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Home My WebLink About05-1366 J. PAUL HINES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION : NO. ~ - /JI../... f..,(.),L ~~ vs. JESSICA J. HINES, : IN DIVORCE NOTICE TO DEFEND 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 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 the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013- 3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4th Floor Carlisle, PA 17013-3387 (7 I 7) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estats demandas expuestas en las paginas siquientes, usted tiene, veinte (20) dias de plazo al partir de lag fecha de las demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 Page I of2 por abogado y archival en la corte en forma escrita sus defensas 0 sus objecciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cuaiquier queja 0 alivio que es pedido en la peticion de demanda. usted puede perder dinero 0 sus propiedades ootros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SINO TIENEELDINERO SUFIClENTEDE PAGAR TAL SERVICIO, V A YAEN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4th Floor Carlisle, PA 17013-3387 (717) 240-6200 ~ ,..~%:::~ ..;/~;:.~--~~ ~~--_._._------_._-, ~....",,~~/e;;./?~:~._. Michael D. Rentschler, Esquire Attorney for Plaintiff Page 2 of2 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA J. PAUL HINES, vs. : CIVIL ACTION JESSICA J. HINES, : NO. Defendant : IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling, please advise in writing promptly by replying to: Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A 17013-3387. Prothonotary J. PAUL HINES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION JESSICA J. HINES, : NO. oS - 13f...r." CU-l-l ~ ~ Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiffis 1. PAUL HINES, an adult individual who currently resides at 9 Ritner Gardens, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is JESSICA J. HINES, an adult individual who currently resides at 9 Ritner Gardens, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui juris and both have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on June I, 2002 in Chambersburg, Franklin County, Pennsylvania. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction, with regard to this marriage. 8. The Plaintiff has been advised ofthe availability of counseling and ofthe right to request 1 that the Court require the parties to participate in counseling. COUNT I Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. II. After ninety (90) days have elapsed from the date ofthe filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 13. The prior paragraphs of this Complaint are incorporate herein by reference thereto. 14. The marriage of the parties is irretrievably broken. 15. The parties are currently residing together. However, it is contemplated that the parties will live separate and apart. When two (2) years have elapsed from the date of final separation, 2 Plaintiff will file his affidavit of having lived separate and apart, provided a divorce decree has not already been granted pursuant to Section 3301C of the Divorce Code. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, it is respectfully requested that this Court enter a Decree in Divorce, pursuant to Section 3301(d) of the Divorce Code. Respectfully submitted, LAW OFFICE OF MICHAEL D. RENTSCHLER, P.C. /~-Y~Z~--' Michael D. Rentschler, Esquire Attorney for Plaintiff Supreme Court LD. #45836 28 North 32nd Street Camp HilI, P A 17011 (717) 975-9129 3 VERIFICATION I, J. PAUL HINES, verify that the statements made in the Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 11 4904 relating to unsworn falsification to authorities. J. PAUL HINES, Plaintiff r ~ CERTIFICATE OF SERVICE I, MICHAEL D. RENTSCHLER, ESQUIRE, do hereby certify that on this date I served a copy of the foregoing Complaint in Divorce by Certified Mail, restricted delivery, return receipt requested to the following: Jessica 1. Hines 9 Ritner Gardens Shippensburg, P A 17257 Date: ..3 // L /6 5,- / / ~~~~-) MICHAEL D. RENTSCHLER, ESQUIRE Attorney for Plaintiff ~ :{s \:J Vl ~ .2:: CY ~ ~ Jd ::Q \ ., 1- 1- ?\l ("j '~;l ..~\ ~C ".." ~ ......... ( ,) 0' J. PAUL HINES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JESSICA J. HINES, Defendant : NO. 2005-1366 CIVIL ACTION - LAW : IN DIVORCE ACKNOWLEDGEMENT OF ACCEPTANCE OF SERVICE OF COMPLAINT IN DIVORCE I, Jessica J. Hines, acknowledge that a complaint in divorce under Section 3301 (C) of the divorce code was filed on March 16,2005 and that I accepted service of the Complaint in Divorce on March 20, 2005. I verify that the statements made herein 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. )g~:~~ 1{~~ J SSICA J. NES, Defendant ~ ..: g --> :::;; ?O I W -0 -,~,;; _\;:40 F3 ., o ~ :1 rn~ -0 t.O. :X!1--( t.~:\ (~? :,1~ 3:~ ',.~:.() iSfn -=-I --po ~ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA J. PAUL HINES, vs. : CNIL ACTION JESSICA J. HINES, : NO. 2005-1366 CNIL TERM Defendant : IN DNORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on March 16, 2005 and the Defendant accepted service of the Complaint on March 20,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final decree of divorce after service of a 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. S 4904 relating to unsworn falsification to authorities. Dated: 3~"/o? . I g~ J AULH ES, Plaintiff ~ s ~ -;A) , c.,...) -0 ~:::"# ~.,... ~ ~:n \ r::: -r"1 rr:" '0"1Y ?:)\b ~~:~, <Sf\" .-\ ~ ~ o - Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA J. PAUL HINES, vs. : CNIL ACTION JESSICA J. HINES, : NO. 2005-1366 CIVIL TERM Defendant : IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l(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! 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.A. g 4904 relating to unsworn falsification to authorities. Date: 3~~~/ , , ~ :3 '"P'" :-0 :;;0 1 W -u ~ B C> ~ .-\ ';f,:9 ';:'" :qd ~~ (J :::.\ ~ ~ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 1. PAUL HINES, vs. : CIVIL ACTION JESSICA J. HINES, : NO. 05-1366 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on March 16, 2005 and the Defendant accepted service of the Complaint on March 20,2005, as evidenced by filed acknowledgement of service of complaint in divorce. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree of divorce after service of a 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. ~ 4904 relating to unsworn falsification to authorities. Dated: 3\\lD \01 ~ . ~ ' ~-t" \,A1I~ J SSICA J. ES, Defendant o r- ....... ~"P "'-3 <:::::> <= ........ > .." ::::0 I W -0 ~:.: o "Tt i!..." m--- -oF;. ,=!< c;:.:) .-~O ,.J= :}.~l ;20 om ~~ ~ -< N .. a Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA J. PAUL HINES, vs. : CIVIL ACTION JESSICA J. HINES, : NO. 05-1366 CIVIL TERM Defendant : 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 fmal 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.A. ~ 4904 relating to unsworn falsification to authorities. Date: 07 ~-~ ~)J'().., J SSICA J. ES, Defendant ....., = = ~ :!O ;A:l I W ~ ~, "'T1 n r=~ -ntIl :(!~., ~-).C) ,;~~~ .~ ~ -0 -.,.,'" -S"'" ~ o Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA J. PAUL HINES, vs. JESSICA J. HINES, Defendant : NO. 2005-1366 : CNIL ACTION - LAW : IN DNORCE 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 Section 3301C of the Divorce Code. 2. Date and manner of service of the complaint: March 20, 2005 by acceptance of service 3. Date of execution of the affidavit of consent required by Section 3301 C of the Divorce Code: by plaintiff on March 16, 2007; by defendant on March 16, 2007. 4. Related claims pending: None, as all economic issues were resolved by Marital Settlement Agreement dated March 15, 2007. 5. Date plaintiff's Waiver of Notice was filed with Prothonotary: April 3, 2007. 6. Date defendant's Waiver of Notice was filed with Prothonotary: April 3, 2007. Respectfully submitted, ~~--- Michael D. Rentschler, Esquire Supreme Court I.D. #45836 28 N. 32nd Street Camp Hill, P A 17011 (717) 975-9129 1 ~ = ........J :P" -v ?J I W ~ -I :I::.-n rnp --m .".'.'Ci ~.~] ( ~;} ~:} {~~ ~ ~ -0 ~ .-:"i.... ~ o if. if. !f. if. if. !f. if. if. if. if. if. if. if. if. if. if. [Ii [Ii '" [Ii'" '" '" [Ii '" ",,,,[Ii if. '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. J. PAUL HINES No. 2005 136h VERSUS ,JRS~TrA.r HTNR~ DECREE IN DIVORCE AND NOW, ~/O e:J.1 ().' c) 1 J.""'. Jo07 , IT IS ORDERED AND DECREED THAT , PLAINTIFF, .J. PATTT. HTNR~ AND JESSICA J. HINES , 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; ALL PROPERTY ISSUES RESOLuED B ATTEST: ,'/ ~ J. ,h ~ PROTHONOTARY if. 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