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Home My WebLink About10-2680IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION - LAW HOPE L. FOUST I Plaintiff No. Q V. Civil Action - Law LEONARD S. FOUST Divorce C A Defendant r ?- N NOTICE TO DEFEND C . LJ'' :x7 C.v.. 'C YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTEREING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 ?3sad a pd-?I ?k 3:7 -7G 'I -f 9 r-? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION - LAW HOPE L. FOUST Plaintiff V. LEONARD S. FOUST Defendant No. 16° ?-6r6 Grv41 f Civil Action - Law Divorce COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Hope L. Foust, by her attorney, L. Rex Bickley, Esquire, and files the following Complaint in Divorce: 1. The Plaintiff, Hope L. Foust, is an adult individual who currently resides at 3526 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant, Leonard S. Foust, 330 Hogestown Rd., Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. The parties were married on November 4, 1978, in Lewisberry, Pennsylvania. 4. There have been no prior actions of divorce or annulment between the parties. 5. The parties hereto have been bona fide residents of the Commonwealth for a period of six (6) months immediately previous to the filing of this Complaint. 6. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The marriage is irretrievably broken. 9. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken is 3301 (c). WHEREFORE, Plaintiff respectfully represents this Court to: A. Enter a decree in divorce between the parties. B. For such other relief as deemed appropriate and equitable. Respectfully submitted, -Z?? L. Rex Bi ley, Esquire Attorney I.D. # 23095 114 South Street Harrisburg, PA 17101 717/234-0577 717/234-7832, fax VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and to the best of my information, knowledge and belief. I understand that false statements made herein are made subject to Pa.C.S.A.§4904 relating to unsworn falsification to authorities. Date: Hope L. Foust ,,_. ~.,~ IFu~ (o ~./yj il:a(, HOPE L . FOIIS~'. ~~ ~ Q d i' i ~ - ~ ~;, j j i : ~ ~; IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~ ~ . ' i i` CIVIL DIVISION LEONARD S. FOIIST Defendant NO. 2010-02680 CIVIL TERM 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 330; (c) 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: IInited States 1Kai1, Certified, 8estricted Delivery, Return Receipt dated April 30, 2010. Tracking number 7004 0750 3• ~~e6p~~rap~i~ja) ort(~ched proof of service) a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiff August 4 , 2010 ; by defendant August 4 , 2010 b. (1) Date of executions of the ,a/ffidlavit required by 3301 (d) of the Divorce Code: ~~lD (2) Date of filing ',and service of the plaintiff's 3301 (d) affidavit upon the respondent opposing patty: ~1.~lio 4. Related claims pending: 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: 8/ fo~1 D b. Date of plaintiff's '',Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: _ 8~(c~lD Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: g l0 10 _ _ Attorn y for Plaint' Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION -LAW HOPE L. FOUST Plaintiff No. 2010-02680 ry ~, v. Civil Action -Law ~- ...,.. ,~ o LEONARD S. FOUST Divorce z; r ~ ~- Defendant _ ~~., 6' _ ~.~ ~ \ .. C..:. ~ ~'~- AFFIDAVIT OF SERVICE I, L. Rex Bickley, Esquire, hereby depose and say that on April 30, 2010, I served the above-captioned Defendant with a Complaint in Divorce and Notice to Defend and Claims Rights with notice of Availability of Counseling., by First Class United States mail, Certified, Restricted Delivery, Return Receipt with a tracking number of 7004 0750 0002 8071 6274 as evidenced by the attached green card. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to Pa.C.S.A.§4904 relating to unsworn falsification to authorities. Dated: August 4, 2010 L. R Bickley, Esquire 114 South Street Harrisburg, PA 17101 717/234-0577 717/234-7832, fax IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVNIA ~ Q CIVIL ACTION -LAW ~'' ` ~~ ~ ~ ~~_ ~; ~ -, ~5 HOPE L. FOUST Plaintiff v. LEONARD S. FOUST Defendant PROOF OF SERVICE ^ Comple~s i6rirrs t ~ 2, and 3. Also Item 4 if tieetrictsd Delivery is desired. ^ Print your name and sddrese on the reverse so that we can rodent the card to you. ^ Attach this card to the track of the mallpiece, or on the front if space permits. i. Artfde Addressed to: (~ n~ a~ X./- W - Q ~0 9d G~- r~';o-rv-'c~ ~' ~ ~ ~~ ~~r,~. No. 2010-02680- . ~~ ~` :~~ .. ~. Civil Action - Lary ~ s_: Divorce ^..~ A. ~ Agent O Addroesee B. Received by (Prir-led Nsrrie) C. Date of Delivery D. la deNvery eddro ~ 1?~ n YES, eater =Cry eddroes o ~ ~~~~~ ~ ~ ~'70,~0 ~Do~r~ a ter, t+b.~e ~ Irisued sax ~ C.o.0. 4. Restricted DsNwry? (F.xEia Feel 1Rea s Ar~sbt~M*sr 7004 0750 0002 871 6274 plsrtsArMe~ asrMleYe1 - P8 Fans 3A11. Febniry 2004 t)orrreeric n.sm nsosipt raa>r~ae~rsw 0 '~ Postage S / ~'K J4 STJ~ ly,~ o Fee a ~. I_ Retum Redept Fee 0 (Eridorsemerd Requires) ~C}~'~Q ~ ,~~~(O. O Restricted Delivery Fee K•~ , , . u'! (Endorsement Required) G( ~ Toial Poetege t>i Fees $ itil0.0i %' O ° aPO Bahr Nb. •-_°- n ~; ~j~. r.. 1 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION -LAW HOPE L. FOUST Plaintiff No. 2010-02680 _~ v Civil Action -Law ~ ~ <°_:~ ~~ ~ ~ ~ ; -=-' _ ~-: .--- ~ ~ .-, LEONARD S. FOUST Divorce Defendant ; ~ ~ ,~.. 3' , .. AFFIDAVIT OF CONSENT ~ ~ ~ ~~ ~ . 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Apri122, 2010. 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. 1 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: ~ , Hope L. Foust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION -LAW HOPE L. FOUST Plaintiff No. 2010-02680 vii. Civil Action -Law LEONARD S. FOUST Divorce Defendant 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.A. §4904 relating to unsworn falsification to authorities. ce~~ Date: Hope L. Faust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION -LAW cs ~~' e.=- "~ -~ ~~ HOPE L. FOUST `-== ~v ~~~ Plaintiff No. 2010-02680 - ~, G_ - vi. Civil Action -Law .~ __ • .. .. LEONARD S. FOUST Divorce ~_~ •' c :r Defendant ~ ~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Apri122, 2010. 2. T'he 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 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: l0 Leonazd S. Foust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVNIA CIVIL ACTION -LAW HOPE L. FOUST Plaintiff v. LEONARD S. FOUST Defendant No. 2010-02680 Civil Action -Law 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.A. §4904 relating to unsworn falsification to authorities. ~~ Date: O Leonard S. Foust IN THE COURT OF COMMON PLEAS OF Hope L. Foust :CUMBERLAND COUNTY, PENNSYLVANIA V. Leornard S. Foust ~ 2010-02680 NO. DIVORCE DECREE AND NOW, Z o a , it is ordered and decreed that Hope L. Foust plaintiff, and Leornard S. Foust ,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 claims are as follows: (If no claims remain indicate "None.") NONE ~d By the Court, $• 13.10 $•13.10 ~~ ~~ cr p~ mov teal (Y~a~.~ 12c~ -4-0 `~ e--~. Aii~., ~U c c,letc,,, d a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HOPE L. FOUST Plaintiff V S. LEONARD S. FOUST FILE NO. 2010 IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME 02680 2010 C A 01) im N J~ T _ p ' V. ?J Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 12th day of August, 2010 hereby elects to resume the prior surname of Hope Lorene Culley and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: -? nature Si na re o name being resumed COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the _2-144 day of 20 L , before me, a Notary Public, personally appeared the above of cant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set n 300MVEALTti OF PENNSYLVA-M dw Seal Public Jennifer t obertso Cu nbberlrlend County South Middleton Twp•. Tres Jul 2y4 2011 My Commirsl Exp __.24 nAFm 6" y7 3 s