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Home My WebLink About10-3291.+ CHRISTIAN CHARLES HUGEL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. LUCY JAYNE HUGEL, : NO ~~ _ 3 ~ ~~ GN~ I -f e ~^~ Defendant :COMPLAINT IN DIVORCE ~ ~ 4 O `7i ~Y', NOTICE '?;~-~ ~- R,~ .~~ _:r -~: r-- YOU HAVE BEEN SUED IN COURT. If you wish to defend against that.: ~ ` ~° claims set forth in the following pages, you must take prompt action. Yo~.~,~~f~ ~"' _ warned that if you fail to do so, the case may proceed without you and a decree c7 ~ ~=~ ~~~' 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 the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR AL{M'ONY, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 $ 3 s~z -~ ~ ~ ~ P~~ cu s ~^ R~~y~~6G Christian C. Hugel 142 Brindle Road Mechanicsburg, PA 17055 (717)433-0834 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTIAN CHARLES HUGEL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. J Q _ ~ ~.. 9 I C ~U~ ~ -f -c t.. LUCY JAYNE HUGEL, Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW COMES, Christian C. Hugel, Plaintiff, and files this Complaint in Divorce and in support thereof alleges as follows: 1. Plaintiff is Christian C. Hugel who currently resides at 142 Brindle Road, Mechanicsburg, in the County of Cumberland, Commonwealth of Pennsylvania; 2. Defendant is Lucy Jayne Hugel who currently resides at 142 Brindle Road, Mechanicsburg, in the County of Cumberland, Commonwealth of Pennsylvania; 3. Christian C. Hugel and Lucy Jayne Hugel have been bona fide residents of the County of Cumberland, Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint; 4. The parties were married on the 16St day of October, 2004, in Cumberland County, Pennsylvania; 5. Neither Plaintiff nor Defendant is in the military or navel services of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments; 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction; 7. Plaintiff and Defendant have no children. There are no children issuing out of the marriage of Plaintiff and Defendant; 8. The 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; 9. The marriage of the parties is irretrievably broken; 10. The cause of action and section of the Divorce Code under which the Plaintiff is proceeding §3301(c) -The marriage is irretrievably broken; 11. The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences; 12. A written Marriage Settlement Agreement has been entered into between the parties prior to the filing of this Complaint in Divorce. Plaintiff desires that the written agreement be approved by the Court and incorporated in any divorce decree which may be entered dissolving the marriage between the parties. A true and correct copy of the Marriage Settlement Agreement is hereby attached to this Complaint in Divorce and marked "Exhibit A"; WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a Decree of Divorce, divorcing the parties from the bonds of matrimony. Respectfully submitted, C . ~.~ Christian C. Hugel 142 Brindle Road Mechanicsburg, PA 17055 (717)433-0834 Plaintiff MARRIAGE SETTLEMENT AGREEMENT Christian Charles Hugel (hereinafter, "Christian") and Lucy Jayne Hugel (hereinafter, "Lucy"), husband and wife, hereby enter into the following Marriage Settlement Agreement (hereinafter, "the Agreement") and agree to the following equitable distribution of marital assets and non- marital assets in contemplation of the filing of a Complaint in Divorce: 1. Christian shall transfer the Registration of Ownership of the 2004 Pontiac Aztek to Lucy; 2. Lucy shall receive sole ownership of the jewelry box and all the jewelry it contains; 3. Christian shall make a payment of $25,000.00 to Lucy; 4. Lucy shall receive ownership of any of the contents of the house located at 142 Brindle Raad, Mechanicsburg, Pennsylvania, 17055, with the following exceptions which Christian will receive ownership of: a. 2005 Pontiac Grand Prix b. flat screen television c. Master Bedroom furniture d. kitchen table and chairs e. green Oriental rug f. all remaining contents of the house located at 142 Brindle Road, Mechanicsburg, Pennsylvania, 17055, which are neither removed nor tagged for removal by Lucy prior to the filing of the Complaint in Divorce; 5. Lucy shall receive sole ownership of the two cats and the two dogs; 6. Christian and Lucy shall transfer the Deed to the property located at 142 Brindle Road, Mechanicsburg, Pennsylvania, 17055, to Christian's sole ownership; 7. Christian shall receive sole ownership of the property located at 502 Market Street, Lemoyne, Pennsylvania, 17043, and all the contents thereof; ~~ ii ~?~HI~iT 8. Christian shall receive sole ownership of the business known as "Law Offices of Christian C. Hugel"; 9. All remaining property not mentioned .in this Agreement and not claimed by Lucy prior to filing of the Complaint in Divorce shall become Christian's property. The above shall constitute the complete Agreement of the parties. i , S" ~, oto Date Christian Charles Hugel s I~ lam ~ o -~z~r Da e ~ Lucy J n ugel COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND On this ~ day of /~Ct 2010, before me, a Notary Public, the undersigned off cer, personally appeared Christian Charles Hugel and Lucy Jayne Hugel, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledge that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and Notarial seal. Notary Public ,//f 6 ~~ ~ ~ Common Wealth of PA My Commission Expires: i/YIQr C'~ ~ NOTARIAL SEAL Parvin M. Mehrtash, Notary Public Upper Aften Twp., Cumberland County My Commission Expires March 06, 2012 VERIFICATION I verify that the statements made in this Complaint 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. §4904, relating to unsworn falsification to authorities. 5' l7 2oi ~ C, Date Christian C. Hugel, Plaintiff CHRISTIAN CHARLES HUGEL, Plaintiff vs. LUCY JAYNE HUGEL, Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, :PENNSYLVANIA NO. 10-3291 Civil COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE PLEAS N n ~-{:r r ; C ftl ~~ ~_ co ~ _, _~~ 4- ~ ~~, 7~ t',, TjL ~ ~--1 ~: I, Christian C. Hugel, hereby state that on May 28, 2010, I mailed a true and correct copy of the Complaint in Divorce by Certified United States Mail, Restricted Delivery, No. 7009 2250 0001 2034 2162, to Mrs. Lucy Hugel, 20042 Shamrock Glen, Lake Forest, California, 92630, the last known mailing address of Defendant, which documents were received on June 5, 2010, as evidenced by the attached Certified Mail Recept and Domestic Return Receipt. /l ~ ~' .~ /'il/ 0 Christian C. Hugel 142 Brindle Road Mechanicsburg, PA 17055 (717)433-0834 Plaintiff 'e s ~ ~ ~ ~ ~ P"I ~• f ~ -~- ' r •-• ~ ~ LPdCE F{lRf51`4~ :,9 ~' ,, - m -- o P $ ~O.bl ,f.: ,.~F43 ~ cerulied Fee ~2. ~Q3 ~ ' ~::" ~ ~ Return Reoalpt Fes (ErWorserru3nt RequYed) ~3 • ~-"' ' ' Posima -G .`klere t (~ (E[idOi'eem@tDit Requir dj 7T.~St~~c, ~ ~`j_S ~`,. ~~ +1 . ~ ~ ~ ~, Tota1 P r~,~ ~ ~io.n ~~ ~- ~S !~ ~~ 3~ ' 1 ' r ~ City, 318tB, t1f44 ~ . r_- r ! ,. .y„ 7. .~...- / ~ ~ ~. / v ~ , , .~G JRf ,a• . e o ti:: ~.. ...:. ra.,+ ^ C~nplete items 1, 2, and 3. Also complete A» sienat<xe item 4 if Reshicted telivery is desired. D ^ Print your name and address on the reverse X ^ Addressee so that we can return the card to you. s. ` ^ Attach this card to the back of the mailpiece, ,. y;. '%~;°, ~ f ,. ~ j Q or on the front ff space permits. ~ ~~~ ° cY 1. ArUde Addressed to: D. Item 1? ^ Yes delivery a t~elow: ~ Wo ~~~~ ~~~~ ~1vw~L ~ ~~~~~=~ti~~~~=r~~~ ~V Q C'~~. ~J~/~MI~OC k ~ f-~J~ 3. SarvfceType Certified NNtI ^ Express Mall ~•14 ~Cr+S ~012~ST GR ^ Re9tecerea ^ cam, fa iwer~nendise 1 °l 2~ 3,0 ^ fnsttred ~ o co.a. 4. Rea4ricted Delivery? jExtrs Fea) Yes ' 2. Artiaero~er ?QQ9 225Q QOD1 2034 2162 PS Form 3811, Febntary 2004 Domestic Redxn Receipt ,o~s~a2-M-iseo CHRISTIAN CHARLES HUGEL IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. LUCY JAYNE HUGEL NO. 10-3291 Civil DIVORCE DECREE AND NOW, ~~~, ~~ , it is ordered and decreed that CHRISTIAN CHARLES HUGEL plaintiff, and LUCY JAYNE HUGEL ,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 Court, ~: ~1