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HomeMy WebLinkAbout10-2972 JAIME L. HUDSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: - S - 20_ Civil ler'rn ID- JA19, ANDRE K. HUDSON, : CIVIL ACTION - LAW Defendant : 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 Prothonotary's Office, Cumberland County, 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. 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 Q accommodations available to disabled individuals having business before the Court, please cc)tactMpr office. All arrangements must be made at least 72 hours prior to any hearing or business bsfo a then: Court. CUMBERLAND COUNTY BAR ASSOCIATION ?- 2 LIBERTY AVENUE T' CARLISLE, PA 17013 N Telephone: (717) 249-3166 -_, Mader. Baturin, squ re Attorney I.D.# 68971 BATURIN & BATURIN 2604 North Second Street Harrisburg, PA 17110 (717) 234-2427 DATE: April 30, 2010 (Attorney for the Plaintiff) i 4WQ.oo PQ A71rf 0,0 5siq p,* agl-55,.s7 JAIME L. HUDSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: - S - 20 ANDRE K. HUDSON, CIVIL ACTION - LAW Defendant IN DIVORCE COUNT I COMPLAINT UNDER SECTION 3301(C) AND (D) OF THE DIVORCE CODE AND NOW, this 30th day of April, 2010, comes the Plaintiff, JAIME L. HUDSON, by and through her attorneys, the Law Offices of BATURIN & BATURIN, and respectfully represents the following: 1. The Plaintiff is JAIME L. HUDSON, an adult individual, sui juris, with a Social Security Number of 173-70-1488, and who currently resides at 205 5th Street, New Cumberland, Cumberland County, Pennsylvania, 17070, and has been for the past four years. 2. The Defendant is ANDRE K. HUDSON, an adult individual, sui juris, with a Social Security Number of 199-58-0156, and who currently resides at 207 5th Street, New Cumberland, Cumberland County, Pennsylvania, 17070, and has been for the past four years. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 27th, 2000, in Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant have continued to live separately and apart since March 23, 2009. 6. There has been no prior action for divorce or annulment of the marriage between the parties hereto in this or any other jurisdiction. 7. Plaintiff avers that there are no children born to the parties under eighteen (18) years of age. 8. The Plaintiff and Defendant are both citizens of the United States of America. 9. Neither the Plaintiff nor the Defendant is a member on active duty of the Armed Services of the United States of America nor any of its allies 10. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. 11. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant and for such further relief as the Court may determine equitable and just. Respectfully submitted, BAT N&B T IN By: MADEL INE N. BATURIN, ESQUIRE (Attorney I.D. No. 68971) 2604 N. Second Street Harrisburg, PA 17110 (717) 234-2427 Dated: April 30, 2010 Attorney for Plaintiff -2- VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Dated: /2r 2 - ? ' (SEAL) J L. Hudson -3- JAIME L. HUDSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : 2010-2972 Civil Term ANDRE K. HUDSON, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on. May 4, 2010. 2. The marriage of the 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 in 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: ^I a ? ? '? ? (Seal) Jaime ,Z. Hudson ?1 T ` , V T J ? t ra Z I Q JAIME L. HUDSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : 2010-2972 Civil Term ANDRE K. HUDSON, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 and 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 TO THE PENALTIES OF 18 PA.C.S. §4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: _? - -? (Seal) Jai We L. Hudson = c a ``Yt J ?V JAIME L. HUDSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : 2010-2972 Civil Term ANDRE K. HUDSON, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 4, 2010. 2. The marriage of the 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 in 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: 6L ? (SEAL) Andre K. Hudson ?C 3 = O W -< JAIME L. HUDSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :2010-2972 Civil Term ANDRE K. HUDSON, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 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 and expenses if I do not claim them before a divorce is granted. 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 TO THE PENALTIES OF 18 PA.C.S. §4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. Date: -(Seal).,. Andre K. udson c. .?, j , c ?rn C5 JAIME L. HUDSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : ANDRE K. HUDSON : No. 2010-2972 Civil Term DIVORCE DECREE AND NOW, ~~ 8 ~ ?.o ! a , it is ordered and decreed that JAIME L. HUDSON plaintiff, and ANDRE K. HUDSON ,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 By the Court, ~~~~ n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAIME L HUDSON Plaintiff : FILE NO. 2010-2972 VS. IN DIVORCE ANDRE K HUDSON Defendant NOTICE TO RESUME PRIOR SURNAME 20 .- lP U V?t Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the SEPTEMBER 8 day of 2010 hereby elects to resume the prior surname of JAIME LYNN STONE and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: l0 /.3 /Q COMMONWEALTH OF PENNSYLVANIA Signature 11.0oPd ?.s ?? Signature of name being resumed fa 0' ?-y?at 0 W SS. COUNTY OF CUMBERLAND On the ,314, O day of & :fub e. r 20 before me, a Notary Public, personally appeared the above affiant 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 my hand and official seal. otary ublic wq i Odpftd..