HomeMy WebLinkAbout09-5775In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Noelani T Pantastico ) Term, 2 i14 Cj _
Plaintiff
V.
Case Number - S
Brady Lee Hartley
Defendant
Notice to Defend and Claim Rights
TO: Brady Lee Hartley
You have been sued in Court. If you wish to defend against the claim 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
child(ren).
When the grounds for divorce are 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 LMA12 4#,ru1 Couk? Arcs in ?C d istc , Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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:
Lawyer Referral Service (enter address below):
Phone:
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los
proximos veinte (20) dial despues de la notificacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte
por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por
la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos
importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE
QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE
OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE
CALIFICAN.
Lawyer Referral Service (enter address below):
---
Phone
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 seventy-two (72) hours prior to
any hearing or business before the Court. You must attend the scheduled conference of hearing.
Date:
Prin Na a (Plain '
Tom,
Si a re (Plaintiff)
Mailing Address: 141 Shatto Drive, Carlisle, PA, 17013
Phone: 717-249-6006
In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Noelani T Pantastico ) Term, 2
Plaintiff
V.
Case Number O i - S 7 Tr
Brody Lee Hartley
Defendant
Complaint for Divorce
COUNTI
REQUEST FOR DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. Plaintiff is Noelani T Pantastico, who currently resides at 141 Shatto Drive, Carlisle, PA,
17013
2. Defendant is Brady Lee Hartley, who currently resides at 2635 13th Street, Moline, IL, 61265
3. Noelani T Pantastico (the Plaintiff) has been a bona fide resident of the Commonwealth of
Pennsylvania for a period of more than six(6) months immediatley preceding the filing of this
Complaint.
4. The parties were married on July 8, 2005 in the city of Honolulu, in the state of Hawaii.
Attached hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage.
5. The Plaintiff is not currently pregnant.
6. There are no minor children born or legally adopted of the marriage.
7. Military Status:
The Plaintiff is is not in the military or naval service of the United States or its allies within the
provisions of the Soldier's and Sailors' Civil Relief Act of the Congress of 1940 and its
amendments.
The Defendant is not in the military or naval service of the United States or its allies within the
provisions of the Soldier's and Sailors' Civil Relief Act of the Congress of 1940 and its
amendments.
8. There have been no prior actions for divorce or annulment between the parties.
9. There are no protective orders between the Plaintiff and Defendant.
10. The Defendant has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in Counseling.
11. The marriage of the parties is irretrievable broken.
12. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to
file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an
affidavit.
WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed
from the date of the filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be
entered pursuant to Section 3301(c) of the Divorce code dissolving the marriage between Plaintiff and
Defendant.
COUNT II
REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT
AGREEMENT PUSUANT TO SECTION 3104(A)(1) AND (3) AND 3323(B)
OF THE DIVORCE CODE
13. Paragraphs 1 through 12 are incorporated herein and made part hereof by reference as though
fully set forth.
14. Plaintiff and Defendant have reached an agreement on issues including, but not limited to the
following;
Property and Debt, Retirement Accounts, Spousal Maintenance, Health Insurance, and Tax
Filings.
WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate a signed
Marital Settlement Agreement reached between Plaintiff and Defendant in the final divorce
decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code.
Furthermore, the Plaintiff requests that the Court order a name change for the Plaintiff and that
the name be changed to: Noelani Tanya Pantastico (maiden/prior name).
Furthermore, the Plaintiff has chosen to act as her own attorney in a pro se fashion, and
understands that she has the legal right to representation by an attorney. She fully understands her
rights and considers the terms of JKe p9ities' agWment to be fair and reasonable.
Plaintiff
VERIFICATION
I verify that the statements made in the Complaint for Divorce are true and correct. I understand
that false statements made herein are subject to penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
4 All
,, L - - - ? 2,
Plaintiff
Date: ,_.
C
Print Name (Plaintiff, Pro Se)
Mailing Address: 141 Shatto Drive, Carlisle, PA, 17013
Phone: 717-249-6006
OF
Pr
'?? rwRY
2009 20
tJrvr
' i NV A
?? ? ?'9-11 ??lG?l6
In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Noelani T Pantastieo
Plaintiff
V.
Defendant
Term, 2 d/
Case Number: '/ - 5-725-
COUNSELING NOTICE (Under PA. R.C.P. Rule
1920A5(a) (1)
The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where
a divorce is sought under any of the following grounds:
Section
3301(a) (6) Indignities
Section 3301 Irretrievable Breakdown
(c) Mutual Consent
Section 3301 Irretrievable Breakdown
(c) Two (2) Year Separation Where the Court Determines 'T'hat There is
a Reasonable Prospect of Reconciliation
A list of qualified professionals is available for inspection in the office of the Appointments Clerk
of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations
Branch of the Family Court of Philadelphia.
2?C?
Date: '(-U, 30
f V d ,.
MA4 Plaintiff) P
Si tur (Plaintiff)
.OTARY
2009 AUG 20 P t4- i 1
In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Noelani T Pantastico
Plaintiff
V.
Defendant
Term, 2 Ql//
Case Number Y/' s77?
COUNSELING NOTICE (Under PA. R.C.P. Rule
1920A5(a) (1)
The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where
a divorce is sought under any of the following grounds:
Section Indignities
3301(a) (6)
Section 3301 Irretrievable Breakdown
(c) Mutual Consent
Section 3301 Irretrievable Breakdown
(c) Two (2) Year Separation Where the Court Determines That There is
a Reasonable Prospect of Reconciliation
A list of qualified professionals is available for inspection in the office of the Appointments Clerk
of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations
Branch of the Family Court of Philadelphia.
Date: AL-^?,-S I II)- _ -Lq
?`aA I?Q r+(e
Print Name (Defendant)
E ?2- -, ??
Signature (Defendant)
THE
2009 AUG 20 PIS i,f: l J
'ITY
In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Noelani T Pantastico ) Term, 2 e
Plaintiff )
V. )
Case Number:_ ?775?
Brady Lee Hartley )
Defendant )
Acceptance of Service
I, Brady Lee Hartley, Defendant in the above-captioned action depose and say that on this date I
hereby accept service of the Complaint in Divorce and Notice to Defend and Claim Rights with Notice
of Availability of Counseling.
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 unworn
falsification to authorities.
Mailing Address: 2635 13th Street, Moline, IL, 61265
Phone: 309-716-5003
OF TFr ??Y
2009 AUG 20 13
01,1,7
Nil