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Home My WebLink About08-2845 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com Stanley R. Haubert, Plaintiff V. Julieana R. Haubert, Defendant Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008- A345 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 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 Court House, Carlisle, Pennsylvania. 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 Lawyers Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com Stanley R. Haubert, Plaintiff V. Julieana R. Haubert, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008- PYe CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Stanley R. Haubert who currently resides and has resided at 91 West Main Street, Plainfield, Pennsylvania 17081, since June of 2007. 2. Defendant is Julieana R. Haubert who is believed to have a mailing address of P.O. Box 192, Byrdstowns, TN 38549. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Defendant is believed to be a resident of the State of Tennessee. 4. Plaintiff and Defendant were married on September 4, 1993, in Tennessee. 5. Plaintiff and Defendant separated on or about July 12, 2006, at which time Plaintiff and Defendant resided in the State of North Carolina. 3 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff Peter J. Russo, Esquire ID # 72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: S -`?2 OV 4 Stanley R. Haubert, Plaintiff V. Julieana R. Haubert, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008- CIVIL TERM IN DIVORCE VERIFICATION I, Stanley R. Haubert, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date nley R. ?Haub?ert?? Stanley R. Haubert, Plaintiff V. Julieana R. Haubert, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008- CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: US Regular Mail; and Certified Mail, Restricted Delivery, Return Receipt Requested, and addressed as follows: Julieana R. Haubert P.O. Box 192 Byrdstowns, TN 38549 Date: ? n q) i e Ashley R. e, Parale al 6 r.a 4f? 4 7 .??? t -- r r7 Q f r ? Od OO - .? L s' LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjdaw.com Stanley R. Haubert, Plaintiff V. Julieana R. Haubert, Defendant Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008--29'/J- CIVIL TERM IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Divorce originally filed in the above stated action on May 2, 2008. Law O ices & Peter J. Rus .C. 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Peter J. Russo, Esquire I.D. No. 72897 Elizabeth J. Saylor, Esquire Date: I.D. No. 200139 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjdaw.com Stanley R. Haubert, Plaintiff V. Julieana R. Haubert, Defendant Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 2008- CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the Praecipe to Reinstate Complaint upon the person(s) and in the manner indicated below: Certified Mail Returned Receipt Restricted Delivery to and/or via Personal Service on Julieana R. Haubert P.O. Box 192 Byrdstowns, TN 38549 _ _0 Ashley R pe, Paral gal Date: 71; i J hV-? Q??) \N Q I\, V W C? m -(,A; C. °n STANLEY R. HAUBERT, Plaintiff v. JULIEANA R. HAUBERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-2845 CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Malcolm, formerly known as Ashley R. Sipe, hereby certify That on iviay 2, 2008 i served a true ar~d correct copy of the Coniplair~t u..der Section 3301(c) or 3301(d) of the Divorce Code upon the Defendant, Julieana R. Haubert, by US Regular Mail; and Certified Mail , Restricted Delivery, Retu~'rn ~~ ~' Receipt Requested and addressed as follows: ~'-'a ~ ~ `i ~``~;-:' s ~.e ~ _.,v ~k,: °-wi is 7 Julieana R. Haubert P.O. Box 192 -= ~ ~' ~, Byrdstown, TN 38549 ~~ ;~ , ~.~ ~_ •, The copy of the Complaint sent via Certified Ma il was returned unclaimed; however, the copy of the Complaint sent via US Regular Mail was not returned to the Law Offices of Peter J. Russo, P.C. 1~ Ashley R. alcolm, Paralegal Date: I STANLEY R. HAUBERT, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2008-2845 c-. ~• ~ --, JULIEANA R. HAUBERT, :CIVIL ACTION -LAW ~-`-;ti.~ ~ ~=' Defendant : IN DIVORCE "'~-' '~`~ dry; ,~ i ""' ' ~~ ~~ ''' "Y'I ~~' :_~r) == NOTICE TO THE PLAINTIFF ~ t '~ "= ~ C'~ l ~ ~ t"r'3 ° ~: If you wish to deny any of the statements set forth in this affidavit, yaa ` ; ?~' .~~ must file acounter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE NOTICE 1. The parties to this action separated on July 12, 2006, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: - ~/U Stanley R. Haubert, Plaintiff STANLEY R. HAUBERT, Plaintiff v. JULIEANA R. HAUBERT, Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-2845 CIVIL ACTION -LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (D) OF THE DIVORCE CODE 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. 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 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 claim. A I verify that the statement made in this counter-affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: Julieana R. Haubert, Defendant t 1L L.I`is't= i iC~ Mindy S. Goodman Attorney at Law 2215 Forest Hills Drive Suite 35 Harrisburg, PA 17112 (717) 540-8742 STANLEY R. HAUBERT, Plaintiff v. JULIEANA R. HAUBERT, Defendant .~ ~,_ n, ~~il~' _, C ;~L > IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-2845 CIVIL ACTION -LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, STANELY R. HAUBERT, in the above matter. r -~ ,.. Eli ab t .Saylor, Esquire Supreme Court ID No. 200139 Law Office of Peter J. Russo, P.C. 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 761-7573 PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance for the Plaintiff in the above- captioned matter. Date: ~? ' / ~ _ ~ v \, ~,,~. ~ ~ ~~`~ Mindy S. Goodman, Esquire Supreme Court ID No. 78407 2215 Forest Hills Drive -Suite 35 Harrisburg, PA 17112 (717) 540-8742 OF cU,� David D. Buell e Renee R Simpson 1Prothonotary o ;SGµ, Z 15` Deputy prothonotary �irkS. Sohonage, ESQ �. • Irene E. Morrow Solicitor 1750 2nd Deputy prothonotary Office of the Prothonotary Cum6erland County, Pennsylvania O -zags CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Fax(717)240-6573