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HomeMy WebLinkAbout09-7415KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff COURTNEY RITCHIE, Plaintiff V. TODD HOSTERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CA - 11415 O ivt ( Germ CIVIL LAW 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 at: 1 Courthouse Square, Carlisle, PA 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 A KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff COURTNEY RITCHIE, Plaintiff V. TODD HOSTERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- CIVIL LAW DIVORCE COMPLAINT FOR DIVORCE COUNT I Request for a No-fault Divorce Under 63301(c) of the Domestic Relations Code 1. Plaintiff is Courtney Ritchie, who currently resides at 87 Leeann Court, Enola, Cumberland County, PA 17025. 2. Defendant is Todd Hosterman, who currently resides at 2022 Market St., Apt. #1, Camp Hill, PA 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 14, 2008 in Barbados. 5. There have been no prior actions for divorce or for annulment between the parties. . .. 6. The marriage is irretrievably broken. 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 Defendant is not a member of the armed services. 9. There are no minor children borne of the marriage. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to S 3301(c) of the Domestic Relations Code. COUNT II Reauest for a Fault Divorce under S 3301(a) of the Domestic Relations Code 10. Plaintiff hereby incorporates paragraphs 1 through 9 of her divorce Complaint as if fully set forth herein. 11. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests this court to enter a Decree of Divorce pursuant to S 3301(a) of the Domestic Relations Code. DATE : I dlulo j / L- KENN#TH . LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff f ' . • VERIFICATION I hereby verify that the statements made in the foregoing document are true 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. Section 4904, relating to unsworn falsification to authorities. Dated: IL?;aLo 2,,(e Odo? COURTNEY R CHIE FUD-OFFICE OF THE PI?CTH' WARY 2009 OCT 28 PM 12: 54 Cuklhv`i ?...'-,UN? t f EININSJAYANA *&-ss.5o po Airy co 199.0 P-T* a3&(A( o KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff COURTNEY RITCHIE, Plaintiff v. TODD HOSTERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7415 Civil Term CIVIL LAW DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. DATE : 1 ~ ~ t ~~ ~-~-~ TODD HOSTE 2022 Market St., Apt. #1 Camp Hill, PA 17011 .,.r- T~ - ;= ~~r~~~~Y L~'~`Q `~~~~ t ~ r''.s' #J~ ~ i ~~ ~, ~,4C J 4N;~ ..... _ _ M i y .(... U~ ~!-;~ f'~OT~~l~T;~~Y ZOlfl E~~R - i Fri 2~ 26 CUPvi~;.-r,~,H,~Y~ ~.luIVTY COURTNEY RITC;~++~~~~~~~~ Plain i v. TODD HOSTERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7415 Civil Term CIVIL LAW DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section (X) 3301(c~ () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service dated 11/4/09 and filed 11/10/09. 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on 2J15/10; by the Defendant on 2/21/10; all filed concurrent with this Praecipe. 4. Related claims pending: NONE, no economic relief requested. DATED: 2/26/10 ~ KEN ETH F. LEWIS, ESQ. Att rn I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff OF ?~ {C~p~ ~ ~~;~T ~~ ZOfO MAR -1 PM ~; 26 ~ENtV~S~~LV~Nt~ ~ COURTNEY RITCHIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-7415 Civil Term TODD HOSTERMAN, CIVIL LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on October 28, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. n.. Dated: ~-~~5 ~~' COURTNE RITCHIE ~ILED~-CFrICE OF ?N"c P~~?TF~nN~T~IF?Y 2010 MAR - I °Fi 2~ 2 6 r ErUPvSI'LV~t-~i~ COURTNEY RITCHIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-7415 Civil Term TODD HOSTERMAN, CIVIL LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REgIIEST ENTRY OF A DIVORCE DECREE IINDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated : ~. ~~ ,~ COURTNE RITCHIE FILED-t~~=r'iCE Ui/ ?1-iE P~~1;-n~D1~iFY KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ZQIO ~9AR -1 °~! 2~ 26 PEN~vSYLV~"+ti1A COURTNEY RITCHIE, Plaintiff v. TODD HOSTERMAN, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7415 Civil Term CIVIL LAW DIVORCE AFFIDAVIT OF CONSENT. 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on October 28, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: '~- ~`.. ~~ 'ou"u TODD HO ERMAN ~ILEd-d~=riCE ~~F TNT P~td'~"'!~dT~RY 2010 PEAR - i RM 2~ 26 curv~~~~i~¢~J~~,,~F~ t~~~~~rr COURTNEY RITCHIE, IN THEP~Ot~i~lj~~~~ COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-7415 Civil Term TODD HOSTERMAN, CIVIL LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. without notice. 2. I consent to entry of a final Decree of Divorce 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 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. 4. I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Z_'Z`, ~~ ~~ TODD HOSTERMAN COURTNEY RITCHIE V. TODD HOSTERMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7415 Civil Term DIVORCE DECREE AND NOW, ~ a~ c~r1 2 'L040 , it is ordered and decreed that COURTNEY RITCHIE plaintiff, and TODD HOSTERMAN ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those Gaims are as follows: (If no claims remain indicate "None.") NONE By the Court, ~~ Attest: J. ~~ Prothonotary ~x~~.