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HomeMy WebLinkAbout01-4715KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, Plaintiff KRISTEN M. HILDEBRANDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - 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 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, Hanover & High Streets, 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, : Plaintiff : : v. : : KRISTEN M. HILDEBRANDT, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - DIVORCE COMPLAINT IN DIVORCE Request for a No-fault Divorce Under §3301(d) of the Domestic Relations Code 1. Plaintiff is DONALD individual with a mailing address of Fayette County, PA 15440. 2. Defendant is KRISTEN individual residing at 210 Senate Hill, Cumberland County, PA 17011. 3. Defendant has Commonwealth for at least six the filing of this Complaint. P. HILDEBRANDT, an adult P.O. Box 130, Gibbon Glade, M. HILDEBRANDT, an adult Avenue, Apartment #418, Camp been a bona fide resident in the (6) months immediately previous to 4. The Plaintiff and Defendant were married on May 31, 1997 in Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties. 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. There are no minor children born of the marriage. 9. Plaintiff and Defendant have been living separate and apart since January 9, 1999. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to S 3301(d) of the Domestic Relations Code. DATED: 8/8/01 K LEWIS, ESQUIRE Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 8/8/01 ~ KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, : Plaintiff : : v. : : KRISTEN M. HILDEBRANDT, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL LAW - DIVORCE AFFIDAVIT OF NON-MILITARY SERVICR COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF CUMBERLAND : Plaintiff avers that Defendant is not in the Military Service or in any branch of the armed forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 8/8/01 KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DONALD P. HILDEBRANDT, : Plaintiff : KRISTEN M. HILDEBRANDT, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL LAW - DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated and have continued to live separate and apart least two years. on January 9, 1999 for a period of at 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. Section 4904, relating to unsworn falsification to authorities. Dated: 8/8/01 ~ DONALD P.~I~DEB~ Donald P. Hildebrandt, Kristen M. Hildebrandt, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND CO., PENNSYLVANIA : : NO. 01-4715 : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF ELECTION TO RESUME MAIDEN NAME Notice is hereby given that a final decree in divorce being granted, hereby elects to resume her prior name of Kristen M. Rovito, and gives this written notice of her intention in accordance with the provisions of 54 Pa.C.S. Section 704. K?isten M. Hildebrandt to be known as Kr~sten M. Rovito COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF ~.o.~[~' : On the [(}/4~ day of -~~ ,2001, before me, a Notary Public, personally appeared Kristen M. Hlldebrandt, t/b/k/a Kristen M. Rovito, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Public Notarial Seal Deborah L. Branneman, Notary Public Camp Hill Bom, Cumberland County My Commission Expires June 18, 2002 Member, Pennsylvania Association of Notaries