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Home My WebLink About07-2869cJ CHARLENE KAY HAUS, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07480 Civil GARY A. HAUS, : DIVORCE ACTION 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. 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 (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 CHARLENE KAY HAUS, PLAINTIFF V. GARY A. HAUS, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. DIVORCE ACTION COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Charlene Kay Haus, is an adult individual who currently resides at 1112 Granada Lane, Mechanicsburg, PA 17055. 2. Defendant, Gary A. Haus, is an adult individual who currently resides at 1112 Granada Lane, Mechanicsburg, PA 17055. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on February 14, 1999, in Mechanicsburg, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Charlene Kay Haus, urges this Honorable Court to enter a Decree of Divorce. Respectfully sub NEALON GOVEN & PE By: James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Wet a- x ao 6 7 VERIFICATION I, Charlene Kay Haus, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Dated: 41 a4D r- ? Q "C7 fTn 00 - `? b ?- C rv < CHARLENE KAY HAUS, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2869 Civil GARY A. HAUS, DIVORCE ACTION DEFENDANT PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the above captioned matter. qbqm Respectfully su NEALON GOV i By: .C. James G. Nealon, 111, Esquire I . D. #: 46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 bli. d Cati3 -n S CHARLENE KAY HAUS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-2869 CIVIL TERM GARY A. HAUS, CIVIL ACTION -LAW Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Defendant, Gary A. Haus, in the above-captioned matter. RESPECTFULLY SUB IZ-1- tharles Rector„Ksquire (IT # 39121) Law Offices of Charles Rector, Esquire, P.C. 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 6 Date: /o ! ,?- ? a •-? M33 ?r .. .....E L? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARGARET E. MATSON, Civil Action - Law Plaintiff, VS. No. 07-3275 CUMBERLAND VALLEY SCHOOL DISTRICT, DR. B. JEAN WALKER, SUPERINTENDENT OF CUMBERLAND VALLEY SCHOOL DISTRICT, AND WATERFORD SQUARE ASSOCIATES, INC., Defendants. JURY TRIAL DEMANDED PRAECIPE TO AMEND PLAINTIFF'S COMPLAINT - AD DAMNUM CLAUSES HEREFORE CLAUSES To the Prothonotary: Please file the attached Stipulations. Respectfully submitted, GRIFFITH, ST CKLER, LERMAN, SOLYMOS & CAL. I S BY: X;A-t Y-? Robert A. Lerman, Esquire #07490 Attorney for Defendant, Cumberland Valley School District 110 South Northern Way York, PA 17402 (717) 757-7602 Date: October 9, 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARGARET E. MATSON, Civil Action - Law Plaintiff, VS. No. 07-3275 CUMBERLAND VALLEY SCHOOL DISTRICT, DR. B. JEAN WALKER, SUPERINTENDENT OF CUMBERLAND VALLEY SCHOOL DISTRICT, AND WATERFORD SQUARE ASSOCIATES, INC., Defendants. JURY TRIAL DEMANDED STIPULATION TO AMEND PLAINTIFF'S COMPLAINT - AD DAMNUM CLAUSES CLAUSES) RE We, Robert A. Lerman, Esquire, George W. Gekas, Esquire and Adam L. Seiferth, Esquire, as counsel for all parties to this litigation, hereby agree to the amendment of Plaintiff's Complaint to reflect that all ad damnum clauses (wherefore clauses) shall read: "an amount in excess of the mandatory arbitration limit in Cumberland County, Pennsylvania". C-LER, LERMAN, & CALKINS BY: Robert A. Lerman, L%quit #07490 Attorney for Defendants, Cumberland Valley School District & Dr. B. Jean Walker, Superintendent of Cumberland Valley School District 110 South Northern Way York, PA 17402 Dated: 10101 George W. Gekas, Esquire Attorney for Plaintiff 1104 Fernwood Avenue, Suite 40t- A01 Camp Hill, PA 17011 Dated: 2 Z0'7 CIPRIANI & WERNER BY: Adam L. Seiferth, Esquire Attorney for Defendant, Waterford Square Associates, Inc. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 Dated: to . 1. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARGARET E. MATSON, Plaintiff, vs. CUMBERLAND VALLEY SCHOOL DISTRICT, DR. B. JEAN WALKER, SUPERINTENDENT OF CUMBERLAND VALLEY SCHOOL DISTRICT, AND WATERFORD SQUARE ASSOCIATES, INC., Defendants. as counsel for all parties to this litigation, hereby agree to the amendment of Plaintiff s Complaint to reflect that all ad damnum clauses (wherefore clauses) shall read: STIPULATION TO AMEND PLAINTIFF'S COYPL U; r -- 'AID CLALShS Civil Action - Law No. 07-3275 JURY TRIAL DEMANDED CLAUSES rVLEREFORE We, Robert A. Lerman, Esquire, George W. Gekas, Esquire and Adam L. Seiferth, Esquire, "an amount in excess of the mandatory arbitration limit in Cumberland County, Pennsylvania". GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: Dated: Robert A. Lerman, Esquire 907490 Attorney for Defendants, Cumberland Valley School District & Dr. B. Jean Walker, Superintendent of Cumberland Valley School District 110 South Northern Way York, PA 17402 George W. Gekas, Esquire Attorney for Plaintiff 1104 Fernwood Avenue, Suite 102 Camp Hill, PA 17011 Dated: CIPRIANI & WERNER 7 09 C?6xx?WL?--, BY: Adam L. Seiferth, E ui e Attorney for Defend nt Waterford Square Associates, Inc. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 Dated: 01 - a 7-acol?' 7 Y 2 1Q / • f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARGARET E. MATSON, Plaintiff, vs. CUMBERLAND VALLEY SCHOOL DISTRICT, DR. B. JEAN WALKER, SUPERINTENDENT OF CUMBERLAND VALLEY SCHOOL DISTRICT, AND WATERFORD SQUARE ASSOCIATES, INC., Defendants. CERTIFICATE OF SERVICE Civil Action - Law No. 07-3275 JURY TRIAL DEMANDED AND NOW, this 9th day of October, 2007, I, Robert A. Lerman, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe to Amend Plaintiffs Complaint - Ad Damnum Clauses (Wherefore Clauses) by United States Mail, addressed to the party or attorney of record as follows: George W. Gekas, Esquire Adam L. Seiferth, Esquire 1104 Femwood Avenue, Suite 102 Cirpiani & Werner Camp Hill, PA 17011 1011 Mumma Road, Suite 201 (Counsel for Plaintiff) Lemoyne, PA 17043 (Counsel for Defendant, Waterford Square Associates, Inc.) GRIFFITH, STR KLER, LERMAN, SOLYMOS & CALK BY: &-t- ' R ert A. Lerman, Esquire #67390 Attorney for Defendant, Cumberland Valley School District 110 South Northern Way York, PA 17402 (717) 757-7602 klr/cumberland-praecipetoamend C Y p V '--? ' p 0 1 t?J N ., CHARLENE KAY HAUS, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-2869 GARY A. HAUS, : DIVORCE ACTION DEFENDANT AFFIDAVIT OF SERVICE I, Tom Walton, do hereby certify, subject to the penalties of 18 Pa. C. S. Section 4904, relating to Unsworn Falsification to Authorities, that I am a competent adult and that on the day of t , 2007, at about Zq 3v o'clock a.m. / p.m., I served true and correct c pies of the following documents in the above-captioned matter. Divorce Complaint filed in the matteror in the manner and form as attached upon the ultimate recipient Gary A. Haus served in the following indicated manner. by personally handing said copies to and leaving same with the said Gary A. Haus at the address below or at by personally handing said copies to and leaving same with the following named adult member at the address below. Tom Walton TO BE FILLED IN BY PERSON ACCEPTING SE VIC Received the h rein described documents on b (Date) Signature: Gary. Haus Address: 1112 Granada Lane Mechanicsburg, Pa 17055 N ? ,..,s ? 3? ? r;_ '' ....?t ' ? -? } - -? ?_ r' t -^.{ ? ..K? .r o CHARLENE KAY HAUS, IN THE COURT OF COMMON PLEA PLAINTIFF CUMBERLAND COUNTY, PENN Nikki V. NO. 07-2869 Civil' tv GARY A. HAUS, :DIVORCE ACTION . 3 r7 DEFENDANT 4? NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE AND AFFIDAVIT OF NON-MILITARY SERVICE 1. The parties to this action separated on May 11, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 4. The Defendant is not presently in the active military service of the United States of America and is not a member of the United States Army, Navy, Marine Corps, Air Force or Coast Guard, nor is the Defendant an officer in the Public Health Service detailed by proper authority with any such service, nor is the Defendant engaged in any active military service or duty with any unit covered by the Soldiers and Sailors Civil Relief Act of 1940, nor has the Defendant enlisted in any military service covered by the act. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penal ' s of 18 Pa. S. § 490 lating to u falsification to authorities. Date: C ?/ - r t harlen ay Ha-us/(P I " tiff) CERTIFICATE OF SERVICE AND NOW, this 29t" day of January, 2010, 1 hereby certify that I have served the foregoing Notice and Affidavit Under Section 3301(d) of the Divorce code and Affidavit of Non-Military Service on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Gary A. Haus 1112 Granada Lane Mechanicsburg, PA 17055 ames Nealon, III CHARLENE KAY HAUS, PLAINTIFF V. GARY A. HAUS, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2869 Civil DIVORCE ACTION NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: Gary A. Haus DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after March 12, 2010, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. C ) ?-,3 . -- f3.7 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 _ CIV. James G. Nealon, III, Esquire CHARLENE KAY HAUS, PLAINTIFF V. GARY A. HAUS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2869 Civil : DIVORCE ACTION COUNTER-AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ( ) (a) I do not oppose the entry of a divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both: ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years ( ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ( ) (a) I do not wish to make any claims for economic relief. 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. ( ) (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me and I shall be unable to thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. GARY A. HAUS NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. CERTIFICATE OF SERVICE AND NOW, this 19th day of Februay, 2010, 1 hereby certify that I have served the foregoing Notice of Intent to Enter Judgment of Divorce and Counter Affidavit of the Divorce code and Affidavit of Non-Military Service on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Gary A. Haus 1112 Granada Lane Mechanicsburg, PA 17055 James G. Nealon, III P! C _ r`F r '? y 2010 MAR 3 u = ?? 10: 4 C CUM ? Y CHARLENE KAY HAUS, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2869 Civil GARY A. HAUS, DIVORCE ACTION DEFENDANT AFFIDVAIT OF SERVICE I, James G. Nealon, III, verify that on the 24th day of March, 2010, 1 served Charles Rector, Esquire, counsel of record for Defendant, with a true and correct copy of the Affidavit Under Section 3301(d) of the Divorce Code, which is attached hereto, by one of the following methods: (CHECK ONE) (X) Service was made by United States Postal Service, first class mail, postage prepaid, on the 24th day of March, 2010. ( ) The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant. Personal service was made at following location and time: on the day of at 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.A. §4904 relating to unsworn falsification to authorities. Date:3ij4S 10 G. Nealon, III d i CHARLENE KAY HAUS, : IN THE COURT OF COMMON PL lf3 M r-11---nr- PLAINTIFF : CUMBERLAND COUNTY, PENNS A NIA T V. NO. 07-2869 Civil c' -v T GARY A. HAUS, : DIVORCE ACTION DEFENDANT NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE AND AFFIDAVIT OF NON-MILITARY SERVICE 1. The parties to this action separated on May 11, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if i do not claim them before a divorce is granted. 4. The Defendant is not presently in the active military service of the United States of America and is not a member of the United States Army, Navy, Marine Corps, Air Force or Coast Guard, nor is the Defendant an officer in the Public Health Service detailed by proper authority with any such service, nor is the Defendant engaged in any active military service or duty with any unit covered by the Soldiers and Sailors Civil Relief Act of 1940, nor has the Defendant enlisted in any military service covered by the act. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penal ' s of 18 Pa. GS. § 490 Iating to u falsification to authorities. Date: ! CJ ( `? harien ay Ha-us/(P I 'tiff) f CERTIFICATE OF SERVICE AND NOW, this 24th day of March, 2010, 1 hereby certify that I have served the foregoing Notice and Affidavit Under Section 3301(d) of the Divorce code and Affidavit of Non-Military Service on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Charles Rector, Esquire 1104 Ferwood Avenue, Suite 203 Camp Hill, PA,47-Q11 mes p.?Nealon, I I I .~ CHARLENE KAY HAUS VS. GARY A. HAUS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 07-2869 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: 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: September 10, 2007 by personal service 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiff ; by defendant b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: January 6, 2010 (2) Date of filing and service of the plaintiff's 3301 (d) affidavit upon the respondent opposing party: Filed on February 2, 2010; served on opposing counsel on May 20, 2010 4. Related claims pending: None, no claims made 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: May 20, 2010 _~ ~ b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the ::'_ M Prothonotary: "'~ ' - Date defendant's Waiver of Notice in 3301 orce was filed with the ,,;~ ~ <~;' ~ Prothonotary: ,..~ F°-~ ._ t. ~ o ..? 1 c~, Ct [°`.~ •~ ~ Attorney for Plaintiff/Defendant ~~3~~~ CHARLENE KAY HAUS, PLAINTIFF v. GARY A. HAUS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-2869 Civil DIVORCE ACTION NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: Gary A. Haus DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file acounter-affidavit to the § 3301(d) affidavit. Therefore, on or after June 12, 2010, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or acounter-affidavit by the above date, the court can enter a final decree in divorce. Acounter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. c z~ ~`~ a ' ~ r ~ ~ _c^ ~ ~, n~ _~,,.,~ t ~ . ... la ~. ~~ n ~~ - +- . ~ r /1 .~.~ .Z'+ ~. •,~ f YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 170"' (717) 249-316E (800) 990-91OE James G. Neaion, III, Esquire . • CHARLENE KAY HAUS, IN THE COURT OF COMMON PLEAS PLAINTIFF ~ :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07-2869 Civil GARY A. HAUS, :DIVORCE ACTION DEFENDANT COUNTER-AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ( ) (a} I do not oppose the entry of a divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both: ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years ( ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ( ) (a) I do not wish to make any claims for economic relief. 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. ( ) (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without ~ further notice to me and I shall be unable to thereafter to file any economic claims. ,- , . . c, ~., _; ~-,u~~, . ~~ l ~i ~ t1 ~i J ~J I .J r+~ ~ l : ~o~o AvU ~ 3 ~~-c~ i~=tea ~ iTti, ~ '~v.. CHARLENE KAY HAUS, IN THE COURT OF COMMON PLEAS PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07-2869 Civil GARY A. HAUS, :DIVORCE ACTION DEFENDANT . AFFIDVAIT OF SERVICE I, James G. Nealon, III, verify that on the 20th day of May, 2010, I served Charles Rector, Esquire, counsel of record for Defendant, with a true and correct copy of the Notice of Intent to Enter Judgment of Divorce, which is attached hereto, by one of the following methods: (CHECK ONE) (X) Service was made by United States Postal Service, first class mail, postage prepaid, on the 20th day of May, 2010. ( )The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant. Personal service was made at following location and time: on the day of at I verify that the statements made in this affidavit true and correct. I understand that false statements herein are made subject to the pe ties f 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ~$ 3 t V James G. Nealon, III . ,. 1 verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unswom falsifications to authorities. GARY A. HAUS NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. IN THE COURT OF COMMON PLEAS OF CHARLENE KAY HAUS :CUMBERLAND COUNTY, PENNSYLVANIA V. ~ ` GARY A. HAUS 07-2869 NO. DIVORCE DECREE AND NOW, a/~ /~~ , ~~ , it is ordered and decreed that CHARLENE KAY HAUS ~ plaintiff, and GARY A. HAUS ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, 8-. ~ ~~ l o N~c~ m~.~ led -~-o -~o itl¢A.~cn Lr~w -~ rrn ~2,ec-l-oc-