HomeMy WebLinkAbout05-6094
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GEORGE K. HUNSICKER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. o.5~ (."oq'( (!,~-t;-r;h
DEBORAH A. HUNSICKER,
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 foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Courthouse
1 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
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
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GEORGE K. HUNSICKER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 0$.(,6<;"/
DEBORAH A. HUNSICKER,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a 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,
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GEORGE K. HUNSICKER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 0.5- I" O?'f e~,-,:J 77_
DEBORAH A. HUNSICKER,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, GEORGE K. HUNSICKER, by his
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is GEORGE K. HUNSICKER, an adult individual who currently
resides at 1156 Oyster Mill Road in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is DEBORAH A. HUNSICKER, an adult individual who currently
resides in East Pennsboro Township, Cumberland, and whose mailing address is P.O, Box
522, Enola, Pennsylvania 17025.
3. Both the Plaintiff and Defendant have been bona fide residents 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 14 February 1982 in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken,
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
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COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE. Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
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Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:
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GEORGE K. HUNSICKER,
PLAINTIFF
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2005-6094 CIVIL TERM
DEBORAH A. HUNSICKER,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
I hereby enter my appearance on behalf of the Defendant, DEBORAH A. HUNSICKER,
in the above rnatter and acknowledge receipt of a copy of the Complaint and accept service of
the same this date.
Date:
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~ B. Costopoulos ----
Attorney for Defendant
Supreme Court 10 # ~ '67 lY
2803 Old Gettysburg Road
Carnp Hill, PA 17011
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GEORGE K. HUNSICKER (165-38-1819).
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2005-6094 CIVIL TERM
DEBORAH A. HUNSICKER (567-08-3455),
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 Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceptance of Service indicatina service
on 1 December 2005 (Acceptance filed 16 December 2005l.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the
Divorce Code: by Plaintiff: 2 March 2006 by Defendant: _2 March 2006
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce
Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the
Respondent:
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 to Transmit
Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 2 March 2006. filed contemporaneouslv herewith. Date Defendant's
Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: dated 2 March
2006, filed contemporaneouslv herewith.
Date: ~ n2U'~ 2a'lf?
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Sa el L. Anaes
Attorney for Plaintiff
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GEORGE K. HUNSICKER. ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
I )
Ii vs. ) CIVIL ACTION - LAW
)
) NO. 2005-6094 CIVIL TERM
DEBORAH A. HUNSICKER, )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
29 November 2005 and served on 1 December 2005.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 {el OF THE DIVORCE CODE
1. 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 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. Section 4904
relating to unsworn falsification to authorities.
{V\ (..\ rd" 2, 2000
Dated:
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GEORGE K. HUNSICKER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVil ACTION - lAW
NO. 2005-6094 CIVil TERM
DEBORAH A. HUNSICKER,
Defendant
IN DIVORCE
8Ff'.IDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
29 November 2005 and served on 1 December 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 Ie) OF THE DIVORCE CODE
1. 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 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. Section 4904
relating to unsworn falsification to authorities.
N\C\.(~ 2, 2.00b
Dated:
~~<1h 0.. ~L.;v0d--U\
EBORAH A. HUNSICKER
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IN THE COURT OF COMMON
PLEAS
OFCUMBERLANDCOUNTY
STATE OF
GEORGE K. HUNSICKER,
Plaintiff
VERSUS
DEBORAH A. HUNSICKER,
Defendant
AND NOW,
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PENNA.
No.
2005-6094
DECREE IN
DIVORCE
fh h""-
,..;-
2006
., IT IS ORDERED AND
GEORGE K. HUNSICKER
, PLAINTIFF,
DECREED THAT
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DEBORAH A. HUNSICKER
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
AND
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
NONE
URT1f ~(
PROTHONOTARY
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