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HomeMy WebLinkAbout01-2754 DEBORAH K. HILL. Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA Defendant : NO. 2001- .:l.,,ry CIVIL TERM : CIVIL ACTION - LA W : IN DIVORCE LEVI HILL, 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 divorce is indignities or irretrievable breakdown of the marriage. you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle. Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY. LAWYER'S FEES OR EXPENSES. BEFORE A DIVORCE OR ANNULMENT [S GRANTED. YOU MA Y 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 2 Liberty Avenue Carlisle. Pennsylvania 17013 (717) 249-3166 DEBORAH K. HILL. Plaintiff : TN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYL VANIA v. : NO. 2001-.2 73-Y CIVIL TERM : CIVIL ACTION - LAW : TN DIVORCE LEVI HILL. Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OR 3301(d) OF THE DIVORCE CODE The Plaintitl Deborah K. Hill. through her attorney. Thomas S. Diehl. makes the following Complaint in Divorce. and. in support thereof. avers as follows: I. The Plaintiff. Deborah K. Hill. is an adult individual who currently resides at 2112 Ne\.\;'ville Road. Carlisle. Cumberland County. Pennsylvania 17013. 2. The Defendant. Levi Hill. is an adult individual who currently resides at 2112 Newville Road, Carlisle. Cumberland County. Pennsylvania 17013. 3. The Defendant and the Plaintitr have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 6. 1999 in Sussex County. Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Anned Forces of the United States of America or its Allies. 7. The 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' marriage is irretrievably broken. WHEREFORE. the Plaintiff. Deborah K. Hill. respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. ~ 3301(c) or 3301 (d) of the Divorce Code. Respectfully submitted, // Date: S' - 7 -Ol Thomas S. 0 Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (7I 7) 240-0833 (717) 240-0893 - fAX LAW OFP'ICES OF MISLITSKV AND DIEHL ONE W..T HIGH STREET. gUI"E 20. CARU8LE:. PENN8YLVANIA 17013 TCL.SPMON. 1717) 240-0833 FAX (717) Z.o-oau VERIFICATION I \c'rir~ Ihallhc sWlcmcllls madc' illlhis (.\'mplailll arc Irllc" alld l'IlITc"CI. 11IIldcTsWIld Ihal 1~IiSl' sl'lIc'mc"llls hc'rcill arc madc sllhjc'<:l I.. Ihc' I'c'llalLic" ..I' I X I'a.( '.S. * -NII.j. rd'lIill~ I.. llll:,,\\lll"n l~lI...;ilil'illi'ln h' alllhllritil's. r r", .~.' '--.:...:.J .__ IlLBlll{;\11 K.IIII.I..l'lailllirr III III IIIIII 1111111:111111111 11I1II111111111 II ("'. l~ rE.... ,,~ .. --,. i;:. .,' r:: ~:': ~;::: ~'...' I ~ .~.(::: ;.,: =< ~? ., f . . : : lH: 81~' ., . : . ~lJ. ; rS:l", : :r _ :L. . z'''' 'V~1 'iC}.. : 9 ~(::C : -.: m: :r: z ~ O' , ~ iF'~1 :-'-I": ~!. ~~et~ . l- f ..... - ':::::: ..J .... .... '" ...J lI" ~ z ~; -I u:mr. :r ~ 'In 0: 2' o > ::c ~ . ~r.r.:~ r"~ . :-) ., : . . ,.' ._. . ., I ._~ . ., .'::,::1 : .~ : ~.") :.n '0 _:"." i , . -.. ;.:;. ,',:,r"l _J ~...., ~-... _:J -< '=, \~- ""'- ~ ~ -" .. ~ ~ r.,.- V', V\ C ~ C DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-2754 CIVIL TERM LEVI HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the above-captioned case for the purpose of securing service upon the defendant. Respectfully submitted, Date: I 'J - ( 1,- U ( Thomas S. Die Attorney for the Plaintiff One West High Street. Suite 208 Post Office Box 1290 Carlisle. Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - fAX DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-2754 CIVIL TERM LEVI HILL, Defendant : CIVIL ACTION - LA W : IN DIVORCE PRAECIPE TO THE PROTHONOT AR Y: Please reinstate the above-captioned case for the purpose of securing service upon the defendant. Respectfully submitted. Date: May 22, 2002 Thomas S. Diehl Attorney for the Plaintitl' One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX 0 r,;} S i'....') -.;'"' ~:j ". -". "') .. rnr":'" " .". "; ::=? ; r...) tF: '-" -', r-' l. -c' ..~: "1';- <: -- , /.. C' r:':' .' ~: ~~.~. . ~~\ .' , c~ :? ~ ;<. DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2001-2754 CIVIL TERM LEVI HILL. Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDA VIT OF SERVICE I. Kimberly L. Hough. an adult individual, hereby certifY that a Complaint in Divorce was served upon the above-captioned Defendant, Levi Hill, by hand delivering a copy of the same to the front desk officer at the Cumberland County Prison, I 101 Claremont Drive, Carlisle, Pennsylvania on May 23, 2002 at approximately 2:00 p.m. in accordance with Pa.R.C.P. I 930.4(2)(ii). DATE: May 29, 2002 /' . ./ - , Leg ssistant - taw Offices of om . Diehl One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 .. .. . n r:::. ., f,; ". , , -, - J:'ll :-.. :.....}:-: ....., ;. , ., c:!~ , ,::.' , .-. c~ '.. , '. '. r,-' - , ~ C !'.1 -' I ~j ...., -.". ...... , 0 ~ DEBORAH K. HILL. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v. : NO. 2001-2754 CIVIL TERM Defendant : CIVIL ACTION - LAW : IN DIVORCE LEVI HILL. AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~3301(c) of the Divorce Code was filed on May 7, 2001. ., The marriage of the 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4909 relating to unsworn falsification to authorities. ~~1~ J{y& D ORAH K. HILL. Plamtlff Date: 'if' - d4 -0 c;L WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. 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 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 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. ~ 4909 relating to unsworn falsification to authorities. Date: 7f'- d~.~;) ~y(7h DE ORAH K. HILL, Plamtiff ,. () C> n c ", "11 '!:: ". "'00_ e .1 !;2fT :n :J'J 1" , ..~.~ zC' ~"'. u:> . ;-j- ., ~:._~~ ;.::::C~ -0 ~O a..... ' ,-.::- ,.-1" , :i>O r:-:l -'-::' rrl C ~::1 ~ "-.) ?i:5 m -< DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : CIVIL ACTION - LAW Defendant : NO. 2001-2754 : IN DIVORCE LEVI HILL, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on May 7, 2001, reinstated on May 23, 2002, and service was made on May 23, 2002. 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. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 4> .;Z,(J-tJ.5 i\~)J-lLtl1l!. SI );t/ DE ORAH K. HILL, PlamtIff DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW Defendant : NO. 2001-2754 : IN DIVORCE LEVI HILL, AFFIDAVIT OF CONSENT I. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on May 7, 2001, reinstated on May 23,2002, and service was made on May 23, 2002. 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 FA~ STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa .S. 94904 REL TING TO UNSWORN FALSIFICATION TO THORITIES. ~:2J~;- DATE / DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW LEVI HILL, Defendant : NO. 2001-2754 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY QF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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 if! 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 THE FOREGOING AFFIDAVIT 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 F ALSIFICA TION TO AUTHORITIES. DATE: 4,d.O ~O-5~ ~ ) Q ~/~"J /I 'f '-6u3t 1. ,c/:'. C:, D ORAH K. HILL, Plamttff DEBORAH K. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW LEVI HILL, Defendant : NO. 2001-2754 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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 if! 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 904 ~O UNSWORN F ALSIFICA TI~N TO AUTHORITIES.) ,//.-/ DATE~ ~ 1,;;-/ EVI HILL, Defen DEBORAH K. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Defendant' : NO. 2001-2754 CIVIL TERM : IN DIVORCE LEVI HILL, PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under S3301(c) 33Gl(d)(I) of tile Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: certified mail/restricted delivery on May 23, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by S3301 (c) ofthe Divorce Code: by Plaintiff: June 20, 2005 by Defendant: June 25, 2005 (b) (I) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Oate of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: June 28, 2005 Date defendant's Waiver of Notice In 93301 (c) Divorce was filed with the Prothonotary: June 28, 2005 ~t\l\f\.nk ~ \)1\ I1\n.l\ - >.\lI\^~Q r. Hannah Herman-Snyder, Esquir GRIFFIE & ASSOCIATES Attorney for Plaintiff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "',+, ~;t; Of:f '+' '+' '+''+'+'+' '+''+''+''+''+''+''+''+''+''+''+''+''+''+''+''+''+' '+'+ ++. ;Ii..+.+.,+,+.+.+.+.+.+. ++.+.+.++.++++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++++ +. +++++ +. ++++++ +. ++++++++++++++? ." . . . . . . . . . . . . . . ;f.:t:;f.;Ii+ :t:;ti :+::of.:+: :+:;t; .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY DEBORAH K. HILL, STATE OF PENNA. . . . . . . . . Plaintiff No. 2001-2754 Civil Term VERSUS LEVI HILL, Defendant DECREE IN AND DIVORCE NOW.~ b ORDERED AND ..--- '~,ITIS DECREED THAT Deborah K. Hill , PLAINTIFF, AND Levi Hill , 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; i.)<t) Y\..9-- ? ,./ :J / .,/ J. '+''+':f. 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