HomeMy WebLinkAbout04-4747KATHY G. HUNTER,
Plaintiff
VS,
TAB A. HUNTER,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION- LAW
NO. 2004- ~7~/7
CIVIL TERM
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
foregoing 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 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 at;
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
KATHY G. HUNTER,
Plaintiff
VS,
TAB A. HUNTER,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2004- CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, KATHY G. HUNTER, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is KATHY G. HUNTER, an adult individual who currently resides at
120 South 15~' Street, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is TAB A. HUNTER, an adult individual who currently resides at
1340 Mountain Road, Dauphin, Dauphin County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Commonh
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 15 September 1999 in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
(unswom falsification to authorities).
KATHY G. HUNTER
Plaintiff
VS.
TAB A. HUNTER
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.I~_~
IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counteraffidavit within twenty (20) days after this affidavit has been served on you or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. The parties to this action separated on 1 September 2002 and have continued to
live separately and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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.
KATHY G. HUNTER, )
PLAINTIFF )
)
)
)
)
TAB A. HUNTER, )
DEFENDANT )
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2004-4747 CIVIL TERM
DIVORCE
ACCEPTANCE OF SERVICE
I, TAB A. HUNTER, hereby accept service of the following documents in the above
matter:
A.
B.
A copy of the Divorce Complaint; and
The Plaintiff's Affidavit under Section 3301 (d) of the Divorce
Code; and
C. The Defendant's Counter-Affidavit under Section 3301 (d) of the
Divorce Code;
I acknowledge receipt of a copy of all of those documents and accept service of them.
Date: ,~/?/~ ~
TAB A. HUNTER ~'' b7
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Defendant
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KA THY G. HUNTER,
Plaintiff
vs.
CIVIL ACTION - LAW
NO. 2004-4747 CIVIL TERM
TAB A. HUNTER,
11\1 DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
21 September 2004 and served upon the Defendant on or about 7 October 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the complaint
on the Defendant.
3. I consent to the entry of a final decree in divorcl~ either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANiA
KATHY G. HUNTER,
Plaintiff
vs.
CIVIL ACTION - LAW
NO. 2004-4747 CIVIL TERM
TAB A. HUNTER,
iN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1. 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 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 Waiver are true and correct. I understand
that false statements herein are subject to the penalties of '18 Pa. C.S. Section 4904 rf'llating
to unsworn falsification to authorities.
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KATHY G. HUNTER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2004-4747 CIVIL TERM
TAB A. HUNTER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 {c} of the Divorce Code was filed on
21 September 2004 and served upon the Defendant on or about 7 October 2004.
2. The marriage of Plaintiff and Defendant is irretri,avably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the complaint
on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
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KATHY G. HUNTER,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2004-4747 CIVIL TERM
T AS A. HUNTER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO FtEQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 leI OF THE DIVORCE CODE
1. 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 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 Waiver are true and correct. I understand
that false statements herein are subject to the penalties of '18 Pa. C.S. Section 4904 relatirlg
to unsworn falsification to authorities.
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KATHY G. HUNTER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2004-4747 CIVIL TERM
TAB A. HUNTER,
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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceptance of Service filed bv Plaintiff's
counsel indicatino service on or about 7 October 2004.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Constmt required by Section 3301
(c) of the Divorce Code: By Plaintiff: 27 Januarv 2005 By Defendant: 19 Januarv
2005
lb) 11) Date of execution of the Affidavit required by Section 3301 (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 lbl:
la) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is
attached:
(b). Date Plaintiff's Waiver of Notice in Section 3301 Ie) Divorce was filed
with the Prothonotary: Dated 27 Januarv 2005 and filed contemporaneously
herewith. Date Defendant's Waiver of Notice in Section 3301 Ie) Divorce was filed
with the Prothonotary: Dated 19 January 2005 and filed contemporaneously
herewith.
Date: 27 January 2005
'By..
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s~. Andes
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
KATHY G. HUNTER,
Plaintiff
VERSUS
TAB A. HUNTER,
Defendant
NO.
PEN NA.
2004-4747
DECREE IN
DIVORCE
NOW'iP~
AND
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DECREED THAT
KATHY G. HUNTER
AND
TAB A. HUNTER
2005 , IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLl_OWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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