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HomeMy WebLinkAbout01-6649 IN THE COURT OF COMMQN PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM HAUSE, * Plaintiff * VS. * THERESE A. HAUSE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU I-LAVE BEEN SUED IN COURT. IF YOM 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 O1~ ANNULMENT MAY BE ENTERED AGAINSJ YOU BY THE COURT. A JUDGMENT MAY ALSO BE ENTERED AGAII~ST YOU FOR ANY OTHER CLAIM OR RELIE REQUESTED IN THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU, INCLUDING CUSTODY OR VISITATION OF YDUR CHILDREN. WHEN THE GROUND FOR THE DIVORCE IS INDIGNITIESi OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST DF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, I COURTHOUSE SQUARE, CARLISLE, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, D1VI~ION 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 A~ 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMO~I PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VSo WILLIAM HAUSE, Plaintiff NO. THERESE A. HAUSE, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVoRcE 1. The Plaintiff is William Hause, who currently resides at 5328 Oxford Circle, Apartment 29, Mechanicsburg, Cumberland County, Pennsylvania 17055 sincei December 15, 2000. 2. The Defendant is Therese A. Hause who currently resides at 20 Colony Street, EXT. Seymour, Connecticut 06483 since February, 2001. , resident in the CommoOwealth for at least six months immediately 3. Plaintiff has been a bona fide previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February !14, 1987 at Newton, Sussex County, New Jersey. 5. There are two minor children of the parties: Williand Thomas Hause, date of birth: January 22, 1990; and Brittany Elizabeth Hause, date of birth; April 31, 19~3. 6. There have been no prior actions of divorce or annul 7. Neither party is presently a member of the Armed F, 8. The parties have not entered into a written agreem nent between the parties. ~rces on active duty. ~nt as to alimony, counsel fees, costs, and property division. 9. Plaintiffhas been advised that counseling is avmqable and ~flaat plaintiff may have the r¥,ht to request that the ex)ua require the parties to participate in eoanseling. Be:a~g so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. The cause of action and sections of Divorce Code under which plaintiff is proceeding is: (a) §3301(e). The marriage ofthe parties is irretrievably broken. 11. Plaintiffrequests the court to enter a decree of divorce. WHEREFORE, the Plainfiffrequests the Court enter an Order dissolving the marriage between the Plaintiff and Defendant. Dated: Respectfully submitted, WILEY, ~ENOX, COLGAN & MARZZACCO, P.C. 1 South l~alth~ore Street Dillsburg, PA 17019 (717) 432~9666 I.D. # 82204 VERIFICATION I, WILLIAM HAUSE, verify that the statemems made in this document are hue and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §490k~, relating to unswom falsification to authorities. Date: WILLIAM HAUSE, Plaintiff VS. THERESE A. HAUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL No: 01-6649 : CIVIL ACTION - LAW : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 28, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. I verify that the statements made in this Affidavit are tree 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: Therese A. Hause WILLIAM HAUSE, Plaintiff VS. THERESE A. HAUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL No: 01-6649 : 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 if I 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 statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Therese A. Hause IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM HAUSE, Plaintiff VS. THERESE A. HAUSE, Defendant NO. 01-6649 CIVIL ACTION - LAW IN DIVORCE INDEMNIFICATION AGREEMENT THIS AGREEMENT made this [ t]~ day o~2 is by and between: WILLIAM HAUSE of 5328 Oxford Circle, Apathnent 29, Mechanicsburg, Cumberland County, Pennsylvania; and THERESE A. HAUSE of 20 Colony Street, Ext., Seymour, Connecticut. WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been married on February 14, 1987; and WHEREAS, the parties hereto, wife being represented by Taylor P. Andrews, Esquire and husband by Christine J. Taylor, Esquire, have exchanged full and complete information as to the property, assets and liabilities owned and owned by each, and have disclosed to each other and to their respective attorneys full information as to the financial status of both parties hereto; and WHEREAS, the parties hereto have mutually entered into an agreement for the provision for the liabilities they owe after both parties have had full and ample opportunity to consult with their respective attomeys, and the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the mutually made and to be kept promises set forth hereinafter, and for other good and valuable considerations, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: 1. The parties agree that the Capital One credit card shall be closed upon payment of the outstanding balance of approximately $499.27. 2. The parties recognize that the credit card is currently held in the names of both parties, but is in the possession of Therese A. Hause. 3. Husband agrees to pay Wife $250.00 towards the remaining balance of the Capital One credit card, whose account number is 4121741364893466. 4. In consideration of such payment from Husband to Wife, Wife agrees to satisfy the remaining balance on the credii card and close such account. 5. Upon closing said ac'count, Wife agrees to provide proof of such closing to Husband. 6. Upon payment of the $250.00 by Husband to Wife, Wife shall hereafter indemnify Husband as to any responsibilities concerning the Capital One account and shall indemnify him as to any collection efforts regarding said account, either through bankruptcy or otherwise. 7. By Wife's signing this Agreement, she acknowledges receipt of the $250.00 payment from Husband. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year firstabove written. William Hause Therese A. Haus~ ' - m~~ ° o IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM HAUSE, Plaintiff VS. THERESE A. HAUSE, Defendant NO. 01-6649 CIVIL ACTION - LAW IN DIVORCE 2001. AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on November 28, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. I verify that the statements made in this affidavit are tree and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date WILLIAM HAUSE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM HAUSE, Plaintiff VS. THERESE A. HAUSE, Defendant NO. 01-6649 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c] OF THE DIVORCE CODE 1. ! 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 statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date WILLIAM HAUSE Plaintiff NOV--19-2002 0~ :54 PM ~CT ~g' ~00~ 3:B4PM ANDREWS~JOHNSO.N '71724~8061 HP LRSERJ~T ~00 P.O~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, pENNSYLVANIA WILLIAM It~USE, ¥S, '[HERESE A. HAUSE, Defendant NO. Ol-66a9 CIVIL ACTION - LAW IN DIVORCE ACCElgr~k.~CE OF SIERVICE I, Therese Itau~, Defendant in t~v above-captior~ecl ra~er, hereby oerti~ L,hat oil or aboul De~ember ~. 2001, I re~eiYed · aue a~ct oorrecl copy of Plaintiff's Complaint for Divorce in abov¢-caption~ matter, which service satisfies the requirement of I~a.R.C.P. 1930.4(h). TRERESB HAUSE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM HAUSE, Plaintiff VS. THERESE A. HAUSE, Defendant NO. 01-6649 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit thc record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c). Date and manner of service of the Complaint: i' re ular U.. Mail n or about December 5 2001. An Acce tance of Service s' ned b Defendant was filed with the court on December 17 2002. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: September 26~ 2002; By Defendant: September 9, 2002. (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice oflnt.ention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Filed October 15, 2002. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Filed September 30, 2002. Date: Christine J. Taylor, ]~uire v ~ - Attorney for Plaintiff fJ Atty ID No. 88204 Wiley, Lenox, Colgan & Marzzacco, P.C. 1 S. Baltimore Street Dillsburg, PA 17019 (717) 432-9666 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. WILLIAM HAUSE ............................................. Versus THERESE A. HAUSE N o .... .°..!..-...6.P..4...9. ..................... 19 ECR EE lIEN IVORC AND NOW, ~-~.~.~.~ :-~.. i~ ........... ~19 Zg?.".~. it is ordered and William Hause , plaintiff, decreed that ................................................. Therese A. Hause defendant, and ......................................................... ' 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., ....................................