Loading...
HomeMy WebLinkAbout01-1143DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 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 Office of the Prothonotary at the Cumberland County Court House, 1 Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AA!NULMENT 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 Cumberland County Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 Attorney for Plaintiff DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CQDE 1. Plaintiff is David Eo Hall an adult individual who is sui juris and resides at 4189 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Michele M. Hall, an adult individual who is sui juris and resides at 4166 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. The present whereabouts of the Defendant, Michele M. Hall, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and DefeJdant were married on September 6, 1998 in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and 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 Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. Decree: WHEREFORE, Plaintiff requests the Court to enter a A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. TUCKER ARENSBERG & SWARTZ P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorney for Plaintiff VERIFICATION I verify that the statements true and correct. I understand that false made subject to the penalties of 18 Pa.C.S. to unsworn falsification to authorities. made in this Complaint are statements herein are Section 4904, relating Dated: 35887.1 David E, Hall Cumberland DW~CE OR ANNULMENTI HUSBAND David E. Hall 4189 Nantucket Drive, Mechanicsburg, Cumberland PA I.ua~o~ one [] [] WIFE Bitting Michele M. Hall e,,m 07 20 70 ~nsylvania 17'M a~k e~i nm~ Manager 4166 Nantucket Drive, Mechanicsburg,' Cumbeland, PA one Pennsylvania 24, OATE OF 06CRF. E (]~N (oar~ OF s~m~ 12 24 68 ~ Pennsylvania ~i~res s~ server 16. ~ ~ ~ ( ~ 09 06 c arr~a~e ~ [rre~rievb]y broken. DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-1143 Civil Term : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 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 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: David E. Hall, Plaintiff S.S. No. 179-60-9349 DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-1143 Civil Term : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 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 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: / ~ j~)~ / Michele M. Hall, Defendant S.S. No. 208-52-1408 DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-1143 CivilTerm :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 divome 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. Section 4904 relating to unsworn falsification to authorities. Date: 43852.1 Michele M. Hall, Defendant DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-1143 Civil Term :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330'1(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 proper[y, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divomed 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. Section 4904 relating to unsworn falsification to authorities. Date: David E. Hall, Plaintiff DAVID E. HALL, Plaintiff MICHELE M. HALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-1143 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF CUMBERLAND ) AND NOW, this 12th day of April, 2001, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Shaun M. Kovach, who, being duly sworn according to law, deposes and says that she is the secretary for Sandra L. Meilton, who is the attorney for the Plaintiff and that she mailed a Divorce Complaint on February 28, 2001, to Mrs. Michelle Hall, 4166 Nantucket Drive, Mechanicsburg, PA 17055, by Certified Mail No. Z 398 269 567, return receipt requested, and the same was received by her on March 15, 2001 as indicated by the Return Receipt Card, which is attached hereto. Shaun M. Kovach ~mm~n~y 2, 2001 Member, PemnsylvanJa Association ot Nota~ SWORN TO AND SUBSCRIBED before me, this 12th day of April 2001. Z 398 269 567 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail (See reverse) Sent to . e PO~ Office, Slate, & ZIP Code Spatial Delivery Fee Whom& Date Delivered j r-, ~"~'~ ~ate, & ~'e~ee's Address SENDER: · Complete items 1 and/o¢ 2 for additional seW~ces. · Complete items 3, 4a, and 4b et;~r* your name and address on the reverse of this form so that we can return this I alSO wi~h to receive the ~ aervice~ (for an extra fee): e; 1. I-I Addressee's Address ,-~ 2. ~Restricted Delivery ~ Consult postmaster for fee, i 4a. Article Number Mrs. Michelle Hall 4b. Service Type _E 4166 Nantucket Dr~ [] Registered ~}:Certified ~ i Mechanicsburg, p~l~fO~.~r.E~l~ai` U Insurec ~ ~ /~ .~ '~tum~tforMerchandise D COD ~ 5. R~eived By: (Print Name) ~ _u, / 8. Addressee s Address (Only ~f mquest~ ~ ~ ~55-~ andfeeispaid) ~ 6. Si~~r~en~ / ~/ ~ m PS Fo~ ~%, ~r 1~ ~m~-.~ ~stic Return Receipt I'N THE COURT OF COMMON PLEAS OF DAVID E. HALL , CU~4BERLAND COLrbITY , PENNSYLVANIA NO, 01-1143 CIVIL 19 MICHELE M. HALL To the Prothonotary: Transmit the record, PRAECIPE TO TRANSMIT RECORD together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section ~M~(x~k 3301(c) ~x~k~) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: March 15, 200~ certified mail 3. (Complete either paragraph (a) or (b) .) and waiver (a) Date of execution of the affidavit of consent/required by Section 3301(c) ~k~ of the Divorce Code: by the plaintiff October 5, 2001 ; by defendant (h) (1) Section 201(d) of the Divorce Code: (2) da~e of service of the plaintiff's affidavit upon the defendant: October 5, 2001 Date of execution of the plaintiff's affidavit required by 4. Rela~ed claims pending: None IN THE COURT OF COMMON PLEAS DAVID E. HALL VERSUS MICHELE M. HALL OF CUMBERLAND COUNTY STATE OF PENNA. NO. 01-1143 Civil Term AND NOW, DECREED THAT AND DECREE IN DIVORCE David E. Hall Michele M. Hall 2001 , IT IS ORDERED AND , PLAIINTI FF, , 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; None. BY TJ~;OUR~: __ PROTHONOTARY