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Home My WebLink About05-5970 .. McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS- - 597t' Ciu~l~YT'\ JOSEPH HUNT, v. ELLEN HUNT, 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 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. One Courthouse Square, Carlisle, PA 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 McNEES WALLACE & NURICK LLC B~~ r em n Cantor Attorney I.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff, Joseph Hunt Dated: November 16, 2005 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS' -.597t) C,'uL ~~ IN DIVORCE JOSEPH HUNT, Plaintiff v. ELLEN HUNT, COMPLAINT IN DIVORCE UNDER 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Joseph Hunt, who currently resides at 3709 Steams Hill Road, Waltham, Massachusetts, 02451. 2. Defendant is Ellen Hunt, who currently resides at 3 Tuscany Court, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 21, 1986, in Hartford, Connecticut. 5. There have been no prior actions of divorce or for annulment between the parties. . 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives his right to such counseling. 8. After 90 days have elapsed from the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate Notices two years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce under Section 3301 (c) or (d) of the Divorce Code. McNEES WALLACE & NURICK LLC By Attorneys for Plaintiff, Joseph Hunt Dated: November 16, 2005 2 VERIFICATION Subject to the penalties of 18 Pa. C.SA S 4904 relating to unsworn falsification to authorities, I hereby certify that the facts set forth in the foregoing document are true and correct to the best of my information and belief. Dated: November !3 ,2005 G -lA. ~ --- 7d ~ -.a ~~ ~ t C> .:::-::; (~;';I .... --,,'" :::r:..,., VI ....... C) ,11;= --- \) -'\"--j ~ ..t: , ~ ...J:: __t ,'--, ~ '".,-; -- \.JV .,., '(--I 0 .', ~ ,;:.'\r'1:1 ~ -"~ ...() (./? __I '--.....l::: U b (A) ':J .~ .-\ ,< ~ ...~ 0-" '----'--. IIO!. Y r. if:.--- r, - C !OVj' McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff JOSEPH HUNT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5970 CIVIL TERM v. ELLEN HUNT, Defendant IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in the above matter on behalf of Defendant, Ellen Hunt. Dated: NovemberJ3, 2005 CERTIFICATE OF SERVICE AND NOW, on this 29th day of November, 2005, I hereby certify that I have served a true and correct copy of the within document, via first class mail postage paid as follows: Cindy S. Conley Howett, Kissinger & Conley 130 Walnut Street PO Box 810 Harrisburg, PA 17108 ~:::,,~~ !"-' () ,-', "11 .-;-~ ',"j (.,' c; --'1 C;'? o ,- '.-.,"/ ';,] :.<.:. -., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH HUNT, v. NO. 05-5970 CIVIL TERM ELLEN HUNT, Defendant 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 a Divorce: 23 Pa. C.S. S3301(c) - Mutual Consent - Marriage irretrievably broken. 2. Date and Manner of Service of the Complaint: Date of service was November 18, 2005. The Complaint was served via First Class Mail on November 18, 2005. An Affidavit of Service was signed by Cindy S. Conley, Esquire on November 23, 2005 and filed with the Prothonotary on November 30. 2005. 3. Date of Execution of the Affidavit of Consent Required by Section 3301 (c) of the Divorce Code: By Joseph Hunt: February 27, 2006 By Ellen Hunt: February 27,2006 4. Related Claims Pending: All outstanding claims have been resolved by agreement. 5. Plaintiffs Waiver of Notice in S3301(c) Divorce is being filed contemporaneously herewith. 6. Defendant's Waiver of Notice in 93301 (c) Divorce is being filed contemporaneously herewith. McNEES WALLACE & NURICK LLC By~!mdit; I.D. No. 66378 100 Pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff, Joseph Hunt Dated}!lfIDfJ -2- , ';\ Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH HUNT, v. : NO. 05-5970 CIVIL TERM ELLEN HUNT, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 17, 2005. 2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days have elapsed since the date of 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. 1 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 4904 relating to unsworn falsification to authorities. Date: February 11 ,2006 I wd- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH HUNT, v. NO. 05-5970 CIVIL TERM ELLEN HUNT, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in 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. Section 4904 relating to unsworn falsification to authorities. Date: February 21 , 2006 ~ .',', ~:' , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH HUNT, ) Plaintiff ) ) v. ) NO. 2005-5970 CIVIL TERM ) ELLEN HUNT, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENl: 1. A complaint in divorce under 9330I(c) of the Divorce Code was filed on November 17,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry ofa final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. 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 in 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 above 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: ~':f F .Lb-u..'v. '(j ~ WhA/ ~~ Ellen Hunt, Defendant +:'+' + +: +: +: + +: +: :+ +::+ . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . , , . , . , . . , , . .. . ,. . . . , . . , , , . , . , . . , , . , , . . , . . , . , . . , . , . , . , , . . . . . . . . , , , . . , , . , . . . ++++:+++:++++:++:+:+::+++++:++++:+:++:+::+ :+ +++++++++++++++:+++.+.+.+.+++.++++++++++++.~ . . . . . . . . . . . . . , . . . . , . , . , . . . , , . . . . . . . . , . . . . . . . , . . . . . , . . . , . . . . . . . , . . . . . , . . . . , . . . , . . . , . . . , . . . . . . . . . , . . , . . . . +:++++: +++ +++++:+ +:+: ++:+:+:+++:++++++:++:+++~ ... ... ++:++: ... . .. . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. JOSEPH HUNT No. 05-5970 Civil Term PLAINTIFF VERSUS ELLEN HUNT DF.FENDANT DECREE IN DIVORCE J lo:t(f'j..,44 . ~ AND NOW, !1~ , IT IS ORDERED AND ).~ DECREED THAT JOSEPH HUNT , PLAINTIFF, AND ELLEN HUNT . 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 ATTEST:.a . ~\f-:~ ( ROTHONOTARY ++++++++ J. ~.;/7 $' ~ 0/,;1-, 90 - 6t" > [' (2) rp fr7:Z~i'#'~P~ ,'ltJ /;C'-Z' . . " it "< ~ ...,: --.--------------