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HomeMy WebLinkAbout05-6027 II v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. )(r.))~ (,crJ7 IN DIVORCE JENNIFER L. HANDE, Plaintiff JOSEPH M. HANDE. Defendant NOTICE TO DEFEND 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 17013 717-249-3166 Respectfully submitted, SAIDlS SHUFF, FLOWER & LINDSAY SAlOIS. SHUFF, FLOWEW~ / ...., ;'''' , I C . . s e" Supreme C"u # 78014 26 West Hig Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff By AlTORNEys-AT-LA.W 26 W. High Street Carlisle. P A SAIDlS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A JENNIFER L. HANDE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0':: - f..0.21 C.A..V".1 v. - I~...-..... JOSEPH M. HANDE, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, The Plaintiff is Jennifer L. Hande, an adult individual residing at 52 Ballpark Drive, Gardners, Cumberland County. Pennsylvania, and has lived there since 1985. 2. The Defendant is Joseph M. Hande. an adult individual residing at 52 Ballpark Drive, Gardners, Cumberland County, Pennsylvania. and has lived there since 1985. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 24, 1979 in Mechanicsburg, Cumberland County, Pennsylvania. 5. The parties separated on November 1, 2005. 6. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 7. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8 The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in counseling. 9. The marriage is irretrievably broken and no possibility of reconciliation exists. SAIDlS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, P A 'I WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with S3301 of the Pennsylvania Divorce Code. Respectfully submitted, By SAlOIS SHUFF, FLOWER & LINDSAY ATrORNEYS-AT.LAW 26 W. High Street Carlisle, P A II VERIFICATION I verify that the statements made in the foregoing document are true and correct. J understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !l4904, relating to unsworn falsifications to authorities, ~ J,./~ Jennif L. Hand NOV 1 8 2a~ ~ ~ ---- ~ "" 1:.(, .-' \}..J ~ '~ -~ ,,--,. --.... ~ ~) ~. ~ '" :, 2) ~) ~ "--~ .l... .> ? (.i ---., ) I ~;J r-.' ~...~' ':../ (:n o '.f1 .-. _.,-........ (,",\ !"'-' f',) . __; ~- ,:J -.,.-', '-:? ( n c.; SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS'AT'LAW 26 W. High Street Carlisle, P A JENNIFER L. HANDE, Plaintiff v. JOSEPH M. HANDE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-6027 IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint in the above-captioned matter. ~-6-0-!5 ate O<~ /lJU Jos h M. ande (c ".,) {:':' .._\ .------- SAIDIS, FLOWER & LINDSAY ATlURNE1'S.AT.LAW 26 West High Street Carlisle,PA I' JENNIFER L. HANDE. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO, 2005-6027 v. JOSEPH M, HANDE, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !l 3301 (c) of the Divorce Code was filed on November 22,2005, 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 of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge. information and belief, 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 J//9 Jf) Iw I I ~~./~ JaPf'nifer L. Hanae ' PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERli 3301 rei 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 to the best of my knowledge, information and belief. 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 J ~ ?; ! 8 l1i ~;j,,/~ Jenrtf(er L. Hande _1._ _,_ ._._l SAIDIS, H.OWER & LINDSAY ~'AT'lAW 26 West High Street Carlisle,PA II JENNIFER L. HANDE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-6027 v, JOSEPH M, HANDE. Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301(c) of the Divorce Code was filed on November 22,2005, 2. The marriage of plaintiff and defendant is irretrievably brOken and ninety days have 6lapS6L fi"ujT'1 tht:: date o( fiilfiy and service ur [he Complaint. 3, I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief I understand that false statements herein are made subject to the Date DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 (e) 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 wiii 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 to the best of my knowledge, information and belief I understand that false statements herein are made Subject to the penalties of 18 Pa,C.S. 4904 relating to unsworn falsification to authorities. J ' . Date:_~' ~ ,r---.... t~ .-c~ \" /~(. Il"" ~~ U Vt\R 3 0 1{0) ,-'. !"-... " .'11 :.-c ..) ..~-, r- ._, SAlDIS, FLOWER & LINDSAY ATTORNEYS.AT_lAW 26 West High Street Carlis!c,PA 1/ JENNIFER L. HANDE. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANtA v, CIVIL ACTION - LAW NO, 2005-6027 JOSEPH M. HANDE, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: Code. 1, Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce 2, Date and manner of service of the Complaint: Defendant signed an Acceptance of Service on December 6, 2005, Proof of service was filed with the Court on December 6, 2005. 3, executed: Date AffidaVit of Consent required under Section ~301 (c) of the Divorce Code was By Plaintiff: March 13, 2006 and filed with Prothonotary on March 14, 2006, By Defendant: March 19, 2006 and filed with Prothonotary on March 3'. 2006, 4, Related claims pending: The terms of the Property Settlement and Separation Agreement dated December 6,2005 are incorporated, but not merged, into the Decree in Divorce, 5 Date Waiver of Notice under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: March 13,2006 and filed with Prothonotary on March14, 2006, By Defendant March 19, 2006 and filed with Prothonotary on March 31. 2006, SAIDjP, F OWER & 1I [~,1,'j Carol J, Lindsay, Esqu Supreme Court 1(0 No '14693 26 West High Stree Carlisle, PA 17013 717-243-6222 ... ! SAlOIS, flOWER & LINDSAY t\TIORII.'IMl'AT.lAW 26 West High Street Carlisle, PA -- II ~ CERTIFICATE OF SERVICE I, Carol J, Lindsay, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY. hereby certify that on this date a copy of the attached document was served on the following individual. via first class mail, postage prepaid, addressed as follows: Joseph Hande P.O, Box 331 Walford. IA 52351 SAlOIS, FLOWER & LINDSAY } .., Carol J, Lindsay, E Supreme Court 10 N 26 West High S t Carlisle, PA 17013 717 -243-6222 "3o..fecL: 331-06 , ,or, ) -n -::f :_') c';'i C) () CJ '-< ~. . . . :+. ;+: :+.:+. +:t::f.:+."":+.:+.:t':t: . .. ... :+.:+.:+.:+.:f.+ :f.:f.:+. :+.:f.:f. ~:f.:f.:f.:+,:+,:+':f.:f.:+'+:f.:f. :+. :f.+'+:f.+:f.:f.~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f.+'++':+':+'+'+'+'+'+:+'++++++? .. IN THE COURT OF COMMON PLEAS . . . . . . . . . . . OFCUMBERLANDCOUNTY JENNIFER L. HANDE, PEN NA. STATE OF . . . . . . Plaintiff No. 05-6027 . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +':+. +.:f.:+. VERSUS JOSEPH M. HANDE, Defendant DECREE IN DIVORCE 1\ ~r'. \ JENNIFER L. HANDE ~ , ),0010 , IT IS ORDERED AND AND NOW, DECREED THAT , PLAINTIFF, JOSEPH M. HANDE , 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; The terms of the Separation and Property Settlement Agreement, dated December 6, 2005, are incorporated, but not merged, into this Decree in Divorce. By THE COURT: \\1\ ~ ~ \ ATTEST: PROTHONOTARY +. ++++++ +++++++++++++. :+':-f:t: Of:+':+.:+. Of:f.:+.:+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. .. 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