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FIFILES\DAT AFILE\GelleraI\CurremII1226-1,dcomltde
Created: 7/15/04 4:28PM
Revised 7/15/04 4:31PM
11226.1
KATHRYN A. HARTZELL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04- g4l./3 c..,.vll
MATTHEW P. HARTZELL,
Defendant
IN DIVORCE
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 ofthe marriage,
you may request marriage counseling. A list of marriage counselors is available at the
Prothonotary's Office, One Courthouse Square, Carlisle, PA 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 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.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
KATHRYN A. HARTZELL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04-
MATTHEW P. HARTZELL,
Defendant
IN DIVORCE
DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE
I. Plaintiff is Kathryn A. Hartzell, who currently resides at 138 South 30th Street, Camp
Hill, Pennsylvania.
2. Defendant is Matthew P. Hartzell, who currently resides at 4 Wheatfield Drive,
Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 5,2001.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiffhas 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.
8. Plaintiff requests the Court to enter a decree of divorce.
MARTS ON DEARDORFF WILLIAMS & OTTO
BYThO!~U~~
J.D. Number 17512
Ten East High Street
Carlisle, PAl 70 I 3
(717) 243-3341
Date: July 15, 2004
Attorneys for Plaintiff
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered by
my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the document and to the extent that it is based upon information which I
have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content of the document is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
IAG.JIL~)'XV\ (llko>'l"\~ II
Katherine Hart~l (j
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F: \FILES\DA T AFILElGeneral\Current\ 11226-laccservice
Created 7115/04 4:44PM
Revised: 7/16104 8:49AM
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-34<3 CJVIL - ACTION LAW
KATHRYN A. HARTZELL,
Plaintiff
MATTHEW P. HARTZELL,
Defendant
IN DNORCE
ACCEPTANCE OF SERVICE
I, Matthew P. Hartzell, being the named Defendant in the above matter filed in the
Cumberland County Common Pleas Coun, h~reby accept service of the Divorce Complaint on
July (,0 ,2004.
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Matthew P. Hartzell
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RECFtVEL
JUL 22 _
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F,\FILES\DA TAFlLE\General\Current\ I 1226 I maiden
Thomas J. Williams, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
LD. 17512
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
v.
IN THE COURT OF CO MON PLEAS OF
CUMBERLAND COUNT , PENNSYL V ANlA
NO. 04-344) CIVIL - AC ION LAW
KATHRYN A. HARTZELL,
Plaintiff
MATTHEW P. HARTZELL,
Defendant
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the above captioned case discontinued.
MARTS ON DEARDORFF W LIAMS & OTTO
Attorneys for Plaintiff
Date: April 4, 2005
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