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Home My WebLink About01-1443 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. (fl '~ / c/c/~'CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. Ifyou wish to defendant 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 will proceed without and a decree in 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 Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FH.E A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. tgl~/~/7-~ CIVIL TERM IN DIVORCE (~OMPLAINT IN DIVORCE 1. Plainfiffis Brian L. Hair, an adult individual currently residin~ at 1328 Pine Road, Lot 6, Carlisle, Cumberland County, Pennsylvania. Plaintiff has resided at this address for approximately three years. 2. Defendant is Jane M. Hair, an adult individual currently residin8 at 592 Lake Meade Drive, Hanover, Adams County, Pennsylvania. Defendant has resided at this address for approximately three weeks. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the ~ling of this Complaint. 4. Plaintiff and Defendant were married on October 21, 2000, in Crardners, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Unites States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriase is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that Defendant will, ninety days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-$551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. BRIAN L. HAIR, JANE M. HAIR, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-1443 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) ot' the Divorce Code was filed on Mamh 13, 2001, and served on March 31, 2001 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 after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE iN THE FOREGOING 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: BRIAN L. HAIR, Plaintiff BRIAN L. HAIR, V. JANE M. HAIR, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : : NO. 01-1443 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: BRIAN L. HAIR, JANE M. HAIR, Plaintiff : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant CIVIL ACTION - LAW NO. 01-1443 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 13, 2001, and served on March 31, 2001 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 Divome after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. qE M. HAIR( Defendant BRIAN L. HAIR, JANE M. HAIR, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-1443 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c~ OF TIlE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. ~:~X/E M. HAIR, Defendant Plaintiff VS. JANE M. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CIVILTERM NO. 01-1443 PRAECIPE'rO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301 ~ of the Divorce code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: certi;ELC__m~ 1: r~tri~d ,~l iv,~-y_: -- __~__on March 31 2001 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: ; by defendant 3/17/QZ by plaintiff ._2 / 14--/-Q~-- (bi (1} Date of execution of the affidavit required by §3301 of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: copy of which is attached: Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was flied with the Prothonotary: 2___~/02_ Date defendant's Waiver of Notice in §3301 (c) Divorce was flied with __ 202_ the Prothonotary: ~ Marylou Matas, ~/3~ ..... Plaintiff VS. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COLINTY, PENNSYLVANIA : CIVIL ACTION- LAW : NO. 01-1443 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVIClr[ AND NOW, this 10t~ day of April, 2001, comes IVlarylou Matas, Esquire, Attorney for Plaintifl~, and states that she mailed a certified and true copy of a Complaint in Divorce to the Defendant, Jane M. Hair, to her address of 592 Lake Meade Drive, East Berlin, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on March 31,2001. Sworn and subscribed to befor~ me this /0 'fi~ day or ~Z~u~ ,2001. NOTARY(~UBLIC -'~c~RO _. NotarMI Seal ~?m J. Goshom, Notan/ nisle Boro Cumberland Marylo~, Esquire % GRIFFIE &~SOCIATES 200 North Ham)vet Street Carlisle, PA 17013 (717) 243-5551 item IN THE COURT OF COttON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff : : File No. : vs. : IN DIVORCE Defendant : NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, havinG been Granted a Final Decree in Divorce on the /5 day of ~.~-;{ , ~__~, hereby elects to resume the prior surname of ~--'~ m m~ _~_~]~ and Gives this written notice pursuant to the provisions of 54 P.S. $ 704. signa~Gre Si~ature of ame~6~ihg resumed COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF CUMBERLAND : SS. On the /~ day of ~/~ · ~, before me, a Notary Public, personally appeared ~he 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. seal. In Witness Whereof, I have hereunto set my hand and official I ..... ~,.A,~e~~ ~ 'l I Bonnie L. Sholley, Not,try Public I ~ SouthMiddlelonTwp,Cum~rl~d~n~ ~ IN THE COURT Of COiVIMON PLEAS OF CUMBERLAND COUNTY ST/~,'¥E Of ~ PENNA. BRIAN L, HAIR. Plaintiff VERSUS Defendant N O. 01-1443 Decree IN DIVORCE DECREED THAT Brian L, Hair 2002 iT IS ORDEred AND PLAINTIFF, a N d Jane M. Hair ,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