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Home My WebLink About07-4583Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) BARBARA A. HALL, Plaintiff vs. WILLIAM A. HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 _ ~~~~ CIVIL TERM IN DIVORCE 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 against 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 with 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 the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 BY An rew C. Sheely, E e PA. I.D. No. 6246 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) BARBARA A. HALL, Plaintiff vs. WILLIAM A. HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW p7 - CIVIL TERM IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned actin in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) BARBARA A. HALL, Plaintiff vs. WILLIAM A. HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 _ 'yS ~'~~ CIVIL TERM IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is BARBARA A. HALL, an adult individual who currently resides at 10 Cottage Ct., Mechanicsburg, Pennsylvania, Cumberland County, Pennsylvania. 2. Defendant is WILLIAM A. HALL, an adult individual who resided at 10 Cottage Ct., Mechanicsburg, Cumberland County, Pennsylvania and who recently moved to 13358 Glissans Mill Road, Mt. Airy, Maryland, 21771. 3. Plaintiff and Defendant were residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 8, 2001 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about June 21, 2007. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT 2 - DIVORCE - FAULT GROUNDS 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 14. Plaintiff avers that she is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render her condition intolerable, life burdensome, unhealthy and impossible for a meaningful relationship or reconciliation. WHEREFORE, Plaintiff requests your Honorable Court to enter a 2 decree in divorce divorcing Plaintiff and Defendant absolutely pursuant to Section 3301(a)(6) of the Divorce Code. COUNT 3 - DIVORCE - 3301(d) 15. Paragraphs 1 - 14 are incorporated herein as if set forth at length. 16. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. COUNT 4 - DIVORCE - EQUITABLE DISTRIBUTION 17. Paragraphs 1 - 16 are incorporated herein as if set forth at length. 18. Plaintiff and Defendant are the owners of various personal property, motor vehicles, bank accounts, retirement accounts, retirement assets and insurance policies acquired during their marriage. 19. Plaintiff and Defendant are the owners of real property acquired during their marriage. 20. Plaintiff and Defendant have acquired various marital debt during the period of their marriage. 3 21. Defendant has incurred marital debt unlawfully and fraudulently during the course of marriage. WHEREFORE, Plaintiff requests your Honorable Court equitably distribute the parties marital property, including marital debt, and including any such further relief as the Court may determine equitable and just. Date: August ~ 2007 Respectfully submitted, C~c/V \. Andrew C. Sheely, Esquire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 4 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: August / , 2007 Bar ara A. Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) BARBARA A. HALL, Plaintiff vs. WILLIAM A. HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 _ CIVIL TERM IN DIVORCE AFFIDAVIT Barbara A. Hall, 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) 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.A. Section 4904 relating to unsworn falsification to authorities. ar ara A. H 1 W ~` '6 (`G\~.j\J~' ~ ° -fin ~1 ~1t.1.~ ZA '1T' ~ ~ ~ ~ -... # ~- Gf ~ j_ N ~ r 7 . t_ y> ~ ~ q, ~ ~- -~ c_,, ~ ~ ~, r ;~- `^, ~ ~~ 4 ~ .__I W -! Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID No. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) BARBARA A. HALL, Plaintiff vs. WILLIAM A. HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 4583 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, H. Anthony Adams, Esquire, hereby accept service of the divorce complaint on behalf of William A. Hall, Defendant, and further certify that I am authorized to do so in accordance with PA. R.C.P No. 402 (b). Date: August ~, 2007 _-__--. H. Anthony Adams, Esquire 49 West Orange Street Suite 3 Shippensburg, PA 17257 717-532-3270 ~ ~. t'' o 0 -r1 ~ -~~~ ~.~ --r, _ ~, Cif .. ~ '"'C BARBARA A. HALL, Plaintiff vs. WILLIAM A. HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 - 4583 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 3301(c) 2. Date and manner of service of the complaint: Acceptance by Attorney for Defendant on August 3, 2007. 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit required by 3301(c) of the Divorce Code: by plaintiff 01/07/08; by defendant 01/03/08. b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code N/A (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: b. Date of plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 01/07/08 Date defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 01107108 Andrew C. Sheely, Esquire Attorney for Plaintiff 127 South Market Street Mechanicsburg, PA 17055 (717) 697-7050 .. -~t rt~;• ~r -rs r '_ _~ , ~ " , ' ~ .,~ ~ ~ N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~'~ PENNA. ~ _: ~. BARBARA A. HALL ~~` ii Plaintiff VERSUS WILLIAM A. HALL Defendant DECREE IN DIVORCE ~ a~ ~ ~~M ` AND NOW, ~~ ~+ 2008 IT IS ORDERED AND DECREED THAT BARBARA A. HALL PLAINTIFF, WILLIAM A. HALL AND 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. All resolved by January 3, 2008 Post Nuptial and Property Settlement Agreement. PROTHONOTARY NO. 07 - 4583 _, ~ . _ ,__