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HomeMy WebLinkAbout03-5928RICHARD B. HAUSCHILDT Plaintiff SHARON FAHRER HAUSCHILDT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :No. CWIL ACTION 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 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, 1 Courthouse Sq., Carlisle, PA 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 RICHARD B. HAUSCHILDT Plaintiff' VS. SHARON FAHRER HAUSCHILDT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. : CIVIL ACTION : IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 3302 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 a list of qualified professionals who provide such services. Accordingly, if you desire counseling, please advise in writing promptly by replying to: Office of the Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCHILDT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. CIVIL ACTION IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE NOW COMES Richard B. Hauschildt, by his attorney, HUGAN[R LAW OFFICES, and respectfully avers the following: 1. The Plaintiff is Richard B. Hanschildt, an adult individual who currently resides at 5248 Strathmore Drive, Mechanicsburg, Pennsylvania 17050. 2. The Defendant is Sharon Fahrer Hauschildt, an adult individual who resides at 5248 Strathmore Drive, Mechanicsburg, Pennsylvania 17050. 3. The Plaintiff and Defendant have been bona fide residents of Cumberland County and this Commonwealth for at least six months prior to the filing of this complaint. 4. Plaintiffand Defendant were married on May 26, 1984 in Dayton, Ohio. 5. The Plaimiff has been advised of the availability of counseling and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 6. There has been no other action of divorce or annulment between the parties in this or any other jurisdiction. 7. The marriage of the parties is irretrievably broken. 8. The parties have lived separate and apart since March 31, 2003. 9. The Defendant is a national of the United States. 10. The Defendant is not in the military service of the armed forces of the United States of America. 11. The Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Richard B. Hauschildt requests that the Court enter an Order divorcing the parties. e et lys bmitte Camp Hill, PA 17011-4824 71%732-8070 Attorney No. 30006 VERIFICATION I, Richard B. Hauschildt, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCHILDT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5928 Civil CIVIL ACTION IN DIVORCE ~ACCEPTANCE OF SERV_ICE Pa_ ..R.C.p. 19_30._4 I accept service of the C.~omvlaint Under Section 3~301(c o~3011~) oft_he Divorcee Code and the N.~otice of Right to Couns_eeling, which were flied of record on November 10, 2003 in the above- captioned matter. Witness RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCH1LDT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLANT) COUNTY, PENNSYLVANIA : : No. 03-5928 Civil : : C1VIL ACTION : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME 54 Pa.C.S. §704 Notice is hereby given that pursuant to the authority granted by 54 Pa.C.S. §704, the Plaintiff in the above matter elects to retake and hereafter use her previous name of SHARON LYNN FAHRER. Currently Known As: ~ ~.~~J°(~~ ~_~ Sharon F~hrer Hausct/ildt To Be Known As: x ~t~o~L~~~ COMMONWEALTH OF PENNSYLVANIA: : SS: COUNTY OF CUMBERLAND : On [ ~- ]-~t~'~,J~. , 2004, before me, a Notary Public:, personally appeared, Sharon Lynn Fahrer, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the forgoing for the purpose therein contained. In witness whereof, I have set my hand and Notarial Seal. NOTARY PUBLIC NOTARIAL SEAL MAP,,,IORIE L. JOHNSON, Notar'j Public Camp Hill Boro., Cumberland County My Commission E!xp~res April 15, 2007 RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCHILDT Defendant : IN THE COU~IT OF CO/Vl/vlON PLEAS OF : CUMBERLAI,/D COUNTY, PENNSYLVANIA : : No. 03-5928 Civil : : CIVIL ACTION :/2~ DIVORCE .AFFIDAVIT OF CONSENT TO ENTRY OF DIVORCE DECREi ,; 1. A Complaint in Divorce under § 3301(c) of the the iDivorce code was filed on November 10, 2003. 2. The marriage of Plaintiffand Defendant is irretrievably broken and more than n/neW days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ora final decree of divorce after service of notice of intention to request entry of the decree. 4. In addition, I specifically acknowledge that a full and[ final settlement of al! property and other rights of the part/es has been entered between the Plaintiffand Defendant by written agreement dated May 2, 2004. I verify that the statements made in the 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. RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCHILDT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5928 Civil CIVIL ACTION : IN DIVORCE .WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DWORCE DECREe,; J-/NDER § 3301(c) AND § 3301(d) OF THE DIVORCE COD~; 1. I c°nsent t° 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 ifI 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 the 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: RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCH/LDT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-5928 Civil : : CIVIL ACTION : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECR ~;I ~; UNDER { 3301(c) AND § 3301(d) OF THE DIVORCE CODE 1. I consent tothe entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, d/vision of property, lawyer's fees or expenses ifI 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 mediately after it is filed with the prothonotary. I verify that the statements made in the 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: R/CHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCHILDT Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5928 Civil CIVIL ACTION[ : IN DWORCE AFFIDAVIT OF CONSENT TO ENTRY OF DIVORCE DECREi ,; 1. A Complaint in Divorce trader § 3301(c) of the the Divorce code was filed on November i 0, 2003. 2. The marriage of Plaintiffand Defendant is irretrievably broken and more than ninety 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. 4. In addition, I specifically acknowledge that a full and final settlement of all property and other rights of the parties has been entered between the Plaintiff and Defendant by written agreement dated May 2, 2004. I verify that the statements made in the 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. RICHARD B. HAUSCHILDT Plaintiff VS. SHARON FAHRER HAUSCHILDT Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5928 Civil : CIVIL ACTION[ : IN DIVORCE Date: _PRAECIPE TO TRANSMIT THE 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: irretrievable breakdown under g; 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Nove~nber 18, 2003, by Defendant's execution of an Acceptance of Service pursuant to Pa.R.C.P. 1930.4. 3. Dates of execution of the Affidavit of Consent to Enllry of Divorce Decree required by § 3301 (c) of the Divorce Code: a. Plaintiff: May 24, 2004 h. Defendant: May 17, 2004 4. Related claims pending: None. On May 2, 2004, the parties executed a marital settlement agreement. 5. Dates of filing Waivers of Notice with the Prothonotary: a. Plaintiff: May 24, 2004 b. Defendant: May24,2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. RICHARD B. HAUSCHILDT VERSUS SHARON FAHRER HAUSCHILDT DECREED THAT AND DECREE lin DIVORCE AND NOW,,__~ e~l'~I~ Richard B. Hauschildt Sharon Fahrer Hauschildt , PLAINTIFF, ,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 o ATTEST: j. PROTHONOTARY + + 4- + + +4- + +++ +4-++ ++++++++++ ++++++++++++++++++++++++++++++++