The URL can be used to link to this page

Home My WebLink About08-2228DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SARAH HITE : NO. 01 - A V 0 CIVIL TERM 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 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 1 .. DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SARAH HITE : NO. OP 2a- CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Danny Hite, Jr. who currently resides at 1521 Baltimore Road, Dillsburg, PA 17019, York County, Pennsylvania, since March 2008. 2. Defendant is Sarah Hite who currently resides at 628 Woodland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, since November 2006. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 18, 1997, at Clarksville, Tennessee. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. -ft 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. Date: ? ;-0 ` 0 D y Hite, Jr. Plaintiff ANDREWS & JOHNSON By: Ronald E. J Attorneys for JKaintif 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 . 4- *8 J J °C eli ti O m T7 .? aF CIA r y tf` ! M ? -IT' m _,. ?- CD ?ft DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SARAH HITE : NO. 08-2228 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this day of April 2008, I, Ronald E. Johnson, Esquire, attorney for Danny Hite, Jr., Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at her residence at 628 Woodland Avenue, Mt. Holly Springs, PA 17065 by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on April 11, 2008, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: Sworn and subscribed to before me this /'7 041 day of April 2008. Nbtarv Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SHELLY SEXTON, Notary Public Carlisle Boro, CumbWoW County Commission E)Orn 26, 2011 1 .. .:? ..?E?. _? f '. ¦ Complete Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Prinj your name and address on the reverse so facet we can return the card to you. ¦ Attach this card to the back of the mailplece, or on the ?ortt If space permits. 1. ArtloleAdAissed to: Se,. ra 1nl (o2S? Wood lard ?? S e % "Ss, QA 1-1065 xn4ll 6- °t N") C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Mail 13 Express Mail reczEtered ? Return Receipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) V%S 2. Article Number (narrseftmsavtoelabs ?OD? 1490 0001 7953 7800 PS Form 3811, Febrwry 2004 Dorr»stic Return Receipt 102595-M-*1540 Exhibit A US Postal Service 4/1-7/2008 10:56 PAGE 001/001 Fax server, UNITED ST/]TES POSTAL SERVICE Date: 0411712008 Fax Transmission To: A-J@ PA.NET ANDREWS Fax Number: 717-243-0061 Dear: A-J@PA.NET ANDREWS: The following is in response to your 0417/2008 request for delivery information on your Certified item number 70071490 0001 7953 7800. The delivery record shows that this item was delivered on 04111/2008 at 02:00 PM in MOUNT HOLLY SPRINGS, PA 17065. The scanned image of the recipient information is provided below. Signature of Recipient'( ?j nrd a Address of Recipient: y Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely United States Postal Service CO r ri M DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SARAH HITE : NO. 08-2228 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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: 7 " ) L, _ ? I Danny rte, Jr., plaintiff C? J -n rn i N DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH HITE Defendant : CIVIL ACTION - LAW NO. 08-2228 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to 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 if I 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 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 unworn falsification to authorities. Date: - 0? V Danny ite, Jr., Plaintiff r?j ca C s N DANNY HITE, 3R. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH HITE Defendant CIVIL ACTION - LAW NO. 08-2228 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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: Sarah Hite, Defendant r+a M{ _ t om. 71 c,? DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SARAH HITE Defendant CIVIL ACTION - LAW NO. 08-2228 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to 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 if I 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 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: R Sarah Hite, Defendant r ?- ... , ,. Nil k.. ?.7 7 _ DANNY HITE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SARAH HITE : NO. 08-2228 CIVIL TERM Defendant : IN DIVORCE 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: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: April 11, 2008 by restricted, certified mail, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff July 12, 2008; by Defendant July 17, 2008. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 712, Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ANDREWS & JOHNSON Date: July-2/ , 2008 Ronald E. J son, Esq. 78 West P et Street Carlisle, P 17013 (717) 243-0123 C ? 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Danny Hite, Jr. Plaintiff NO. 08-2228 VERSUS Sarah Hite Defendant DECREE IN DIVORCE AND NOW, d&4 IT IS ORDERED AND Danny Hite, Jr. DECREED THAT PLAINTIFF, Sarah Hite 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 PROTHONOTARY ?AV f ? ,r,w .i ; ,V- oe6 '5p- ;?z-6