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Home My WebLink About05-5478 PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE :' NO. 05- 5"4180 v; , CIVIL TERM HANK W. 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 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- ,6"'/7 F CIVIL TERM DIVORCE COMPLAINT The plaintiff, Patricia A. Hartman, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: COMPLAINT UNDER 23 Pa.C.S. ~~3301(c) AND 330l(d) OF THE DIVORCE CODE 1. Plaintiff is Patricia A. Hartman, who currently resides at 161 North East Street, Apartment 1, Carlisle, Cumberland County, Pennsylvania 17013, since December 2004. 2. Defendant is Hank W. Hartman, who currently resides at 815 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070, since 1994. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 14, 1994 at Camp Hill, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since March 2001. 6. There have been no prior actions for divorce or for armulment between the parties. 7. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Date: Ie fleftS ,J . I (1 . -l.:c/;tf-.l- Angelic evelant Certified Legal Intern 'u(ja./hi.... '-- ( ZU; Robe ains Thom s M. Place Anne MacDonald-Fox Lucy J ohnston- Walsh Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. Date Or k- I?? :JrY)S~ , '-RX1.tr itL 0 9Jn.zt) 111 L I Patricia A. Hartman, Plaintiff :', :11 "V (9 ]"',') ,',:.' c-'. -n :'.:-J ,J) --..i ;'1 ;',; \..J ( ,--.' -i..::) PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 05- 5'fft CIVIL TERM HANK W. HARTMAN, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Ms. Patricia A. Hartman, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date iO/~{;/os . . Respectfully submitted, /)/J' , ), ."j , I Li..4iY:.[r C '<Lk ~ AngeliQa evelant Certified Legal Intern ii/it{ Yu~J dJ rL{)(,C ROBE y{. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 ,'"') -:---''\ '.;..\\ ,~:i"\ ~ . PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- 5478 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in March 2001, and have continued to live separate and apart for a period of at least 2 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 nrrt )-.1 ~ 0 DS- i2tu"rA~ 0, t)J ~YV\A\ Patricia A. Hartman Plaintiff :;-" ~s~ t..:::.. , , \-2~:-'_~' ;!~,f;: CL-tw,," ,.,..) L~J ;j...-"- F:: l.t~ C"J "I c..J (0 ,- ,:"'-- (.}.. r- \ -p (::J :z-::: 1.0 c;:.'.' ~~ t 51q l PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- 5478 CIVIL TERM CERTIFICATE OF SERVICE I, Angelica 1. Revelant, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of Divorce Complaint on Hank W. Hartman, residing at 815 Bridge Street, New Cumberland, Pennsylvania, by depositing a copy ofthe same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Hank W. Hartman, on the 3rd day of November 2005 as evidenced by the attached green card. J 1 . kiLL ;(.t/ F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 . . 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: o Agent o Addressee DYes o No 'fJevnif'~ -y/S ~ ;.jP..u:i ~~~4IjJ.q liD7Li 3. Service Type '::6 Certified Mall o Registered o Insured Mail 4. Restricted Delivery? (Extra Fee) :::8I'Ves 2. Article Number (Copy from service label) "700.<) 0/,<10 0003 .)..~~ ~ <0 -7.)- PS Form 3811, July 1999 Domestic Return Receipt 'I02595-99-M-1789 o ~'n r-' c-:'.',:> '.-c:.~ <-~ -- .',. Si .-\ -c ~11 ...-'(.! --- c:? "" - PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- 5478 CIVIL TERM CERTIFICATE OF SERVICE I, Angelica L. Revelant, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of Plaintiff's Affidavit under Section 3301(d) and Defendant's Counter-Affidavit under Section 3301(d) on Hank W. Hartman, residing at 815 Bridge Street, New Cumberland, Pennsylvania, by depositing a copy of the same in the United States mail, postage prepaid. a~4{ ((;Jf kL i dl-M Angelica evelarlt Certjfied Legal Intern '~-t{.i ,src ucy J s n-Walsh, Esq. Supervising Attorney Date: NOVNYltJi'r'0.;uJC>5 . F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 r--> <.~ C.7J c.n Z o ...,..;: o -n ::;1 hlp -nm ;:;.~~~ I 0:) :.~ ::, :,-: .-,;-("": ~~:;h'\ ~"l ~7') --< \...0 en C''l PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- 5478 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(d) 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. 94904 relating to unsworn falsification to authorities. Date 1/ de:; I' nS-- J ,-p oXtU' j't' Ot, \~ l1d1rYl ~ Patricia A. Hartman, Plaintiff ~~ ( .. \..'/J C:-, (y, PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- 5478 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330Hd) 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. 94904 relating to unsworn falsification to authorities. ~ ~ Date th;L<J -ej S ~f~ Hank W. Hartman, Defendant .:'.:~~, 1 \ -- ~,r.,i C' PATRICIA A. HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANK W. HARTMAN, Defendant : NO. 05- 5478 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: irretrievable breakdown and separation for at least two years under S3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Hank W. Hartman on November 3,2005. 3. Complete either paragraph (a) or (b). (a) Date of execution ofthe affidavit of consent required by 11 3301 (c) of the Divorce Code: by Plaintiff ; by Defendant (b)(1) Date of execution of the affidavit required by 11 3301(d) of the Divorce Code: November 7, 2005: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: November 7, 2005. 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe, a copy of which is attached: (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: November 29, 2005 Date defendant's Waiver of Notice was filed with the Prothonotary: November 29,2005. ~~tU-d Angeli Revelant Certified Legal Intern (1/2.11/0S Date , ' c"1 . ,w(L ~ Lucy J st n-Wa1sh, Esq. Counsel for Plaintiff F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, P A 17013 717.243-2968 -----"" ("') r-,".~ (~,;:.) c;, C.Jl CJ f'"; Co I ('.'" "' C) ,'J ::~:I <2,) .';:::- co - ;+; 'to '+0 't' Of. '*' + 't' + 't' +. 't' + 't' + 't' 't' +.:+ + '+ +"" . + + + + + + + ++ + + + + + + + + + + + + + + + + + + + + + + + + + + ++ ++ ++ +:f.+.Of.+. + + + + ++ + + + ++ ++ +++ +. Of. +. '+ "" Of. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. PII'1'RH'TII II HAR"J1MAN. No. 5478 2005 plaintiff VERSUS + + + + + + + + + + + + HANK W. HARTMAN, Defendant DECREE IN + + + .+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + ++ + DIVORCE I vs, i:? t'" J Vc L. , \ b , ,... , Zoos, IT IS ORDERED AND AND NOW, DECREED THAT PATRICIA A. HARTMAN , PLAINTIFF, HANK W. HARTMAN AND .' 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 .~ ATTE a~u#,. " 7ROTHONOTARY + 't; :++'f.:f.+:f.++++:f. + + + 't;Of.+'f.'t''t'+:f. 't'++'t':f. :f.+:f.+:f. +:f.:f. ++++Of.0f.+++:+:+:f.++:++++ J. + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + . + . + + + + + :++:+;\ , h ,'( ~'n/ ryJ-v)/ 7 j2. ~?W ;/~T1) 5(" ,/ . . .. /r/ ,',,' " ! . l; / Ji' r-j i i - Patricia A. Hartman, Plaintiff v. Hank W. Hartman, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW DIVORCE NO. 05 - 5478 CIVIL TERM CERTIFICATE OF SERVICE I, Rene M. Gornall, Certified Legal Intern, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit Record, the Plaintiffs Waiver of Notice oflntention to Request Entry of Divorce Decree, the Defendant's Waiver ofNotiee oflntention to Request Entry of Divorce Decree, and the Divorce Information Sheet Hank W. Hartman, residing at 815 Bridge Street, New Cumberland, P A 17070, by depositing a copy of the same in the United States mail, first-class. F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 .....' = ..--'" d' c;;:1 8 N N ;::~~ ~ o ..1 --< ::r:....., rr\F: ""--In' -by .,~"'J ,:- '-~'l':.;l ~,'. ......,- i~cS ,":'5f\\ ;;~ :;:1 .-<.. 9 Cl {'..,