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Home My WebLink About09-3227TERRY D. HOLLEN, Plaintiff VS. STEPHANIE A. HOLLEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 31x7 Zvil 7Ervn 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 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 Courthouse, 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. Court Administrator Cumberland County Courthouse 4t' Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 TERRY D. HOLLEN, Plaintiff vs. STEPHANIE A. HOLLEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0,9 3??? Imo,,. : CIVIL ACTION -LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 c or d OF THE DIVORCE CODE 1. Plaintiff is Tent' D. Hollen, an adult individual who resides at 16 Maple Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Stephanie A. Hollen, an adult individual who resides at 5520 Devonshire Road, Dauphin County, Pennsylvania 17112. 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. The plaintiff and defendant were married on November 3, 1995, at Westminster, Maryland. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the court require that the parties participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce 0o H. Rehkamp, Esquire R AND O'CONNELL rth ont Street Harrisburg, PA 17110 (717) 232-4551 Attomey for plaintiff Verification I verify that the statements made in the foregoing Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: 6 TerryD. ollen TERRY D. HOLLEN, Plaintiff vs. STEPHANIE A. HOLLEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Of - 3.2 -2 7 &a 7_ccz.... : CIVIL ACTION -LAW : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty days after this,affidavit has been served on you or the statements will be admitted. Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code 1. The parties to this action have continued to live separate and apart for a period of at least two years, since February 4, 2000. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: 6 d ferry D. llen Fill -f !J ?T tr t.rai l,. 1. r .J',.) End l y $ sse . 50 Pa ATM aic l* 4441 RT* aas 484 Sheriff s Office of Cumberland County R Thomas Kline ~~,~3~tr ct ~~~~gkrr~~ Edward L Schorpp Sheriff ~~ Solicitor ~b; Ronny R Anderson ~ ~° . '""' Jody S Smith Chief Deputy aF~icE car T'ra~ s+~rti~~ Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/02/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Stephanie A. Hollen, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 06!10/2009 12:20 PM -Dauphin County Return: And now June 10, 2009 at 1220 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the'' within Complaint in Divorce and Affidavits, upon the within named defendant, to wit: Stephanie A. Hollen by making known unto herself personally, defendant at 5520 Devonshire Road Harrisburg, PA 17112 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.44 June 15, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-3227 Terry Hollen v Stephanie Hollen C') ~ O ~ ° ~,,., , ~ ~ ' ~'., : ~ rfz~ :_ - -corn .~; : i _:aQ _ "r-_ ._ -'n - -H t _ r ~ rr+ ~ ~ Mary Jane Snyder Real Estate Depu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780.6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick sheriff Commonwealth of Pennsylvania County of Dauphin TERRY D HOLLEN VS STEPHANIE A HOLLEN Sheriff s Return No. 2009-T-1565 OTHER COUNTY N0.20093227 And now: JUNE 10, 2009 at 12:20:00 PM served the within COMPLAINT IN DIVORCE & AFFIDAVITS upon STEPHANIE A HOLLEN by personally handing to STEPHANIE A HOLLEN 1 true attested copy of the original COMPLAINT IN DIVORCE & AFFIDAVITS and making known to him/her the contents thereof at 5520 DEVONSHIRE ROAD HBG PA 17112 Sworn and subscribed to before me this 10TH day of June, 2009 ~~~ NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highspire, Dauphin County M Commission Ex ices S t 1 2010 So Anpswers,, l~G!~4r~~C_._ Sheriff of D uphin Coin Pa. By ~'`~+i Deputy Sheriff Deputy: T WONG Sheriffs Costs: $49.25 6/4/2009