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Home My WebLink About01-3460 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF JAMES A. HANSARICK Plaintiff VERSUS ANGELA M. HANSARICK Defendant PENNA. No. 01-3460 DECREE IN DIVORCE AND NOW, C9 ~JlL l-) 2-t..A>t , IT IS ORDERED AND DECREED THAT JAMES A. HANSARICK , PLAINTIFF, AND ANGELA M. HANSARICK , 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; NONE // ';' BY THp COURT: /' // / .. .....] -",/, .~ 1 PROTHONOTARY ~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ J. _~ .% ~n' ~.t, 'oie-,~ ~I j!' ~ ~ APi! /'9 /!7tr?' - - - JAMES A. HANSARICK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION ANGELA M. HANSARICK, Defendant NO. 01-3460 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: bre~breaksQ~&e~~>>Siax~ 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: United States Mail, Certified, return receipt requested, addressed to Defendant and received by her on June 7, 2001. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff ; by defendant (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: June 5, 200l. (2) Date of filing and service of the plaintiff's affidavit upon the respondent: June 7, 2001. 4. Related claims pending: To date, Counter-Affidavit not filed by Defendant. Spousal support to Wife denied and child support increased at support conference on October 18, 2001. 5. 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: Certified mail delivered to Defendant on September 24, 2001. Attached is this writer's letter, a copy of the notice of intention to request entry of section 3301 Cd) decree and the 3301 Cd) Counter~Affidavit sent by certified (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with mail. the Prothonotary: Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: r k!dt~ tJ ~ Attorney for P, tiff.' QQf8Jl88;t ----- Q ~;- -0(:; t-r1 ~, ~~~, :L~ "'" ?; 7~~; ~C r _'~ ~ ;.....~ -- -"') ..:.::) >\ ~,..,; f'--' -Q ::.0- 'F3 .. ~ WILLIAM A. YOCUM ATTORNEY AT LAW 3001 MARKET STREET CAMP HILL PA 17011 AREA CODE 717 TELEPHONE 761-5041 September 21, 2001 Angela M. Hansarick 45 Noble Street Kutztown, PA 19530 Re: Divorce Dear Mrs. Hansarick: Enclosed is a Notice of Intention to Request Entry of a Section 3301 (d) divorce decree which is self explanatory. Also enclosed is a Counter Affidavit form under Section 3301 (d) of the Divorce Code which I am required to forward to youi Very truly yours, Vd~"a.~ William A. Yocum JAHES A HANSARICK Plaintiff HI TH~ COURT OF CONNON PLEAS ~UMnERLANDCOUNTY, PENNSYLVANIA v. NO. 01-3l160 ANGELA M. llANSARICK Defeildant CiVIL ACTION- LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to tile Section 3301 (d) affidavit. Therefore, on or after October 16, 2001 ,the other party can request the court,to enter a final decree in divorce. If you do not file with the Prothonotary uf the Court au answer with your signature notarii~d ~r verified or a counter-affidavit by tile above date, the Court can enter a final decree in divorce. A counter-affidavit which yuu may file with the Prothonotary of the Court is attached to LIds notice. Unless you have already filed witll the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce ami you will lose forever the right to ask for economic relief. The filing of the '. ". . form counter affidavit alone ooes not protect your ecunomic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAHYER AT ONCE. IF yOU DO NOT HAVE A LA\.fYER OR CANNOT AFFOIUJ ONE, GO TO OR l'ELEl'Il0NE Tim OFflCESET FORTH BELOH TO FIND OUT WHERE YOU CAN GET LEGAL BELl'. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty avenu~ Carlisle, PA l70~3 (717) 249-3166 1-800-990-'-9108 'I.' 12 4 ~)J.J!lt't1-!L. Ii. __f{414'1 William A. Yoc'um (; L Attorney for Plaintiff 0 c' C ~ a L' r-l .~ rn f;'t"l -~ : ....". -, .4- ('...) Z ~-,- (/~ r".,) -~ ~ ~ " l.:'~ () ..."",.. .e:.. C 5 .'-J (,,_._1 c:: '. , L ,::;> d_~; :< en =< JAMES A. HANSARICK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3460 ANGELA M. HANSARICK, Defendant CIVIL ACTION - LAW IN-DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic reliefwhich may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-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: PlaintiffIDefendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. JAMES A. HANSARICK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01- ']l.((P() ANGELA M. HANSARICK, Defendant CIVIL ACTION - LAW 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 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, 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, P A 17013 (717) 249-3166 1-800-990-9108 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0), 3 <fit, 0 0.VJ-r~ JAMES A. HANSARICK, Plaintiff ANGELA M. HANSARICK, Defendant CIVIL ACTION - LAW IN-DIVORCE FIRST COUNT COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. The Plaintiff is JAMES A. HANSARICK, who currently resides at 2805 Yale Avenue, Camp Hill Borough, Cumberland County, Pennsylvania, since Year 2000. 2. The Defendant is ANGELA M. HANSARICK, who currently resides at 9727 Red Road, Stoney Run, Berks County, Pennsylvania, since February of2001. 3. The Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediate previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 10, 1997, at Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. Being so advised Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 8. Plaintiff requests the Court to enter a decree of Divorce. COUNT II IRRETRIEVABLE BREAKDOWN UNDER SECTION 3301 (d) 9, The Plaintiff incorporates by reference hereunder Paragraphs 1 through 8 hereinbefore set forth. 10. The marriage is irretrievably broken and the parties have lived separate and apart for a period in excess of two years prior to the date of the filing of this Complaint. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree of Divorce from the bonds of matrimony. I, JAMES A. HANSARICK, hereby verify that the statements made of 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. Date: Jtt h~ ~J ;JO(7) I 'J~~ /4', /~A William A. Y oculn, Attorney for Plaintiff 3001 Market Street Camp Hill, PA 17011 (717) 761-5041 I.D.# 06263 Page 3 of 3 JAMES A. HANSARICK, PlaintifT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. (i / - "5 4 6~ c; ANGELA M. HANSARICK, Defendant CIVIL ACTION - LAW IN-DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my 4' economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.S4904 relating to unsworn falsification to authorities. Date: Plaintiff/Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE TIDS COUNTER-AFFIDAVIT. o c> ~ -ot,r) Iii f' -;I' -....-. ~.(~:< If) , ::..:: .~~ r::: (--', """,~-' -p z.C --C. J:> c:. -/ ~ - ,- ..,,>~ ....... I C;P ,r'1 q (~) -.'(} ~ ~ 'i c--} (::.,,"'f\ ~ ~ ::< ~'l.l \.D ::- (.0 -------------------- JAMES A. HANSARICK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-3460 ANGELA M. HANSARICK Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, WILLIAM A. YOCUM, attorney for the Plaintiff, do hereby certify to the service of a true and correct copy of the Plaintiff's Complaint in Divorce, an Affidavit under Section 3301 (d) and a Counter-Affidavit under Section 3301 (d), which were deposited in the United States Mail, certified, return receipt requested, addressed to Angela M. Hansarick on June 6 , 2001 and received by the Defendant on June 7 , 2001. June 8, 2001 If' IN' /) / ' /2 .vttt-{vl..., /7. tr-rZ: /1/ ^---- William A. Yocum,/Attorney for Plaintiff u.s. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) U"J U"J ru ru I KEMPTON PA 19529 1 Postage $ $0.55 Certified Fee fl.90 0011 22 Postmark Return Receipt Fee $1.50 Here (Endorsement Required) F~estricted Delivery Fee $3.20 (Endorsement Required} Total Postage & Fees $ $7.15 06/0612001 cO ..JJ ru ....=I cO ru CJ CJ CJ CJ ..JJ CJ Recipient's Name (Please Pnnt Clearly) (to be completed by mai'er) ,_ _ _ Allg ~:L? _ ,li. _Hans a r i c k Street, Apt, No" or PO Box No.mmnm-mmm'nn _mn_9.Z_2LnRed Road City, State, ZIPtrn-nmm--mn---m- Stoney Run, PA 19529 " CJ CJ CJ l'- :.. A. .11 o ~ ." ~lF~~'. :i:. ::, ~t z ..-., -< , C) S=: ..-_.~ ."r.;...- :.,,) ,:.-\ ~ :::> t-,;; -------- .~ .SENDER:- :2';':. Complete items 1 and/or 2 for additional services. Ul .. Complete items 3, 4a, and 4b, Q) . Print your name and address on the reverse of this form so that we can return this ~ ~m~ ft ~ . Attach this form to the front of the mailpiece, or on the back if spa.ce does n E Q) perm,\. ... . Write "Return Receipt Requested" on the mailpiece below the article number, ~ . The Return Receipt will show to whom fhe article was delivered and the date - delivered. I also wish to receive the following services (for an extra fee): trp.Cf\Jdress ~~ri~e~very t r for fee, ai o .::; ... Q) l/l 3, Article Addressed to: Angela M. Hansarick 9727 Red Road Stoney Run, PA 19529 4a, Article Number :tJ 4b, Service Type D Registered D Express Mail D Return Receipt for Merchandise 7, Date of Delivery ~ertified o Insured D COD 8, Addressee's Address (Only if requested and fee is paid) . 7(tJ/ is - ::::I o >- .lO: c: III .r I- 102595,98-8,0229 Domestic Return Receipt Ui\iITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid USPS Permit No, G-10 . Print your name, address, and ZIP Code in box · William A. Yocum, Esquire 3001 Market Street Camp Hill, PA 17011 2~ . 11I,/lLillli'Il,IIIl,iLII,L!'llIL,III'!II1I1'IIII1,lIl1i JAMES A. HANSARICK , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 0/- pL;(P{) ANGELA M. HANSARICK, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, WILLIAM A. YOCUM, attorney for the Plaintiff, do hereby certify to the service of a true and correct copy of the Plaintiff's Notice ofIntention to Request Entry of a Section 3301(d) divorce decree and a Counter-Affidavit under Section 3301 (d) which were deposited in the United States certified mail, return receipt requested on September 21,2001 and received by the Defendant on September 24, 2001.. OcftlbPt- 4; 2P Cl ( / . ~~ t?j,P~ William A. Yocum, orney for'1>laintiff u.s. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) cO ...J] ru H I KUTZTOWH PA 19530 I Postage $ $.0.57 Certified Fee JZ.IU 0011 09 Postmark Return Receipt Fee $.1.50 Here (Endorsement Required) Restricted Delivery Fee $.0.00 (Endorsement Required) Total Postage & Fees $ H.17 0912112001 cO .:r ru ru cO ru CJ CJ CJ CJ -D Recipient's Name (Please Print Clearly) (to be completed by malferJ CJ ....A~KeJ!'l...1':1...,.J:I.~g,l?,~;rJ~J<,.,., ",.",."..,..".,.,., Street, Apt, No,; or PO Box No. g 45 Noble Street CJ 'city: siaie:ziP~4"'''''''''''''''''''''''''''''' I"-- Kutztown PA 19 . . a. AI. .. ( -- ~~ ~.; -"; -, r:? r:"" II> ~-,- . '-'__W"'- ,,';, .1~ "_', ."'_ "~...,,>,,.. UNITED STATES POSTAL SERVI ..... ,\ ..cl 0- ~..'..".~'" . Print your a~@dgress, and 2!I'f>'~od&inthi~-~-. _ ~ l';\'ill. ."";i'..~....;__,...;".,"_,..,....,,,.. "',..~_. William A. Yocum, Esquire 3001 Market Street Camp Hill, PA 17011 2~ I i 1'1 "1 ,'\ II I II I I lj I 'I Ii I! , 1i!!1 !!dl 1l!1i! III I!I!! !II i!1!!ll nil llIHII!! lHI ~ SENDER: 't:I . Complete items 1 and/or 2 for additional services, 'iij . Complete items 3, 4a, and 4b. Gl . Prinf your name and address on the reverse of this form so that we can return this ~ card to you, > . Attach this form to the front of the mailpiece, or on the back if space does not Gl permit. .. . Write "Return Receipt Requested" on the mailpiece below the article number, ~ . The Return Receipt will show to whom the article was delivered and the date ..., delivered. c: o 't:I Gl Qj 0.. E o o I also wish to receive the 1011 owing services (lor an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery Consult postmaster for fee, 4a, Article Number ?O. 4b, ervice Type o Registered D Express Mail o Return Receipt for Merchandise 7. Date of Delivery 3. Article Addressed to: Angela M. Hansarick 45 Noble Street Kutztown, PA 19530 JAMES A. HANSARICK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. (J)- 3 4ft" 17 ANGELA M. HANSARICK, Defendant CIVIL ACTION - LAW 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. l)e parties to this action separated on May 3 1, 1999 and have continued to live separate 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. Date: Jhl1 € ~ 'JtlO) . ~d:'~--./ /' (Plaintiff/Dd~n~allt) 0 0 ~~) c ,'J ~ L_ -OCr.; c::: rnr; , -,~ -7""'---' ....,... ~-~- I ZC (f) ='-:'~ 0'" ri/- C' :.:::: - ~~~: )-... '-'. Z,,-,,' )>~ I..P ;'-;: .. :.--:, z e;:- el;) ~ \0 =<