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HomeMy WebLinkAbout07-6092HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term BRYAN M. HUNT, : ACTION IN DIVORCE 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. C)7- Civil Term vs. BRYAN M. HUNT, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Plaintiff is Holly A. Hunt, a competent adult individual, who has resided at 320 McCulloch Road, Shippensburg, Cumberland County, Pennsylvania, 17257 since April 2006. 2. Defendant is Bryan M. Hunt, a competent adult individual, who resides at 4 Horse Creek Road, Wilsall, Montana, 59086. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on July 17, 1998 in Hinesville, Georgia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have three children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - CUSTODY 11. Sections 1. - 10. are herein incorporated by reference. 12. The parties are the natural parents of three children, namely, Sunshine A. Hunt (8), born February 14, 1999, Wyatt N. Hunt (3), born May 15, 2004, and Emma J. Hunt (1) , born January 2, 2006. 13. The parties have been unable to enter a custody stipulation in writing. 14. A custody complaint is being filed contemporaneously with this complaint. WHEREFORE, Plaintiff prays this Honorable Court, to enter a custody Order regarding the child. I verify that the statements made in this Complaint 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. unt, P ai tiff Respectfully submitted, Date: 16,11'k,1107 Q Adams, Esquire n-e, 4. o. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF c'1 r? ? V ? V _° tyA ) N c--? --r cn co ? f C7 HOLLY A. HUNT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. C>? - 1.09P-,., Civil Term BRYAN M. HUNT, ACTION IN DIVORCE Defendant CUSTODY COMPLAINT 1. Plaintiff is Holly A. Hunt, who currently resides at 320 McCulloch Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant is Bryan M. Hunt, who currently resides at 4 Horse Creek Road, Wilsall, Montana, 59086. 3. Plaintiff is the Mother of the following children and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Sunshine A. Hunt 2/14/99 (8) 320 McCulloch Rd. Shippensburg, Pa. Wyatt N. Hunt 5/15/04(3) 320 McCulloch Rd. Shippensburg, Pa. Emma J. Hunt 1/2/06(l) 320 McCulloch Rd. Shippensburg, Pa. Mother and Father married on July 17, 1998. A divorce complaint has been filed under the above-captioned docket number contemporaneously with this custody complaint. Mother currently has primary physical custody of the children. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Holly A. Hunt Lucinda and Joseph Ross (maternal grandparents) Holly A. Hunt Bryan M Hunt 320 McCulloch Rd. Shippensburg, Pa. 17257 32 Leap Lane Belgrade, MT 59614 April 2006 - present 2002 - March 2006 rRVE COPY FROM RECORD f Testhnony whereof, I hens unto sat my trend $1 the ass Of said cou at lisps, P& thonotary k The mother of the children is Holly A. Hunt. She currently resides at 320 McCulloch Rd. Shippensburg, Pa. She is married to Bryan M. Hunt. The father of the children is Bryan M. Hunt. He currently resides at 4 Horse Creek Road, Wilsall, Montana. He is married to Holly A. Hunt. 4. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides with the children and maternal grandparents, Lucinda and Joseph Ross. 5. The relationship of defendant to the children is that of Father. The defendant currently lives with a roommate. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or anyone who claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties separated in November 2005. Since separation Mother has maintained primary custody of the children. She has resided in Cumberland County since April 2006 and Father has remained in Montana. Mother is requesting a custody order which would confirm that she has primary physical custody, would provide for shared legal custody, and periods of partial custody for Father as the parties agree. Mother believes that such an order would be in the best interest of the children because it would provide stability for the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Date: ?0 l t? 6'? Respectfully su,)mitted, ne Adams, Esquire .D. . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint 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: 1? ?? Holly . unt, Plaintiff ?Q Dl -4? Ca 1 (n d Q -r ri r ? I HOLLY A. HUNT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BRYAN M. HUNT DEFENDANT • 2007-6092 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 24, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, November 12, 2007 at 2:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ John[. Mangan, r. Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 cPvkXWW 1. --4- hf 671 W/ fo - J?xt??r _yr k IJ L0-hir o/ 3?U JO HOLLY A. HUNT, Plaintiff vs. BRYAN M. HUNT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 6092 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this November 6, 2007, I, Jane Adams, Esquire, hereby certify that on November 1, 2007, certified true copies of the NOTICE TO DEFEND, COMPLAINT IN DIVORCE, AND CUSTODY COMPLAINT were served upon the following person, via certified mail, return receipt requested at the following address: Bryan M. Hunt 4 Horse Creek Road Wilsall, MT 59086 • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse DEFENDANT so that wefeturn the card to you. ¦ Attach this'caM'to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: BRYAN M. HUNT 44 HORSE CREEK RD WILSALL MT 59086 A. S ,,._. C3 Agent '?4j x ? Addressee B by (fin- tm' D. Is ,ery address d'dferent from item 11 ? Yes If YES, enter delivery address below: ? No D avess Mail g ? Remn Receipt for Merchandise ? Insured Men 0 C.O.D. 2. ArtldeNumber (M 7pp3 2260 000 8703 5452 wafar firom service label) PS Form 3811, February 2004 Domestic Return Receipt 102905-0¢4A-1540 Respectfully Sub itted: Qj ?" , J ne Adams, Esquire I No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF °i -TI rt t" r i l.wJ rQ . '1 NOV 1 32DD7? 4r, HOLLY A. HUNT, Plaintiff V. BRYAN M. HUNT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-6092 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this _? day of November, 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Bryan M. Hunt, and the Mother, Holly A. Hunt, shall have shared legal custody of Sunshine A. Hunt, born 2/14/99, Wyatt N. Hunt, born 5/15/04 and Emma J. Hunt, born 1/02/06. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: Mother shall have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as follows: a. Commencing 2008, between the months of June and August, Father shall have physical custody of the Children for two (2) weeks, with Mother being present in Montana, and if all goes well for the two (2) weeks, Father shall have an additional two (2) weeks consecutive without Mother being present in Montana. Father shall notify Mother of proposed summer dates by April 0 to provide ample time to make arrangements. b. Should Father have the occasion to come to this jurisdiction, Mother shall make all reasonable efforts to facilitate Father's visitation with the Children. c. The parties may alter or expand Father's physical custodial periods upon mutual agreement. 3. Holidays: Commencing 2008, Father shall have physical custody of the Children in all even years for the Christmas holiday, the dates and times by mutual agreement. 4. Transportation: Father and Mother shall share the cost of transportation for Mother and Children to travel to Montana, unless otherwise mutually agreed upon. 5. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Children. 3 0 .y 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consumelbe under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 8. Both parties are directed to provide the other party with information, including household members, addresses and telephone numbers, for the households in which the Children would be staying. 9. Telephone contact: Father shall have regular telephone contact with the Children two times during the work week, on Tuesday and Thursday after 5:00 pm (Eastern Time) and the Children shall call Father after 9:00 am (E.T.) on Saturdays. Mother shall also have reasonable liberal telephone contact with the Children when the Children are in Father's custody. 10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the.Cetfff, J. Distribution: X ?"`e Adams, Esq. jtyan Hunt, 4 Horse Creek Road, J. Mangan, Esq. Wilsall, Montana 59086 V YNVAIASNN?d ? C :8 WV ? I AON LOOT A8VION 1 H.,?(l? , ??d+N? 3Hl Jo HOLLY A. HUNT, Plaintiff V. BRYAN M. HUNT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-6092 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Sunshine A. Hunt 2/14/99 Primary-Mother Wyatt N. Hunt 5/15/04 Primary-Mother Emma J. Hunt 1/02/06 Primary-Mother 2. A Conciliation Conference was held with regard to this matter on November 12, 2007 with the following individuals in attendance: The Mother, Holly A. Hunt, with her counsel, Jane Adams, Esq. The Father, Bryan M. Hunt, pro se appeared via telephone 3. The parties agreed to the entry of an Order in the form as attached. Date HOLLY A. HUNT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6092 Civil Term BRYAN M. HUNT, : ACTION IN DIVORCE 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 OF SEPARATION 1. The parties to this action separated on November 11, 2005, 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 my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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: 4 0 ?'0 0 _ Holl H nt, lainti 11 CC, rr, ITI ; ? { O HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6092 Civil Term BRYAN M. HUNT, : ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE REGARDING THE AFFIDAVIT OF SEPARATION AND NOW, this February 27, 2008, I, Jane Adams, Esquire, hereby certify that on January 25, 2008, a certified true copy of the AFFIDAVIT OF SEPARATION was served upon the following person, via certified mail, return receipt requested at the following address: Bryan M. Hunt 4 Horse Creek Road ' Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. Wllsall MT 59086 • Print your name and address on the reverse , DEFENDANT so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A X B. JELeg&ed by (Prf /?l har"OPF C. Date of Delivery D. Ie Avery address different from item 1? ? Yes If YES, enter delivery address below: ? No ? Agent BRYAN M HUNT 4 HORSE CREEK RD WILSALL MT 59086 3. Service Type )d%WW AY ? Express Mail ? Regiswred ? Return Receipt for Merchandise ? Insured Md ? C.O.D. 4. Redrlclsd DsNwry? Pft Fee) ?. Yes 2. ArticleNMxnber 7907 1490 0001 7952 0086 ( wWw ft m servke label) Ps For, 3811, February 2004 Domestic Return Receipt 102695-02-M-1540 Respectfully Submitted: " a&4?,, ane Adams, Esquire D. No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF C'S ?'v ? '? ? ` ? ? ? '? ?,.1. "T] ? 2 i . 's .;_ (? ? .r r .? HOLLY A. HUNT, Plaintiff vs. BRYAN M. HUNT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 6092 Civil Term ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this April 2, 2008, I, Jane Adams, Esquire, hereby certify that on March 11, 2008, a true copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER AFFIDAVIT was served upon the following person, via certified mail, return receipt requested at the following address: Bryan M. Hunt 4 Horse Creek Road Wilsall, MT 59086 DEFENDANT ¦ Cgn hft home 1, 2, and 3. AYo coin Item 4 if Restricted Delivery Is desired. ¦ Print your dame and address on the reverse so that w4, can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. X ? agent n mein B by (Pd Name) C. Date of Delivery 47P lan 11 %o".Y28 D. Is delivery address different from item 11 ? Yes If YES, enter delivery address below: ? No 3. Service Type U Certified Mail O Express Mali 0 Raptatared a Relurrr Receipt for Merchandise O Mrrred Mefi ? C.O.D. 4. RastricM DeYwryi' 45rbe Fiat E3 Yes 2. Article Number ?00? 1490 0001 ?951 4 016 (lianelier from service label F's .. -m 3811, February 2004 Domestic Return Receipt 10250"2-M-1UO A true copy of said NOTICE AND COUNTER-AFFIDAVIT is attached hereto. Date: Respectfully Submitted: t Adams, Esquire o. 79465 est South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6092 Civil Term BRYAN M. HUNT, ACTION IN DIVORCE Defendant NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Bryan M. Hunt, Defendant Date: February 27, 2008 4 Horsecreek Road Willsall, MT 59086 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, in twenty days, after March 17. 2008 the Plaintiff 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 date above, 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 your counter-affidavit alone does not protect your economic claims. 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 St. Carlisle, Pa. 17013 (717) 249-3166 HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6092 Civil Term BRYAN M. HUNT, ACTION IN DIVORCE Defendant COUNTER-AFFIDAVIT UNDER SECTION 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, and 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 in writing 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 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. §4904 relating to unsworn falsification to authorities. Date: Bryan M. Hunt, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. +?;a ---1 .,.. _ .. -tai ' ; .:U-''? v : _ ,?; ,. ?-- ? W }.`.. ,. __?,: ` C? 7 =i ::? ...?. :'1 .... HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6092 Civil Term BRYAN M. HUNT, ACTION IN DIVORCE Defendant NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Bryan M. Hunt, Defendant Date: February 27, 2008 4 Horsecreek Road Willsall, MT 59086 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, in twenty days, after March 17. 2008 the Plaintiff 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 date above, 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 your counter-affidavit alone does not protect your economic claims. 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 St. Carlisle, Pa. 17013 (717) 249-3166 HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6092 Civil Term BRYAN M. HUNT, : ACTION IN DIVORCE Defendant COUNTER-AFFIDAVIT UNDER SECTION 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 l may lose rights concerning alimony, division of property, lawyer's fees, and 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 in writing 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 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. §4904 relating to unsworn falsification to authorities. Date: Bryan M. Hunt, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. c? ? ?-n, „ { ? ? --, ?? ? ?. a` r'? .. ___j ""' ' ?. r i '-?.' HOLLY A. HUNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07 - 6092 Civil Term BRYAN M. HUNT, : ACTION IN DIVORCE Defendant TO THE PROTHONOTARY: 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 3301 d of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery. return receipt requested, on November 1. 2007. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: January 10. 2008 Date of filing and service of the plaintiffs affidavit of separation required by §3301(d) of the Divorce Code on respondent: Filed: January 11. 2008. Served on Defendant: January 25. 2008. Affidavit of Service filed: February 27. 2008. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary, along with an Affidavit of Service: Served on March 11. 2008, via certified mail. Date: 6 Respectfully Su miffed: Adams, Esquire ?IN0. 794 65 . South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff . ? ? 1=? 3 ? r t;9;7 ?- rv=rr ? ! CnJ ?_. ^,? ' ?.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Holly A. Hunt, Plaintiff' No. 07 - 6092 Civil Term NO. VERSUS Bryan M. Hunt, Defendant DECREE IN DIVORCE d AND NOW, _ P" IT IS ORDERED AND Holly A. Hunt DECREED THAT AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. . PLAINTIFF, DEFENDANT, 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. BYIT'IT-COJL : ATTEST: J. PROTHONOTARY Bryan M. Hunt >?. 2 '?!? ?o d H ?, t '? . °;