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HomeMy WebLinkAbout02-0454David Carl Hartman Plaintiff VS. Carol Ann Hartman Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : NO. : CIVIL ACTION - LAW : 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 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 grounds for divorce are 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: Office of the Prothonotary Cumberland County Court House One Courthouse Square Carlisle, Pennsylvania, 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THESE. 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, PA 17013-3387 717-249-3166 David Carl Hartman Plaintiff VS. Carol A. Hartman Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE COUNTI AND NOW comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows: Plaintiff is DAVID CARL HARTMAN, who currently resides at 1290 Old Mountain Road, Wellsville, PA 17365. 2. Defendant is CAROL ANN HARTMAN, who currently resides at 2101 Cedar Run Drive, Apt. 105, Camp Hill, PA 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 20, 1971. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised, Plaintiff does not desire counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce. DATE: January. 21, 2002 Respectfully submitted, 727 352 S. Sporting Hill Road Mechanicsburg, PA 17055 (717)737-2033 I verify that the statements made in this affidavit are tree 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. Oav~ Car~Ita. rtman, Plaintiff DAVID CARL HARTMAN PLAINTIFF ¥S. CAROL ANN HARTMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBEIII.&ND COUNTY, PENNSYLVANIA NO. 02-454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE BY MAIL PURSUANT TO PA. R.CP. 1920.4 (a) (B (ii) JAMES M. BACH, Esquire, being duly sworn according to law, deposes and says that he is the Attorney for PLAINTIF~F, and that he did mail a true and correct copy of a Complaint under Section 3301(c) of the Divorce Code of 1980, along with a Notice to Defend and Claim Rights, by registered/certified mail, remm receipt requested, deliver to addressee only, to the DEFENDAN~T, on ~ 2002. Attorney I.D. No. 18727 352 South Sporting Hill Road Mecharficsbu~g, PA 17050 717-737-2033 · 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 mailpiece, or on the front if space permits. 2. Article Number (Copy from service label) PS Form 381 1, July 1999 [ C. Signature -- 3. Sejwice Type I~,~ Certified Mail r=l ~p~ ~~ R~i~ ~ R~urn R~ for M~ha~i~ ~~ In~ M~I ~ C.O.D. 4. R~ ~iv~ ~ ~) ~ Yes Domestic Return Receipt 102595-99-M-1789 David Carl Hartman Plaintiff VS. Carol Ann Hartman Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 02-454 ._ : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE (1) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on January 29. ~002. (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, without formal notice of the intention to request entry of divorce decree. (4) 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. (5) 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. May 2, 2002 _ _ D ATE D A V'I'~D'~A RL HART1V[AN PLAINTIFF DAVID CARL HARTMAN Plaintiff VB · CAROL ANNHARTMAN Defendant IN THE dOURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-454 CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, Court for entry of a Divorce Decree: 1. GROUNDS FOR DIVORCE: Irretrievable breakdown under Section ( X )3301(c) or ( )3301(d)(1) of the Divorce Code. (Check applicable section.) 2. DATE AND MANNER of service of the Complaint: Certified mail, January 29, 2002. 3. COMPLETE EITHER PARAGRAPH Ca) or Cb). Ca) Cb) to the Date of execution of the Affidavit of Consent required by Section 3301(c)of the Divorce Code: By Plaintiff May 2, 2002; by Defendant May 2,2002 1. Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: 2. Date of service of the Plaintiff's Affidavit upon the Defendant: DATE: RELATED CLAIMS PENDING: NONE DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, a copy of which is attached, if the Decree is to be entered under Section 3301(d)(1)(I) of the Divorce Code: May 2, 2002 By: M. BACH, ESQUIRE Attorney I.D.# 18727 Attorney for Plaintiff 352 S. Sporting Hill Rd. MECHANICSBURG, PA 17050 (717)737-2033 IN THL COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE Of ~ PENNA. ................................................... P.1 a.in~t i£-f ........... Versus ..... CAROL-- ANN-.-I~AR-TMAN ..................................... ........................................... Defendant ~qo..92-454 X9 2002 DECREE IN DIVORCE AND NOW .... i~-'~.~.. ~ ................. ,~ .20n~., it is ordered and decreed that ..........D~,VJ;9. CA~L. ~RTMA~ .................. plaintiff, and ...................¢.AR0~...ANN-~ARTM~N .................. 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 .................................... '