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Home My WebLink About01-3498 WANDA L, HOLLAND, DEFENDANT NO, 01 - JI..J9P IN DIVORCE C~u~l~4 GOLDBERG. KATZMAN is. SHIPMAN. P,C, PAUL,J, ESPOSITO - I.D. #25454 ATTORNEYS FOR PLAINTIFF 320 MARKET STREET STRAWBERRY SQUARE P.O. Box I 268 HARRISBURG, PA 17 J 08- I 268 (7 I 7) 234-4 I 6 I BARRY F, HOLLAND, PLAI NTI FF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 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 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, CARLISLE. PENNSYLVANIA. 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, PA I 70 I 3 <7 I 7) 249-3 I 66 BARRY F. HOLLAND, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUN1Y, PENNSYLVANIA v, CIVIL ACTION - LAW WANDA L. HOLLAND, DEFENDANT NO. 0 J _ :3 (I q f IN DIVORCE WAIVER OF COUNSELING BARRY F. HOLLAND, BEING DULY SWORN ACCORDING TO LAW, DEPOSES AND SAYS: I . HAVE BEEN ADVISED OF THE AVAILABILITY OF MARRIAGE COUNSELING AND UNDERSTAND THAT I MAY REQUEST THAT THE COURT REQUIRE MY SPOUSE AND I TO PARTICIPATE IN COUNSELING, 2. I UNDERSTAND THAT THE COURT MAINTAINS A LIST OF MARRIAGE COUNSELORS IN THE OFFICE OF THE PROTHONOTARY. WHICH LIST IS AVAILABLE TO ME UPON REQUEST. 3, BEING SO ADVISED, I DO NOT REQUEST THAT THE COURT REQUIRE THAT MY SPOUSE AND I PARTICIPATE IN COUNSELING PRIOR TO A DIVORCE DECREE BEING HANDED DOWN BY THE COURT, I VERIFY THAT THE STATEMENTS MADE IN THIS WAIVER ARE TRUE AND CORRECT, 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. DATE: 6 - 3' -o~ ~~d:~L~N~~ GOLDBERG, KAUMAN &. SHIPMAN, P,C, PAUL.J. ESPOSITO - 1.0. #25454 ATTORNEYS FOR PLAINTIFF 320E MARKET STREET STRAWBERRY SQUARE P.O. Box I 268 HARRISBURG, PA 17 I 08- I 268 (7 I 7) 234-4 I 6 I BARRY F, HOLLAND, PLAINTIFF IN THE COURf OF COMMON PLEAS CUMBERLAND COUN1Y, PENNSYLVANIA v, CIVIL ACTION - LAW WANDA L. HOLLAND, DEFENDANT Q " NO. (.>1- 34 1) IN DIVORCE ~ lhA- COMPLAINT IN DIVORCE I . BARRY F. HOLLAND, IS AN ADULT INDIVIDUAL, WHO CURRENTLY RESIDES AT 659 CUMBERLAND POINT CIRCLE, MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA, 2. DEFENDANT, WANDA L, HOLLAND. IS AN ADULT INDIVIDUAL WHO CURRENTLY RESIDES AT 1949 MULBERRY STREET, HARRISBURG, DAUPHIN COUNTY, PENNSYLVANIA, 3. PLAINTIFF AVERS THAT HE HAS BEEN A BONA FIDE RESIDENT IN THE COMMONWEALTH OF PENNSYLVANIA FOR A PERIOD OF AT LEAST SIX (6) MONTHS PREVIOUS TO THE FILING OF THIS COMPLAINT. 4. THE PARTIES WERE MARRIED ON APRIL 24. 1983. IN DAUPHIN COUNTY, PENNSYLVANIA. .. 5, THERE HAVE BEEN NO PRIOR ACTIONS OF DIVORCE OR ANNULMENT FILED BY EITHER OF THE PARTIES HERETO, 6, PLAINTIFF HAS BEEN ADVISED OF THE AVAILABILITY OF COUNSELING AND THAT PLAINTIFF HAS THE RIGHT TO REQUEST THAT THE COURT REQUIRE THE PARTIES TO PARTICIPATE IN COUNSELING. 7, THE DEFENDANT IN THIS ACTION IS NOT PRESENTLY A MEMBER OF THE UNITED STATES ARMED FORCES OR OF ANY OF ITS ALLIES. 8. PLAINTIFF REQUESTS THE COURT TO ENTER A DECREE OF DIVORCE. COUNT I 9. THE AVERMENTS OF PARAGRAPHS THROUGH 8 HEREIN ARE HEREBY INCORPORATED BY REFERENCE THERETO, 10. THE MARRIAGE IS IRRETRIEVABLY BROKEN. COUNT II I I THE AVERMENTS OF PARAGRAPHS THROUGH 10 HEREIN ARE HEREBY INCORPORATED BY REFERENCE THERETO. I 2. THE AVERMENTS OF PARAGRAPHS THROUGH I 2 HEREIN ARE HEREBY INCORPORATED BY REFERENCE THERETO, 13. PLAINTIFF AND DEFENDANT HAVE ACQUIRED PROPERTY, DURING THEIR MARRIAGE UNTIL THE DATE OF THEIR SEPARATION. WHICH PROPERTY IS MARITAL. J 4. PLAINTIFF REQUESTS THIS COURT TO PRESERVE HER RIGHT TO HAVE ALL MARITAL PROPERTY OF THE PARTIES EQUITABLY DISTRIBUTED. WHEREFORE, PLAINTIFF PRAYS YOUR HONORABLE COURT TO: (A) ENTER A DECREE IN DIVORCE, DIVORCING THE PLAINTIFF FROM THE BONDS OF MATRIMONY HERETOFORE EXISTING BE1WEEN PLAINTIFF AND DEFENDANT; (B) ORDER EQUITABLE DISTRIBUTION OF MARITAL PROPERTY; AND (C) ORDER SUCH OTHER RELIEF AS THE COURT DEEMS ,JUST AND REASONABLE. RESPECTFULLY SUBMITIED, BY GOLDBERG, KATZMAN & SHIPMAN, P,C. /J ~'- /-. /' ,jatd;</ 1 ej~l/I PAUL ,J/i ESP SITO. ESQUIRE 320 fiARKet STREET POST OFFICE Box 1268 HARRISBURG, PA 170 18-1268 SUPREME COURT 10 #25454 ATIORNEYS FOR PLAINTIFF VERIFICATION I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief I understand that false statements contained herein are made subject to the penalties of18 Pa.C.S, Section 4904 relating to unsworn falsification to authorities. Date: :J -2>\ -b \ t,~~ l+~~ BARR HOLLAND (J Ti1t en :::- b! "-> c..., V) ~ -G -.J::. '-.. - ..o.......~ AJ en en v lf1 () ~ C) c V -u r~ ~ ~. ~\9 ~ - ~ lrt~ \) '"'( c C> v-; os 1- o C' C ?~ ~ "V 1:,,' -;.,:'. c.;: "- \.' ~-~... ~" i!)~:~ ~C) -1':) ~(-) ~_... 1:c:-c> ~? 7'c. z - 2. (~ ""(2: r',! "':".\."e -"'7 -I.....;J ~"1 ~ Goldb.:rg, Katzman & Shipman, P.c. Paul J. Esposito, ES4uir~ - 1.0. u25454 320 Markd Str.:d Post Office Box 1268 Harrisburg, P A 17108-1268 Attorneys for Plaintiff BARRYF, HOLLAND, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 01-3498 Civil Term WANDAL. HOLLAND, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF SERVICE COMMONWEAL TH OF PENNSYLVANIA ) ) ) SS: COUNTY OF DAUPHIN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, PAUL J ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on June 7, 200 I, he sent a certified copy of a Complaint in Divorce by certified mail, return receipt requested, restricted delivery, to Wanda L. Holland, 1949 Mulberry Street, Harrisburg, P A 17104, and the return receipt card signed by Wanda Holland, and shown as being delivered June 20, 2001, is attached hereto and made a part hereof. /"'1 ,&?r 1..' i .' ".?/ /, / C;{' v,o...L{. / t ';'~1I-'I- uti PAUL 1. ESPOSITO, ESQUIRE Sworn to and subscribed before me this 2nd Notarial Seal Victoria Y. Chambers, Notary Public Harrisburg, Oaul?hin County My Commission ExpIres Apr. 7. 2003 My Commission E ..,. .. . 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, 1. Article Addressed to: ~. ~~ l, \+D\ \().J\O \ql..\ q {'i)W'oemj ~. \~~I f1\ \rIO'4 3 Service Type ~ Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C,O.D. 4, Restricted Delivery? (Extra Fee) Yes 2, Article Number (Copy from service labeO ,DQq -3'-\0()- CtOd--''X:J 84..;. 4D7(..., PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 o ~ ~ iY ('OJ r y-, - . . <Y- eP ) . ~.~ ~:,i -<. ~ ~ .. ""-" c Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel For Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLLAND Plaintiff v. NO. 01-3498 Civil Term WANDA L. HOLLAND Defendant CIVIL LAW - DIVORCE PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Theresa Barrett Male, Esquire on behalf of the Defendant in the above-captioned action, L~~ 'Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Defendant Date: July 31, 2001 a ~ ,::. ~ J::.. CS"' -.::::. :> . . , Paul 1. Esposito, Esquire to. #25454 GOLDBERG, KATZMAN & SHIPMAN, P.c. 320 Market Street P. O. Box 1268 Harrisburg, PAl 71 08-1268 (717) 234-4161; (717) 234-4161 (facsimile) Counsel for Plaintiff BARRY F, HOLLAND, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3498 Civil Term WANDA L. HOLLAND, Defendant CIVIL ACTION - LA W IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about July, 2000, and have continued to live separate and apart for a period of at least three 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. Section ~ <-:::::::::.:s- o (,N sIj (\., ;-." - 01 - , . N -:-0 ~ o ~--: f " t MAR 1 0 2004 ~ Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Petitioner COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLAND Plaintiff v. NO. 01-3498 Civil Term WANDA L. HOLLAND Defendant CIVI L ACTION - DIVORCE ORDER OF COURT AND NOW, March 1"2- r 2004, upon consideration of the foregoing petition, the Court ISSUES a Rule on plaintiff and defendant to show cause why the petitioner is not entitled to the relief requested. The Rule is returnable within ten (10) days of service. BY THE COURT: Distribution: Aaul J. Esposito, Esq., P.O. Box 1268, Harrisburg, PA 17108-1268 vWanda L. Holland, 1949 Mulberry St., Harrisburg, PA 17104 ~heresa Barrett Male, Esq., 513 N. Second St., Harrisburg, PA 17101 ~~ 03--:fo" f L :'1 U_! {'J .: ; 'IlllOliZ .' l, ~ i" ,f.... '::'j r Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Petitioner COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLAND Plaintiff v. NO. 01-3498 Civil Term WANDA L. HOLLAND Defendant CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, March 2004, the Court GRANTS Theresa Barrett Male, Esquire, leave to withdraw as counsel for Defendant in this proceeding. BY THE COURT: J. Distribution: Paul J. Esposito, Esq., P.O. Box 1268, Harrisburg, PA 17108-1268 Wanda L. Holland, 1949 Mulberry St., Harrisburg, PA 17104 Theresa Barrett Male, Esq., 513 N. Second St., Harrisburg, PA 17101 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Petitioner COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARRY F. HOLAND Plaintiff v. NO. 01-3498 Civil Term WANDA L. HOLLAND Defendant CIVIL ACTION - DIVORCE PETITION FOR LEAVE TO WITHDRAW AS COUNSEL 1. Defendant retained Petitioner to represent her in this proceeding. 2. On March 2, 2004, Defendant informed Petitioner that Defendant is terminating the representation. Wherefore, Petitioner respectfully requests the court to grant her Petition to withdraw as counsel for Defendant. ~Ac<<If-~ Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 Petitioner Date: March 5, 2004 PROOF OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R.C.P. 440: Service by first-class mail addressed as follows: Paul J. Esposito, Esquire 320E Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Plaintiff Wanda L. Holland 1949 Mulberry Street Harrisburg, PA 17104 Defendant l~ I~-c( A,,- Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Petitioner Date: March 5, 2004 ------- ----- r-' C'::) = .:::- -~ o -n --..; :T~ :D r. t c-- rn y c':) :.f-~ 5-') I c:> --;-'} :J~ (J1 1"'.,) BARRY F. HOLLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-3498 WANDA L. HOLLAND, Defendant : CIVIL LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please enter the appearance of Marianne E. Rudebusch, Esquire on behalf of the Defendant in the above referenced matter. Respectfully Submitted, Dated: ~\ III I \'-1 ' \ ;l\\G0C&"'.-A--{ It \2w:)Qc, "--'~ Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PAl 71 09 (717) 657-0632 Id. No. 63522 WITHDRAWAL OF APPEARANCE Please withdraw the appearance of Theresa Barrett Male, Esquire on behalf of the Defendant in the above referenced matter. Respectfully Submitted, Dated: ~)Yjc~f -""\ / "> . /'7 L,~ GM>itr I:L- Theresa Barrett Male, Esquire 513 North 2nd Street Harrisburg, P A 17101 (717) 233-3220 Id. No. 46439 C) (~ . t--) (;:~ '-':'-'.:> 1".... , , .on - _"J _.:~.l r;? C\ ~~-."._-~-_.__.~-~-