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Home My WebLink About05-3146 DOROTHY M. HAZZARD, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : CNIL ACTION - LAW L <.....- : NO. DS - 314b Ci(.)L' I tA.~ THOMAS J. ADAMS, 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 at the Cumberland County Courthouse, One 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 DOROTHY M. HAZZARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW I<=-- NO. OS" - c.,.U~\... I~ THOMAS J. ADAMS, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301(D) OF THE DIVORCE CODE AND NOW COMES the above named Plaintiff by her attorney, Gary L. Rothschild, Esquire, and seeks to obtain a decree in Divorce from the above named Defendant, upon the grounds hereinafter more fully set forth: COUNT I - DIVORCE 1. Plaintiff is Dorothy M. Hazzard, who currently resides at 9S Spruce Lane, Carlisle, Cumberland County, Pennsylvania 17013, having so resided since August 2003. 2. Defendant is Thomas J. Adams, who currently resides at the Bethesda Mission, Men's Center, 611 Reily Street, P.O. Box 3041, Dauphin County, Pennsylvania 17105, having so resided since June 2005. 3. Plaintiff and Defendant are sui juris and have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and Defendant were married on October 3,1996, in Cresson, Pennsylvania. 5. The 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. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there are no children ofthe parties. WHEREFORE, the Plaintiff prays your Honorable Court to: a) enter a Decree in Divorce from the bonds of matrimony , and b) such other relief as the Court may deem equitable and just. Respectfully submitted, ~ Date: ~l;;5 By: Gary . Rothschild, Esquire Supreme Court LD. No. 62041 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg,PA 17112 (717) 540-3510 Attorney for Plaintiff '. . VERIFICATION 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 unsworn falsification to authorities. ?A'-'#2J(();; / I , Date i0vt~,~,( ,J/~JA-L' Dor y M. HAzz ' x.)~ ~ \l 1I1 - ""Q. - (J ~ w ..c Vl ~ - ..c () ~ C> ~ ~ '-!. n f ,.., c'" c:::::. ,;.n 8 9n <--- 9"11 ~.~,~ r-t1 F:: ..,;.,.. _n(1i ~-:) .::) --J ;.-., 1 ::.~~; -0 ':~) ("'", '," Z',f't'l <i? \~~~ ~:b C) :--.;, -J - DOROTHY M. HAZZARD, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW : NO. 05 - 3146 CIVIL TERM THOMAS J. ADAMS, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Thomas .T. Adams, accept service of the Complaint In Divorce. I certify that I am authorized to accept service as I am the above-named defendant. L- ams Date: '7. ~.. o.z:; Bethesda Mission, Men's Center 611 Reily Street Harrisburg, Pennsylvania 17105 ....,.t '~~ d~li - 7',_ t.;:~ \ C/,;,' 0i~~ ".:1 ::.: () ~ ...., = = c.n <- c:: r o -n ~::o -oFn -n"i' t5C} ~i~ :~ 2~f! S ",. ~ ~ - .. "'" DOROTHY M. HAZZARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW : NO. 05-3146 CIVIL TERM THOMAS J. ADAMS, Defendant : IN DNORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(C) of the Divorce Code was filed on June 17, 2005. 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. 9 4904 relating to unsworn falsification to authorities. Date: 7t~, ) /'U / By: ,~~ #/ .:t~L Dorothy M. azzard, Plamtl o r'" ", ,-:::;', C-;"__) <::...q o -n :d rH -r; r ~"~tS (-j ). :l ~_J "-1; -'1-;; C;~ "e__ U1 -ry r",) .t:"" c:> ;','"51 ,. ,~~ .< DOROTHY M. HAZZARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW NO. 05-3146 CIVIL TERM THOMAS J. ADAMS, Defendant IN DNORCE ~ AIVER OF NOTICF. OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER & 3301 (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: lItUf. ~ IJ 'J ,- By: ~u~ -# ~~?~ Dorothy M. zard, Plain . ~'. '... r-> ~~ Sd UI -C' o -.n =2"\\ i:'n~~: --j ~:'-) 2-) i-il \') .. x- o DOROTHY M. HAZZARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW : NO. 05-3146 CNIL TERM THOMAS J. ADAMS, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301(C) of the Divorce Code was filed on June 17,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe 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. S 4904 relating to unsworn falsification to authorities. Date: JIIIJ q / uS / ,. BY:~~ Tho. . A arns, Defendant {~} c: ~"'.,'} c'..' r.~ c........ 7: c;-'~ .r,C;: C:A t.n -c:- 5 r<} -",/ 3, ~ c?' DOROTHY M. HAZZARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW NO. 05-3146 CNIL TERM THOMAS J. ADAMS, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301 Ie) 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: J l/t:,;: /- , By: CJ (~: s~ .-"? ~o\ ..-:'~. &;... ~?- q., -;:-~ .-'(1. :;:\\~:.. '~'0,;'~b ',I , -.,--) \"<>'.<;, , "-).'. <,,;:c:-, r\'~.\';> ',""")' T:-:~\ --.",,, '}J. -~ "(Yl, ~. ......'~ ~ r'~,) '.- ,,,;; o DOROTHY M. HAZZARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 05-3146 CIVIL TERM THOMAS J. ADAMS, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following infomlation, to the Court for entry of a Divorce Decree: 1. Ground for Divorce: 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Regular mail on June 20, 2005. Acceptance of service filed July 11,2005. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff 11/01/2005 ; By Defendimt 11/09/2005. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: 11/15/2005; Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: 11/15/2005. !lI.I ..-- Dated: 1/ tit') Gary, . Rot schild, Esquire 2215 Forest Hills Drive, Suite 35 Harrisburg, PA 17112 (717) 540-3510 Attorney for Plaintiff ~::,:j 0,) c~::..' (, ~~~~T.~T.~T.T.T.T.T.T.T.~~T.~T.T.T.~T.T.T.T.T.T.T.T.T.T.T.T.T.+T.T.+T.+T.+T.+T.+T.T.T.+T.T.T.T.+T.T.+++T.+T.T.T.T.T.T.T.T.T.T.T.T.T.~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . T. <+O;f<+O;+' IN THE COURT OF COMMON STATE OF Dorothy M Hrl7.7.rlrn. . Plaintiff VERSUS Thomas J. Adams. Defendant AND NOW, DECREED THAT AND PLEAS OFCUMBERLANDCOUNTY '~ PENNA. No. 05 - 3146 DECREE IN DIVORCE J~ "'''' -",--- z,cV'.> --' IT IS ORDERED AND Dorothy M. Hazzard , PLAINTIFF, Thomas J. Adams , 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; . . . . ++++T.+T.++++T.++T.T.T.T.T.T.T.T.+T.T.T.T.T.T.T.T.T.T.T.+++++++++T.T.T.T.T.T.T.TT.TT.TT.TT.T.TT.T.T.T.T.T.T.T.T.? None. . -', )/ By THE COURT:/I? ~/ <- J?:.J ATTESTa ~$,l ,r - PROTHONOTARY "- --- J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ h.? /fJ~'n# "yu; <;0 ') q 1fr7Ji1 if? .~. /'fr~/ ~?.pp 5'(/ t') C/ . ' . ,~: '