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Home My WebLink About01-4873CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~ IN DWORCE NOTICE TO DEFF. ND AND CI ,AIM 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 divome 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 Cumberland County Courthouse, Carlisle, Pennsylvania. 1F 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 (717) 249-3166 Anthony L. DeLuca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE Plaintiff is Christina S. Seifert, who currently resides at 156 Brindle Road, Mechanicsburg, Cumberland County, Pennsylvania, since August 9, 2001. 2. Defendant is Johnno R. Hills, who currently resides at 6 Anmdel Street, Maidstone, Kent ME 14-2RS United Kingdom since June, 2001. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were mamed on March 24, 2000 at Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no pr/or actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the paxties to participate in counseling. 8. Plaintiffrequests the court to enter a decree of divorce. I verify 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 unswom falsification to authorities. · a S. Seifert, Phinti~i' ' Z//- · ~)le~a, Esquire . -~ Attorney for Pl~ntiff 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 u T < VS. In the Court of Common Pleas of Cumberland County, Pennsylvania No. ~--~ Z'- ¢?'>7..? Civil. 19 Pro~honomry - - --"~Attorney for Plaintiff - No. Term, 19 ~ Filed PRAECIPE 19__ · Atty. CHRISTINA S. SEIFERT, Plaintiff VS. ~OI-I~O R. HILLS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DWORCE ACCEPTANCE OF RF. RVICF In accordance with R CP. 19104 id), I, Johnno R. Hills, Defendant in the above-captioned action in divome, do hereby voluntarily accept service of the Complaint filed to the above- captioned action and acknowledge receipt of a copy thereof. Jo~ - Date of Acceptance of Service: ~a"(~}--,,m:~2~_~ I [,(~,4,--r'. ~_4~ ~ Mailing Address CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-4873 : IN DIVORCE AFFIDAVIT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Christina S. Seifert, Plaintiff CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW : NO. 01-4873 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: Christina S Seifert, Pl~in-tifff CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. HILLS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01-4873 : IN DIVORCE AFFIDAVIT OF MAD' JNG COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND : Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says that he mailed by REGISTERED LETTER, a tree and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Defendant at his residence and that Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A". Sworn to and s,u2~bed before me this dr day of ~t,~, 2002. ' ~jqotary~etib-lic - - I ,~O~?~UAFIJORIEI~A.TI~aL SEAL ] [ M~d~ ~wp., ~m~ ~ / By: Anthony L. D~'~ca, Esqmre 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 CHRISTINA S. SEIFERT, Plaintiff VS. JOHNNO R. Hlt.LS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01-4873 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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 ifI 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 Prothonota~. 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 unswom falsification to authorities. Date: J~R.~II[, Defendant CHRISTINA S. SEIFERT, Plaintiff J~HNNO R. HILLS, VS. Defendant IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 01-4873 CIVIL TERM 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 §3301 (c) X~l~:][~(~; of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: October 2001 by Registered Mail. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff July 8, 2002 ; by defendant July 27, 2002 (b) (1) Date of execution of the affidavit required by §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 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 §3301 (c) Divorce was filed with the Prothonotary: July 8, 2002 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: August 5, 2002 Att~l~ey for Plaintiff / Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNtY STATE OF .~. PENNA. SEIFERTw CHRISTINA S. Plaintiff VERSUS JOHNNO R. HILLS, Defendant NO. 4873 2001 DECREE IN DIVORCE AND NOW, DECREED THAT CHRISTINA S. SEIFERT , ~_o~ it is orDeRED AND , PLAINTIFF, , DEFENDANT, aND JOHNNO R. HILLS ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISD{CTION 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 THe COURT: ///~ //7 / I - PROT~ON~I'TAr~