HomeMy WebLinkAbout09-2862John C. Howett, Jr., Esquire
HOWETT, KISSINGER & HOLST, P.C.
130 Walnut Street, P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Kristen E. Hashkowitz
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KRISTEN E. HASHKOWITZ,
Plaintiff )
V. ) NO. 2009- oZR&A _ CIVIL TERM
BRIAN A. HASHKOWITZ, ) CIVIL ACTION - LAW
Defendant ) 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 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 Square, Carlisle, Pennsylvania
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
Telephone: (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
4.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KRISTEN E. HASHKOWITZ, )
Plaintiff )
V. )
BRIAN A. HASHKOWITZ, )
Defendant )
NO. 2009- CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Kristen E. Hashkowitz, by and through her counsel, Howett,
Kissinger & Holst, P.C., who states the following in support of the within Complaint:
1. Plaintiff is Kristen E. Hashkowitz, an adult individual who currently
resides at 6348 South Powderhorn Road, Mechanicsburg, Cumberland County, Pennsylvania,
17050.
2. Defendant is Brian A. Hashkowitz, an adult individual who currently
resides at 168 Gloucester Terrace, Ground Floor Flat, W2 6HR, London, England, United
Kingdom.
3. Plaintiff has been a bona fide resident in the Commonwealth of
Pennsylvania for a period of at least six months immediately preceding the filing of this
Complaint.
4. Plaintiff and Defendant were married on October 27, 2007 in Cumberland
County, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the
United States or its allies within the provisions of the Servicemembers Civil Relief Act.
4
6. There have been no prior actions for divorce or annulment of the marriage
instituted by either of the parties in this or any other jurisdiction.
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. The marriage of the parties is irretrievably broken.
9. The parties have lived separate and apart since on or about January 3,
2009.
10. Plaintiff requests the court to enter a decree of divorce.
Date: C-14 /'o
Respect lly submitted,
e ?
Jo C. Howett, Jr., Esquire
HOWETT, KISSINGER & HOLST, P.C.
130 Walnut Street, P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Kristen E. Hashkowitz
N
VERIFICATION
I, Kristen E. Hashkowitz, hereby swear and affirm that the facts contained in the
foregoing COMPLAINT IN DIVORCE are
true and correct to the best of my knowledge, information and belief and are made subject to the
penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
Date: 5/6/09 21 44eG 'C? J, •
STEN E.14ASHKOWITZ
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OF THE PROTHOAnTAAY
2009 MAY -7 PM 1:07
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KRISTEN E. HASHKOWITZ,
Plaintiff
V.
BRIAN A. HASHKOWITZ,
Defendant
NO. 2009-2862 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO REINSTATE COMPLAINT IN DIVORCE
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce filed with this Court on May 7, 2009.
Respectfully submitted,
Dater q
John C. H weft, Jr., Lsquire
HOW , KISSING ER & OLST, C.
130 Walnut Street, P.O. Box 81
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Kristen E. Hashkowitz
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