATTORNEY ID NO. 92999 35 EAST HIGH STREET CARLISLE PA 1701 (717) 243.6090 ATTORNEY FOR PLAINTIFF ., TAMMY L. HALTER Plaintiff V. GLENN E. HALTER, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 5953 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD Please 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: On or about October 6, 1999 defendant was served by certified mail, restricted delivery, with a copy of the divorce complaint. See attached Affidavit of Service filed by plaintiff's counsel. 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 the plaintiff: April 18, 2000 By the defendant: May 4, 2000 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A; and (2) Date of filing and service of the plaintiffs affidavit upon the defendant: NIA. 4. Related claims pending: None. 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: N/A (b) Dale plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:May 11, 2000 Date defendant's Waiver of Notice in Section 3301(c) Divorce was fj(Bd with the Prothonotary: May 11, 2000 May 11, 2000 Attorney for C C ? -` ?:. - •'r L:. .: ?4 >_ I?I .l. :1:. 1,. :L LL C 7 V G l? ?1 LAW OFFICE OF HAROLD S. IRMN, 111 ATTORNEY ID NO. $7506 35 EAST HIGH STREET CARLISLE PA 17017 (717) 243-0090 ATTORNEY FOR PLAINTIFF TAMMY L. HALTER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 99 - CIVIL TERM GLENN E. HALTER, 59?3 Defendant : IN DIVORCE NOTICE 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 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 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 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 AVE CARLISLE, PA 17013 (717) 249-3166 f TAMMY L. HALTER PlaintNf L-n GLENN E. HALTER, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAM NO. 99 - CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, John J. Baranski, Jr., Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Tammy L. Halter, an adult individual residing at 437 Crossroads/School Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Glenn E. Halter, an adult individual residing at 722 Grahams Woods Road, Newville, Cumberland County, Pennsylvania 17241. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on April 10, 1993, in Cumberland County, Pennsylvania. 11 COUNT I - DIVORCE Plaintiff hereby incorporates by reference averments 1 through 4 as if each averment were set forth fully hereunder. 5. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 6. Neither party is in the Armed Forces of the Untied States. 7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that she has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. COUNT II - PAYMENT OF FEES Plaintiff hereby incorporates by reference averments 5 through 8 as if each averment were set forth fully hereunder. fees. Plaintiff requests alimony, alimony pendente lite, costs and attorney's WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties and such other additional relief as the Court deems necessary. Respectfully submitted, LAW OFFICE OF HAROLD S.,IMIN. III Date: n7 19 n JOHN . BA SI I, JR., ESQUIRE ID # 2585 Attomey For Plaintiff, Tammy L. Halter VERIFICATION I verify that the facts cuntained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. September 1999 Tammy L. Halte laintiff CS: cJ . Cl) J j L•7 ,a v c U - U, 0 (3 1 1; L) CL d .? X 1 TAMMY L. HALTER Plaintiff V. GLENN E. HALTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 5-183 CIVIL TERM • IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. September, 1999 0u o F 1?1 Tammy L. Halter V O L ce; n T t . c ; [ l u U ? TAMMY L. HALTER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ?• : CIVIL ACTION - LAW NO. 99 - y,? CIVIL TERM GLENN E. HALTER, Defendant :IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R C P RULE NO 1920.4 (a)(1)(1) NOW, John J. Baranski, Jr., Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about October 6, 1999, by certified mail "restricted delivery", addressed to him at 722 Grahams Woods Road, Newville, PA 17013, certified mail, return receipt No. Z 339 062 132. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities-, . , __ 7 October)g, 1999 J. Baranski, Jr. iey for plaintiff r -Si e or 1 of i 1 . ? OI 0 O. o 3. ?n ig I 1 PS • I al-enyg wish to receive the follow- t too): f ame i and/or 2 for aedlional eemces. ra or an ex Ing Arv"s ( ame 3. N. and 90. was and addmaa on the reverse of IN. torte w dial we ran relum INS I., •1 ? Addressee's Address twm W the ft,,, of ft maeplace, or on the fuck f space does ml 2. O Restricted Delivery m RacW Raquwled,m Ins mellplace below the adkle renroer. i Rarelol MI snow to whom the arWe was delNeled end tha dale ArdCIBAddressed 10: `woa33or Ee5 O6z /3 t? °1 G, A 1 IV/q LTC O 4b. Sece Registered Type XCeN9 zi f?GrAOgJ'nSOL)OMS? ?ExpressMail ?Insured "N `Return Receipt for Merclwlolse ?COD (71v1 C,W v 7. Date of Delivery 172W ILI /Of?b/ ff , December 1994 feels IMSB539BA22] L 1 1 1 _p6 I C 6 ? I(. YL , F C: 4'.. r r_. r C. U Ch U1 j 1, JOHN J. SARANSKI, JR. ESQUIRE LAW OFFICE OF HAROLD S. IRWIN, 111 35 EAST HIGH STREET CARLISLE, FA 17013 (717) 243.8089 DANIEL E. HORNER, Plaintiff V. HAYLEY JO SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :No. 00-2492 Civil CIVIL ACTION LAW CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of plaintiffs Complaint upon the defendant by placing same in the United States mail at Carlisle, Pennsylvania, Certified Mail on this 7 0 7 10 day of May, 2000 and addressed as follows: ,.HAYLEY JO SWARTZ '' 37 SOUTH EAST ST = m CARLISLE, PA 17013 .f. cn -c JohrrT Baranski, Jr. Law Office of Harold S. Irwin, III 35 East High Street Suite 2011202 Carlisle, PA 17013 TAMMY L. HALTER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 99 - 5983 CIVIL TERM GLENN E. HALTER,: Defendant : IN DIVORCE FFIDANIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on June 22, 1999 and reinstated on October 19, 1999. 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. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 1 verify that the statements made in this affidavit are true and correct. 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. 5- q- 2000 IV7, GLENN E. HALTER m ?? r uin _ LLti Y_ ,' CI C-1 U TAMMY L. HALTER Plaintiff V. GLENN E. HALTER,: Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 - 5983 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on June 22, 1999 and reinstated on October 19, 1999. 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. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 1 verify that the statements made in this affidavit are true and correct. 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. 2000 ==Cl n+.? d TAMMY L. HALTZR 7 .. U _. i _ 3'? t °.. ( a. T O:: ' Y j, ?: ? + c: "L?_I Lr_ L? ?; ..) L) ?? ? TAMMY L. HALTER Plaintiff V. GLENN E. HALTER,: Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY$ PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 - 5983 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. -00 2000 ? (:x }- TAMMY L. HAL LL n '- . > _ u] _ u.. O ? O a CJ TAMMY L. HALTER Plaintiff V. GLENN E. HALTER,: Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99. 5983 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 of divorce without notice. 2. 1 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. 1 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 unsworn falsification to authorities. 2000 GLENN E. HALTER C.' r !n ' ELI :..I 1 r It]_ U- p _l ? • • • . . 6