Loading...
HomeMy WebLinkAbout04-1021DEBORAH J. HALL Plaintiff V. EDWARD H. HALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 'NO. t SgLI : CIVIL ACTION - LAW : 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 DEBORAH J. HALL, Plaintiff EDWARD H. HALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6q- lO,,2.I CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is DEBORAH J. HALL, an adult individual residing at 1287 Smmnitview Court, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is EDWARD H. HALL, an adult individual residing at 4604 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on January 17, 1999 in Cumberland Cotmty, Pennsylvania. 5. There are no minor children bom of this marriage. 6. The parties separated on September 21, 2003. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiffnor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs I through 9, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaimiffrequests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff requests entry ora divorce decree in her favor in accordance the Pennsylvania Divorce Code factors. WHEREFORE, Plaintiff, DEBORAH J. HALL prays this Honorable Court to enter judgment Dated: ,,~/~awarding Plaintiff a decree, 2004in divorce ~//B~um /~ ple-Sullivan,~~ Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 3 DEBORAH J. HALL, Plaintiff EDWARD H. HALL, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. · 2004 DEBORAH J. HALL, Plaintiff EDWARD H. HALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, DEBORAH J. HALL, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. ,2004 Barbara Sumple-Sullivan, Esquire Supreme Cour~ #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBORAH J. HALL, Plaintiff EDWARD H. HALL, Defendant · IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-1021 : CIVIL ACTION - LAW · IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7002 2410 0006 7111 3485, Return Receipt Requested, on the above-named Defendant, Edward J. Hall, on March 12, 2004 at Defendant's last known address: 4604 Brian Road, Mechanicsburg, PA 17055. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification/~c) authorities. Dated: March 15, 2004 ~~~~ // '-'-~~ B a~-~ar~'~S~umple- Sulliva~re f 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff 0070 EXHIBIT "A" Barbara Surnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 q717) 774-1445 DEBORAH J. HALL, Plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAFff) COUNTY, PENNSYLVANIA v. NO. 04- 1021 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on EDWARD H. HALL, Defendant March 9, 2004. 2. The marriage of the Plaintiff.and Defendant is in'etrievably broken. Ninety days have elapsed since the 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. 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. DATE: ~/~/~ 5. I verify that the statements made in this affidavit are true and correct. I understand that faise statements are made subject to the penalties of 18 Pa. 2 S A. Section 4904 relating to unsworn falsification to authorities. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBORAH J. HALL, Plaintiff EDWARD H. HALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-1021 : CIVIL ACTION - LAW : 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 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 this 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. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBORAH J. HALL, IN THE COURT OF COMMON PLEAS Plaintiff V. EDWARD H. HALL, Defendant CUMBERLg2qD COUNTY, PENNSYLVANIA NO. 04- 1021 CIVIL ACTION - LAW IN DIVORCE; AFFIDAVIT OF CONSENT A Complaint in Divmce under Section 3301(c) of the Divorce Code was filed on March 9, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce at~er service of notice of intention to request entry of the decree. 4. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Edward H,, Hall Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Strcct New Cumberland, PA 17070 (717) 774-1445 DEBORAH J. HALL, : IN THE COURT OF COMMON PLEAS Plaintiff V. EDWARD H. HALL, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- 1021 : CIVIL ACTION - LAW : 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 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 this 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: ,.~ Lf/r~ ~/~ Edward H. Hall Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBORAH J. HALL, Plaintiff EDWARD H. HALL, Defendant : 1N THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : NO: 04-1021 · CIVIL ACTION - LAW ' IN DIVORCE .PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infom~ation, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail Restricted Delivery on March 12, 2004. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: June 11, 2004; by Defendant: June 11, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c~ June 16, 2004. Date Defendant's Waiver of Notice in Prothonotary: June 16, 2004. Dated: June ~, 2004 ) Divorce.~s filed with Prothonotary: ~~s filed with Barbara Sumpl~- Sullivan, ~squire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for P'laintilT Barbara Sumple-Sullivan. Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBORAH J. HALL, Plaintiff V. EDWARD H. HALL, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: 04-1021 CIVIL ACTION - LAW 1N DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I sexved a true and correct copy of the foregoing Plaimiffs Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: DATED: June [,~, 2004 Timothy J. Colgan, Esquire The Wiley Group 130 W. Church Street, Suite 100 Dillsburg, PA 17019 ~~, Esquire 549 Bridge. Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff 1N THE COURT Of COMIVION PLEAS STATE Of DEBORAH J. HALL, Plaintiff VERSUS Defendant Of CUMBERLAND COUNTY PEN NA. NO. 04-1021 DECREE IN DIVORCE AND NOW, DECREED THAT AND 2004 , IT iS ORDERED AND , 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.