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Home My WebLink About10-3364 JOANNE HOUDESHELL, PLAINTIFF vs. WILLIAM F. HOUDESHELL, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. /O'3~L~ f CIVIL TERM CIVIL ACTION -LAW ACTION FOR 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. Wlten 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 Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. 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 ~"~ ~,: ;- ~ ]-- f-- 2 Liberty Avenue ~~~ c ~ ~' ? ". Carlisle PA 17013 (7l7) 249 3166 ~.3S~.Q~j~~ ~ , ~ f ~ - `~ --" ~- _" r ~ 1-800-990-9108 J ~~~ _ ~~ ~-~ >~ ~ 1~~ ~ ~~ ~~-a~a,~~s _ .~ u- o ..~ v t JOANNE HOUDESHELL, PLAINTIFF vs. WILLIAM F. HOUDESHELL, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION -LAW ACTION FOR DIVORCE COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, JOANNE HOUDESHELL, by and through her counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and makes the following consolidated complaint in divorce for divorce. 1. Plaintiff is JOANNE HOUDESHELL, an adult individual, who currently resides at P.O. Box 378, Enola, Cumberland County, Pennsylvania, 17025 and has resided in Cumberland County for over one (1) year. 2. Defendant is WILLIAM F. HOUDESHELL, JR., an adult individual, who currently resides at $28 Magaro Road, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully married on Apri124, 1993. 5. There have been no prior actions of divorce or for annulment between the parties except this Complaint filed for divorce. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the court require the parties to participate in counseling. Plaintiff has chosen not to engage m, or to request any counseling. Neither Plaintiff nor Defendant was a member of the United States Military Services. 9. Plaintiff and Defendant have no children from their marriage. COUNT I -REQUEST FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference thereto. 11. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiff believes Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff, JOANNE HOUDESHELL, respectfully requests the court to enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: May_(~__, 2010 Susan Kay Candi , Counsel for Pla tiff PA I.D. # 64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: s • ~~ • 20 ~ ~ JO E HOUDESHELL IN THE COURT OF COMMON PLEAS OF JOANNE HOUDESHELL :` CUMBERLAND COUNTY, PENNSYLVANIA . V. WILLIAM F. HOUDESHELL, JR. ~ 2010-3364 NO. DIVORCE DECREE AND NOW, `~, Le 1 ~ , it is ordered and decreed that JOANNE HOUDESHELL plaintiff, and WILLIAM F. HOUDESHELL, JR. ,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 to ~~~ ~•l0 ~!O /v~~.. ~~ ~a i~ c~u.~ ~erJ -~ ~~.