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HomeMy WebLinkAbout04-4175F:Tsev Folda\Fim Docs\Gendoa\Gendocs2003\1088- I ldiv complain[.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBETTE N. HUNTER, Plaintiff V. CIVIL ACTION - LAW NO. 2004- 5173 FORREST W. HUNTER, Defendant 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBETTE N. HUNTER, Plaintiff V. CIVIL ACTION - LAW lope FORREST W. HUNTER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 7?d day of August, 2004 comes Plaintiff, Bobbette N. Hunter, by and through her attorneys, Hanft & Knight, P.C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Bobbette N. Hunter, who resides at 257 Allen Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Forrest W. Hunter, who resides at 1724 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for aperiod of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on March 10, 1989, in Boiling Springs, Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Sections 3301(c) of the Divorce Code of 1980, as amended. 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, HANFT & KNIGHT, P.C. Sean M. Shultz, Esquir Attorney ID No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 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 Complaint in Divorce and to the extent that the document 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. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Bobbette N. Hunter rzz? ? v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBETTE N. HUNTER, Plaintiff V, CIVIL ACTION - LAW NO. 2004-4175 FORREST W. HUNTER, Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this3a day of June, 2005, I, Sean M. Shultz, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Divorce filed in the above-referenced matter. The Complaint in Divorce was mailed on August 30, 2004, but actual service took place on September 4, 2004, by Defendant signing for a copy of the Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Forrest W. Hunter 1724 Walnut Bottom Road Carlisle, Pennsylvania 17013 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, KI\IIGHZ,& ASSOCIATES, P.C Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 ?ou?ce?ao?zoos?ioes-11 .Id Attorneys for Plaintiff ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed to: _ FDrfo W. µmnfr NU KJ OA0 8041YK U. A. Signature l 0 Agent X 0 Addressee B. Received by (Printed Name) C W pel vgry. D. Is delivery address different from hem 1? ? Yes if YES, enter delivery address below: 0 No 3. Service Type C A /1 0 CertMied Mail 0 Express Mail (A/f `C A ? Registered 0 Retum Recel t l (( ?3 0Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 2. 7003 3110 0004 5769 8440 flee 3811, February 2004 ' ` `. _ : ' Domestic Return Receipt C7 P v' ?, A Curtis R. Long Prothonotary office of the Protbonotarp . Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor L[ , !4 (1.-CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 - (717) 240-6195 • Fax (717) ')An 4c"