HomeMy WebLinkAbout01-3636
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
Valerie J. Hartman,
Plaintiff
No.
2001
3636
VERSUS
David B. Hartman,
Defendant
DECREE IN
DIVORCE
AND NOW,
au,..,
Valerie J. Hartman
l'
, ko ~ , IT IS ORDERED AND
DECREED THAT
, PLAINTIFF,
David B. Hartman
, DEFENDANT,
AND
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 THE COURT/! d
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Michael S. Travis
ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
DAVID B. HARTMAN,
Defendant.
In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
No. 2001-3636
VALERIE J. HARTMAN,
Plaintiff,
vs.
CIVIL TERM
IN DIVORCE
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 S 3301(d)(l) of the Divorce
Code.
2. Date and manner of service of the complaint: Complaint was served upon
Defendant by Cumberland County Sheriff February 26, 2002 return of service attached hereto.
3. Date of execution of the affidavit of consent required by S 3301 (d) of the Divorce
Code: by Plaintiff on June 12, 2002; (b) Date of filing and service of plaintiff's affidavit upon the
respondent: June 18, 2002 (filed), June 18, 2002 (served).
4. Related claims pending: No claims were raised.
5. Date and manner of service ofthe notice of intention to file praecipe to transmit
record, a copy of which is attached: July 10,2002, US Mail fir class postage prepaid.
chael S. Travis
Attorney for Plaintiff
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
VALERIE J. HARTMAN,
Plaintiff,
)
)
)
)
)
)
No. 2001 - 3&3 ~
CIVIL TERM
IN DIVORCE
vs.
DAVID B. HARTMAN,
Defendant.
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:
Office of the Prothonotary
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty A venue
Carlisle, PA 17013
(717)249-3166
In the Court of Common Pleas of Cumberland County,
Pennsylvania
VALERIE J. HARTMAN,
Plaintiff,
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001 - 3 C. 3{P
vs.
CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302( d) ofthe Divorce Code, you may request that the court require you and your
spouse to attend marriage counseling prior to a divorce being handed down by the court. A list
of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
Michael S. Travis
ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-95092
In the Court of Common Pleas of Cumberland County,
Pennsylvania
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001 - 3 t, "-J(,
VALERIE J. HARTMAN,
Plaintiff,
vs.
CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by her attorney Michael S. Travis, respectfully represents:
1. Plaintiff is Valerie J. Hartman, who resides at 10 W. Lauer Lane, Camp Hill,
Cumberland County, Pennsylvania, 17011, since December 1993.
2. Defendant is David B. Hartman, who resides at 2 Dogwood Lane, Carlisle
Cumberland County, Pennsylvania, 17013, since April 2001.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on Marc~, 1985, in Dauphin County,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. 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.
9. Neither plaintiff nor defendant are in the Military Service in the United States
Armed Services. Neither plaintiff nor defendant are within the provisions of the Soldiers' and
Sailors' Relief Act of Congress of 1940 and its amendments.
10. Plaintiff requests 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. 9 4904, relating to
unsworn falsification to authorities.
Date:5-j 5.0/
~J1A~
Valerie J. Hartman,
Plaintiff
A
V'
c . e s. T~avis
Attorney for Plaintiff
J.D. # 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
Fax 731-9511
-
VALERIE J. HARTMAN,
Plaintiff,
In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
No. 2001-3636
vs.
DAVID B. HARTMAN,
Defendant.
CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Michael S. Travis, certify that on June 18, 2002, I served a true and correct copy of
Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code, and Counter-Affidavit Under
Section 3301(d) of the Divorce Code by first class mail, postage prepaid, on the following
person(s), addressed as follows:
David B. Hartman
Cumberland County Prison
1101 Claremont Road
Carlisle, PA 17013
Date: P' / I
j 1/ Iv::;"
BY~'
V 1 ael S: Travis
ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PAl 7011
(717) 731-9502
Attorney for Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03636 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HARTMAN VALERIE J
VS
HARTMAN DAVID B
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - DIVORCE
was served upon
HARTMAN DAVID B
the
DEFENDANT
, at 1446:00 HOURS, on the 26th day of February, 2002
at CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQ
CARLISLE, PA 17013
by handing to
DAVID B HARTMAN
a true and attested copy of COMPLAINT - DIVORCE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
.00
.00
10.00
.00
28.00
So Answers:
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R. Thomas Kline
02/26/2002
MICHAEL S. TRAVIS
Sworn and Subscribed to before
me this
._-1;7
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day of
BY'~~
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Deputy S iff
1~ J{fo;U A.D.
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A-..Ajl~ V' IIAAf..f.IA / ~
/ {Prothonotary I
In the Court of Common Pleas of Cumberland County,
Pennsylvania
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001-3636
CIVIL TERM
IN DIVORCE
VALERIE J. HARTMAN.,
Plaintiff,
vs.
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 before December 1993, 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 lmderstand that
false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn
falsification to authorities.
,
Date: (p. / cl ,tJ~
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Va ene J. art , mntiff
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
VALERIE J. HARTMAN,
Plaintiff,
)
)
)
)
)
)
No. 2001-3636
vs.
DAVID B. HARTMAN,
Defendant.
CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF S 330l(d) DIVORCE DECREE
TO: David B. Hartman
Cumberland County Prison
1101 Claremont Road
Carlisle, PAl 7013
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the S 3301 (d) affidavit. Therefore, on or after July 31, 2002, the other
party can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in
divorce. A counter-affidavit, which you may file with the prothonotary of the court, is attached
to this notice.
Unless you have already filed with the court a written claim for economic relief, you must
do so by the above date or the court may grant the divorce and you will lose forever the right to
ask for economic relief. The filing of the form counter-affidavit alone does not protect your
economic claims.
YOU SHOULD TAKE TillS 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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
. ..
In the Court of Common Pleas of Cumberland County,
Pennsylvania '
VALERIE J. HARTMAN.,
Plaintiff,
)
)
)
)
)
)
No. 2001-3636
vs.
DA VID B. HARTMAN,
Defendant.
CIVIL TERM
IN DIVORCE
COUNTER-AFFIDAVIT UNDER 9 3301(d)
OF THE DIVORCE CODE
1. Check either ( a) or (b):
D (a) I do not oppose the entry of a divorce decree.
D (b) I oppose the entry of a divorce decree because (check (i), (ii) or both):
D (i) The parties to this action have not lived separate and apart for a period of
at least two years.
D (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
D (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.
D (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 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. 94904
relating to unsworn falsification to authorities.
Date:
David B. Hartman, 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 TillS COUNTER-AFFIDAVIT.
.
In the Court of Common Pleas of Cumberland County,
Pennsylvania
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001-3636
VALERIE J. HARTMAN,
Plaintiff,
vs.
CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Michael S. Travis, certify that I have this day served a true and correct copy ofthe
foregoing document by first class mail, postage prepaid, on the following person(s), addressed as
follows:
David B. Hartman
c/o Cumberland County Prison
11 0 1 Claremont Road
Carlisle, P A 17013
Date: 7- / 0 ~ o;}..,
lchael S. Travis
ill No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
Attorney for Plaintiff
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
VALERIE J. HARTMAN,
Plaintiff,
)
)
)
)
)
)
No. 2001- 3636
vs.
DAVID B. HARTMAN,
Defendant.
CIVIL TERM
IN DIVORCE
Praecipe to Reinstate Complaint in Divorce
To the Prothonotary:
Please reinstate the Complaint in the above captioned divorce. This is the second time
the Complaint has been reinstated.
Date: /~ / J;l01
/-4
~
:;-;;
By-' /%
1 ael S. Travis
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717)731-9502
Supreme Court ill No. 77399
Attorney for Plaintiff
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2001-03636 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HARTMAN VALERIE J
VS
HARTMAN DAVID B
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
HARTMAN DAVID B
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - DIVORCE
, NOT FOUND , as to
the within named DEFENDANT
, HARTMAN DAVID B
PER POST OFFICE, MOVED AND LEFT NO
FORWARDING ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
3.25
5.00
10.00
.00
36.25
S;~.'. /'//--~.. '
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R Thomas K:tlne
Sheriff of Cumberland County
MICHAEL TRAVIS
10/18/2001
Sworn and subscribed to before me
this
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J-b-'OI A. D.
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Pro h notary
In the Court or Common Pleas or Cumberland County,
Pennsylvania
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001 - ,,-{~3&
CIVIL TERM
IN DIVORCE
-
~
VALERIE J. HARTMAN,
Plaintiff,
vs.
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:
Office of the Prothonotary
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM: FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM: ANY OF THEM.
YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
In the Court of Common Pleas of Cumberland County,
Pennsylvania
VALERIE J. HARTMAN,
Plaintiff,
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001 -
CIVIL TERM
IN DIVORCE
vs.
NOTICE OF A V AlLABILITY OF COUNSELING
TO THE WITIllN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302(d) of the Divorce Code, you may request that the court require you and your
spouse to attend marriage counseling prior to a divorce being handed down by the court. A list
of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
Michael S. Travis
ill No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-95092
In the Court of Common Pleas of Cumberland County,
Pennsylvania
VALERIE J. HARTMAN,
Plaintiff,
DAVID B. HARTMAN,
Defendant.
)
)
)
)
)
)
No. 2001 -
vs.
CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by her attorney Michael S. Travis, respectfully represents:
1. Plaintiff is Valerie J. Hartman, who resides at 10 W. Lauer Lane, Camp Hill,
Cumberland County, Pennsylvania, 17011, since December 1993.
2. Defendant is David B. Hartman, who resides at 2 Dogwood Lane, Carlisle
Cumberland County, Pennsylvania, 17013, since April 2001.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on Marc~ 1985, in Dauphin County,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. 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.
9. Neither plaintiff nor defendant are in the Military Service in the United States
Armed Services. Neither plaintiff nor defendant are within the provisions of the Soldiers' and
Sailors' Relief Act of Congress of 1940 and its amendments.
10. Plaintiff requests 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. 94904, relating to
unsworn falsification to authorities.
~t1Aj~
Valerie J. Hartman,
Plaintiff
Date: 5- /5. tJ!
A~s
Attorney for Plaintiff
I.D. # 77399
4076Nlarket Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
Fax 731-9511
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
CIVIL
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2001
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
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Civil. ~
3~3b'
No.
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To
Prothonotary
19~
.~ .. ^ ~~orney for Plaintiff
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No.
Term, 19 _
VS.
01 'J'"<Al{j 13 )2:')8 PM.
PRAECIPE
Filed
19_
, Atty.