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Home My WebLink About04-2799 W A 'r'NE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 ALLAN M. HONE, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 04- )....,q 1 CIVIL TERM JENNIFER A. HONE, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been su~d in Court. If you wish to defend against the claims set forth in the following pages, you mmt 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 marriagl' counseling. A list of marriage counselors is available in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 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 I AKE THIS PAPER TO YOUR LA WYER 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 ~~ /"~~ Waynef'. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 170]] ALLAN M. HONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 04- ;nqq CIVIL TERM JENNIFER A. HONE, Defendant ; IN DIVORCE COMPLAINT 1. Plaintiff in this Action in Divorce is ALLAN M. HONE, an adult individual who resides at 17 Oak Ridge Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is JENNIFER A. HONE, an adult individual and citizen ofthe United States of America who resides at 14 Jane Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. Plaintiff and Defendant were lawfully joined in marriage on February 2, 2002, in Boiling Springs, Cumberland County, Pennsylvania. 5. The parties have been living separate and apart since on or about May 5, 2004. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. Both parties to this Action in Divorce are legally capable of managing their own concerns. 9. Defendant herein is not a member of the armed forces of the United States of America. 10. There were no children born to the parties. 11. 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. ,E F, SHADE meyatLaw PomfretStreet 1 Pennsylvania \7013 -2- " SHADE at Law fret Street "lsylvania , WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. ~r~ Wayn{F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -3- r":> 0 ('2 c? <;.~ :;) -"(I , .s-- -:;1 ~ -l9- '-< -p - :~ \-{ .0 -- 't-- \S- O c..... L' -:':' CIl -~ -.". )J -- (('l 0 r:'? ~ -- --.:l. -cJ ...::. (), ~ r J- /,----' ' .....------------_.. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania ]70]3 I verity that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: June 8, 2004 ~/ p [J V=- ';. - )J Crt _ ~ ~ ~ -19. - .() C> C( () t! :D ~ r' "" c.:..;:.. c...;:) ""- S-.: co -< ::I: I:,., o ",'I ,-. =.r-" nlr~ -:Jf}:l -."CJ ""-.-' I C-'c; :,',:1..::, '-n <~;ri . -,~ r'~ 'I ~. i " " € Ui - ..~ WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania [7013 ALLAN M. HONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. JENNIFER A. HONE, Defendant : NO. 04-2799 CIVIL TERM ; IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on June 18,2004, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Plaintiff on June 19, 2004, as evidenced by the return receipt card attached hereto bearing Certified No. 70993401) 0018 5044 8608. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: June 21, 2004 wa~~~e~ . Complete Items 1, 2, and 3. AI80 co."pIele Item 4 If Restricted Dellvlll')lls desiI'ed, . Print your name and address on the rev...... so that we can return the card to you. . Attach this card to the back of the mallplece, or on the front W space permits. 1. Article Addressed to: O,ladollvery__fromIlem1? If YES, enter dellveoy .- below: Jennifer A. Hone 14 Jane Lane Carlisle, PA 17013 3. Service Type CtCertlflod Mall D Raglatarod o Insured Mail o Express Mail D Return Receipt for MerchandIse DC,O,D, raFee) -I ~ 2. Article Number (Transfer from service label) PS Form 3811, August 2001 Domeatlc Roturn _ 102585-02-M-Q835 .., E:l ...ll .., ::r ::r E:l LT1 Postage $ .60 2.30 1. 75 3.50 8.15 Postmark Here Certified Fee Return Receipt Fee c[] (Endorsement Required) r"I E:l E:l Restricted Delivery Fee (Endorsement Required) June 18, 2004 Total Postage & Fees $ E:l E:l .::r Recipient's Name (Please Print Clearly) (to be completed by mailer) fTI .Jennif.er___A...___Rone--- [J"'" Street, Apt. No.; or PO Box No IT' 14 Jane Lane C .city:siaie:z(p;.:r----------------- r- Carlisle ." ALLAN M. HONE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA ; CIVIL ACTION - LA W JENNIFER A. HONE, Defendant : NO. 04-2799 CIVIL TERM : IN DIVORCE COMMONWEAL TH OF PENNSYL VANIA) ) SS; COUNTY OF CUMBERLAND ) AFFIDA VlT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DrVORCE DECREE UNDER 93301(c) OF THE DrVORCE CODE I. A Complaint in Divorce under ~3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on June 18,2004, and served on Defendant on June 19,2004, by certified Cnited States mail postage prepaid, return receipt requested, addressee only. 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 without notice. 4. ,vAYNEF. SHADE I understand that I may lose rights concerning alimony, division of property, Attorney at Law 3 West Pomfret Street ''''''''. Peno,y'van;, lawyer's fees or expenses if I do not claim them before a divorce is granted. 17013 II 5. I understand thaI 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. 6. I have been advi,ed of the availability of marriage counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counselin5. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, whict list is available to me upon request. 8. Being so advised, I do not request that the Court require that my SPouse and I participate in counselin5 prior to a Divorce Decree's being handed down by the Court. 9. I verity 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 tillsification to authorities. Date: September 17, 2004 WAYNE F, SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 z:::::.:r~~ .1 (') '" C) (~:::) ~~ co> -n _C'" " C/, :.~ n ~,~ , C__"l -.J -,' I;; ( ~~:! :r~ -.:>.. ~. r' C CO '~ ,,",- -~ CO -( 0 . ALLAN M. HONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 04-2799 CIVIL TERM JENNIFER A. HONE, Defendant : IN DIVORCE AFFlDA VlT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under ~3301(c) of the Divorce Code with Notice of Availability of Counseling wa:; filed on June 18, 2004, and served on Defendant on June 19,2004, by certified United States mail postage prepaid, return receipt requested, addressee only. 2. The marriage of Plainti tT and Defendant is irretrievably broken and ninety (90) days have elapsed from the dale of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without notice. 4. 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. 5. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the D~cree will be sent to me immediately after it is filed with the Prothonotary, 6. I have been advised oflhe availability of marriage counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. 9. I verity that the statements made in this At1idavit are true and correct. I understand that false statemems herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: September 17, 2004 n y1AAA G. ~ A. Hone Cl.+LrlO --. - , '. .. () '" :f€ ~,') (,) ~ -" -<- -,', fl"_ C/) :';--J ~. f1"j j'l'j - ~, '1:, .'-" ," (,.-. ~.'2 - ("1ft; r:' " -Ur:'1 ~i Z2:? ~~::12:; " , , (") ?,.) n;- <. -.~: t;:) ')":, -'-:: ."=0 Q '"" WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 ALLAN M. HONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA ; CIVIL ACTION - LAW v. JENNIFER A. HONE, Defendant ; NO. 04-2799 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary; Please transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Ground for divorce; Irretrievable breakdown under ~3301(c) of the Divorce Code. 2. The date and manner of service of the Complaint were to Defendant on June 19,2004, by certified United States mail postage prepaid, return receipt requested, addressee only. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention to Request Entry ofa Divorce Decree under ~3301(c) of the Divorce Code by Plaintiff was September 17, 2004, and by Defendant was September 17,2004. 4. Related claims pending: None. Date: September 17, 2004 ~~~ Wayn F. Shade Attorney for Plaintiff !;--:c ~c -..C'-' ~ :::J , (') c.. I':' (., - "-> "'" t:;;.,) -"" G-) L':~: c:. -.,-') =:,j -..1 ~ C:) C;l , , , " " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNA. STATE OF ALLAN M. HONE, , Plaintiff No. 04-2799 CIVIL TERM , VERSUS , JENNIFER A. HONE, Defendant , , , DECREE IN DIVORCE ~~ 27 :~ ~ IT IS ORDERED AND AND NOW, DECREED THAT ALLAN M. HONE , PLAINTIFF, AND JENNIFER A. HONE , , DEFENDANT, , , ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; UO~ , J, / / / BY ~ COURT: ..m?:~ PROTHONOTARY , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , . . , . , . , . . . , . . , . . , . . . , , " . ~ % ~ ~?? ~pt, .119 [f'" t7 ~p ,lt /p '~.~~ -~ /7Cl.J:C".O ';, . ,'.. "", , ..,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA II JJ1t Plaintiff Ij i.Lft N J-et7Y7itfv< Vs Il JIJ-e Defendant FileNo. o t..j -:;;, 79 9 IN DIVORCE C ii/I I fe1f' m NOTICE TO RESUME PRIOR SURNAME _ prior to the entry of a Final Decree in Divorce, or $__ after the entry of a Fmal Decree in Divorce dated 3./~ 1~(1(J.y' hereby elects to resume the prior surname of ,J.!()U)tJ If D , and gives this written notice avowing his / her intention pursuant to rovisions of 5 P.S. 704, Date: .5 12 y I DS- 1 I ~ Si COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ~ On the~day Of.l!fi1J!.- ,200.5, before me, the Prothonotary or the 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 hereunto set my hand and official seal. NOTARIAL SEAL PROTHONOTARY, NOTARY PUBUC CARUSlE CUMBERLAND CDUNlY COURT HOUSE MY COMMISSION EXPIRES JANUARY 2, 2006 " . . " . " .' . :'~': -....... '" -z ~ ~. ~ 'J 1"\.'1 r\; b' \ ~ ~ ~. '\':'~, '.~lIo....,' , .'-'''.~''V-P.::,~" >0 :'I. .' ,~ . \, .~ . .~... \ '...... ;" .' , "'.:' (::",