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Home My WebLink About04-4211 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JENNIFER L. HUTCHISON Plaintiff CIVIL ACTION -LAW vs. NO. 04- 4,)/1 CIVIL TERM SHA WN D. HUTCHISON 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 in the Office of the Prothonotary, First Floor, Cumberland County Courthouse, Carlisle, Pennsylvania 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: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 Telephone number: (717) 249-3166 Toll Free (in PAl 1-800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JENNIFER L. HUTCHISON Plaintiff CIVIL ACTION -LAW VS. NO.04-"7'.lIl CIVIL TERM SHAWN D. HUTCHISON Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE PENNSYL VANIA DIVORCE CODE I. Plaintiff is Jennifer L. Hutchison, who currently resides at 90 Beechcliff Drive, Carlisle, Cumberland County, Pennsylvania since March 17, 2004. 2, Defendant is Shawn D, Hutchison, who currently resides at 1063 Monroe Street, Oberlin, Dauphin County, Pennsylvania since April 9, 1999. 3, 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 defendant were married on October 12,2002 at Mechanicsburg, Cumberland County, Pennsylvania 5, There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has 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. I veritY that the statements made in this Complaint 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: August 10,2004 S)~ Q.c?'~ David P. Perkins, Esquire Attorney for Plaintiff Attorney !D. No. 34342 4 James Circle Shippensburg, PA 17257-2165 Telephone: (717) 658-6531 ~ '- ~ " "- ~ ~~. ~ ~ (~ \ \{ ~ ~ ~ ~~ ~ ~ .z "t- ~ JENNIFER L. HUTCHISON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4211 CIVIL TERM vs. CIVIL ACTION--LA W SHAWN D. HUTCHISON, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, David P. Perkins, Esquire, do hereby certify that on this day Plaintiff's Complaint in Divorce was served by Certified Mail, restricted delivery addressee only upon the Defendant addressed as follows: Mr. Shawn D. Hutchison 1063 Monroe Street Oberlin, PA 17113 Date: August 27, 2004 C7)~ C? C?~ David P. Perkins, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, P A 17013 (717) 240-0296 JENNIFER L. HUTCHISON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4211 CIVIL TERM VS. CIVIL ACTIONnLA W SHAWN D. HUTCHISON, Defendant IN DIVORCE I . -_._---~_..._-.__._-_._-_.._-,._-.... -; 2. ..... r: ~I ......., PS Form 7003 0500 0003 7599 5995 ~-- .._-----~~- , U ~ j U ili U " I ; Ii ;;; Ii [ i ( ! Iii 102!5850Q2..M.1lS4O <;;.(.J,~, Lf1 IT'" IT'" Lf1 U.S. Postal Service," CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) IT'" IT'" Lf1 f'- HQS8Gh 17IU Postage $ $0.37 ~~ . Certified Fee $2.30 CJ Return RecJept Fee $1 .75 (Endorsement Required) Restricted Delivery Fee $3.50 o (Endorsement Required) Lf1 CJ TotaJPoslage&Fees $ $7.92 08/2712004 rTl ~ s:~~:Ef::~~l;f..C..h/'3:'~'S'f,.....--mm.....m -.........--...............m.....mL!lI/l::1._y.Q..m._......m..._._........... CHy. St''', ZIP+< I:... /,/'J / II :3 :11 ) ) , ~ ( l 1 \ "'~ 0 c:::> c:, -n ~- (/) ...., :r:: "T\ rr'1 rnr:.::. " rn f'.') CJ N () -T., -<:1 .. " , ~ C' -' l '-,' ( ...~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. HUTCHISON, Plaintiff : CIVIL ACTION -LAW vs. : NO. 04 - 4211 CIVIL TERM SHAWN D. HUTCHISON, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on August 24, 2004. 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. 1 consent to the entry of a final decree of divorce after service of notice of intention tD request entry of the decree. 1 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 relating to unsworn falsification to authorities. DatelJ "d.:J' ('f-/ --- ,......., ~~ en ~- .;:;1.. :.;.roc.: , w ," , " =r1 "" O.J - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. HUTCHISON, Plaintiff : CIVIL ACTION -LAW vs. : NO. 04 - 4211 CIVIL TERM SHAWN D. HUTCHISON Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on August 24, 2004. 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. fi 4904 relating to unsworn falsification to authorities. Date: i d . i" ' 0 4 , Shawn D. Hutchison, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. HUTCHISON, Plaintiff CIVIL ACTION -LAW vs. NO. 04 - 4211 CIVIL TERM SHAWN D. HUTCHISON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER g3301(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 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. & 4904 relating to unsworn falsification to authorities. Date: } a . a a .Cf-/ ennifer L. Hutchison, Plaintiff .-.;> 'c::::;~ ~~ c_ :'dC .,.4 ~( \"'\ ~ \ vJ - "" cO - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. HUTCHISON, Plaintiff CIVIL ACTION -LAW VS. NO. 04 - 4211 CIVIL TERM SHAWN D. HUTCHISON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301(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 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. q 4904 relating to unsworn falsification to authorities. Date: 1~'/b'Olf ~ .r1l~~., Shawn D. Hutchison, Defendant 1 '. JENNIFER L. HUTCHISON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO. 04-421 I CIVIL TERM SHAWN D. HUTCHISON, Defendant : IN DIVORCE PRAECIPE TO 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 S3301(c) of the Divorce Code. 2, Date and manner of service of the complaint: August 28,2004, certified mail. 3. Complete either paragraph (a) or (b), (a) Date of execution of the Affidavit of Consent required by S3301(c) of the Divorce Code: by Plaintiff on December 22, 2004; by Defendant on December 16,2004. (b)(1) Date of execution of the affidavit required by S3001(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff's 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 a copy of which is attached: A (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: January 3, 2005. Date Defendant's Waiver of Notice was filed with the Prothonotary: December 20, 2004. C))"""~ 0. G'-"vk~ David p, Perkins, Esquire Attorney for Plaintiff (_.... \ G) ,"" ~, ,- cP ,," " " " " " " " " " " " " " " " Of. :+;~ ;t; " " " " ;+::f.:f~ :f.'t: :f. :f.:f.+.:+;:+::t-;:f.:f.:f. :f.:f:f. :f.:f.:f.:f.:f.'l':f " " " " " " " " " " " " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. " " " " " " " " . CJ..J.ril Tf'!rm" " . . . . STATE OF " " . " . . . . " " " . JENNIFER L. HUTCHISON NO. 04-4211 Plaintiff VERSUS " SHAWN D. HUTCHISON . . " . " " " " " " . . . . " . " " . . . . " . " . . . . " . . . . Defendant DECREE IN DIVORCE AND NOW, 1"'" ty..,,,,, (J- S .iT ~:..), A"" , ;}DOS, IT IS ORDERED AND JENNIFER L. HUTCHISON , PLAINTIFF, DECREED THAT SHAWN D. HUTCHISON , DEFENDANT, AND 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 // ~ \ ATTESTO(.~~~ __._~. ~ROTHONOTARY . " . . . . . . .. + Of :f.:+::f. Of:+::+' + :f.:+: Of'+. :f.i+:'+':+: :+: 'l' '+:+: :f.'f.:f.:f. :f.:f.:+: '1'+ :f. :f.:+: " "" 'to,!,:f.;+; " " . :+: +:+::+: :+: . . . " . . . " . " . . . " " . . " . " . . . . . . . . . . . . . . " . . . . . " . . . . " . . . . " . . " . " . . . " h :2. I'f}.?,.w' ry,7V-" f,:(I~11 ~~ETY fj!:? ~ /f//~ ?kv7 r{lRlII I .' . ~ --