The URL can be used to link to this page

Home My WebLink About05-6103 SAIDlS SHUFF, FLOWER & LINDSAY ATIQRNEYS.AT.LAW 26 W. High Street Carlisle. P A JANET Z HILBISH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, tj)- C,103 {'.':, I IN DIVORCE v, ROBERT F, HILBISH, JR" 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 prompl action, You are wamed thaI 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 judgmenl may also be entered againsl you for any other claim or relief requested in these papers by the Plaintiff, You may lose money or property or other righls 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, Lawyer Referral Service Cumberland County Bar Associalion 32 South Bedford Street Carlisle, PA 17013 717-249-3166 or 800-990-9108 Respectfully submilted, SAlOIS, ER & LINDSAY Caro J, Lindsay, squire 26 West High Stre t Carlisle, PA 3 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY AlTORNEVS.AT.LAW 26 W. High Street Carlisle. P A I[ JANET Z, HILBISH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW _ NO, 05-' 103 tu:J (Lv- ROBERT F, HILBISH, JR., Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, The Plaintiff is Janet Z, Hilbish, an adult individual residing at 906 Cocklin Street, Mechanicsburg, PA 17055, 2, The Defendant is Robert F, Hilbish, Jr" an adult individual residing at 13 Southpoint Drive, Mechanicsburg, PA 17055, 3, The Plaintiff and Defendanl 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 October 21, 1989 in Mechanicsburg, Cumberland County, Pennsylvania, 5, The parties separated in June of 2002. 6, There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction, 7, Neilher Plaintiff nor Defendant is in the military or naval service of Ihe 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, SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYSeAT.LAW 26 W. High Street Carlisle, P A II WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with S3301 of the Pennsylvania Divorce Code, Respectfully submitted, Dated: Ii I) 1/ t15 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A .. r _.m VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, S4904, relating to unsworn falsifications to authorities, Date: /1 ,x9 OS NOV i 3 2lm (D:' 'J - , ~ '~ "1- "-- ~, --(\ ~ (5 ---- ~ '\j ," 'l...'\ '--..... , "\-..\ ,> ....... ,'\ ~. ~ ~ ~- '" -~ "-0 -.., ;:::::5c , -', -.,r \ ':-1 ,') --'II I '. -, ;-1-1 r-,"\ t.) r,'> - " ;..;~' ...< , ~ SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A II JANET Z, HILBISH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW NO, 05-6103 ROBERT F, HILBISH, JR, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J, Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on December 13, 2005, she served a true and correct copy of the Divorce Complaint upon Defendant, Rober! F, Hilbish, Jr., by mailing those documents to his address at 13 South point Drive, Mechanicsburg, Pennsylvania 17055, by Certified U,S, Mail, Restricted Delivery, Return Receipl Requested, as evidenced by the attached U,S, Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Rober! F Hilbish, Jr. Respectfully subrnitted, SAlOIS, ~LlFF,F LO ER & LINDSAY . 7 (/ (}4I!J7Z Carol } ~ind: a , Esquire Attorney 10 f\1 ,44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff . ....... . 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 maHpiece, or on the front if space permits. 1. Article Addressed to: x SENDER: COMPLETE THIS SECTION 0, o Agent o Addressee DYes o No KDbe.rt: F' I~,I b'5~, J(-, . ;3 5ou..thpoLnt Dr. 'l'Y\c:chCLn, c5bLtfg I PA 17DSS 3, ~ o E)(press Mail o Rl~turn Receipt for Merchandise o C,Q.D, 4. Restricted Delivery? (Extr:S1 Fee) DYes 2. Article Number (Copy from service label) 7003 1010 0001 1201 6296 PS Form 3811, July 1999 Domestic Return Receipt 102595-00.M.0952 0 ", C r= ~. ..:.- .;~~.) <~ .i -'-1' " a 'I"! :~ ". PI :: , ,) A . N ., :J C CJ ., - (' ~ Cf! C -,,- ~' U) SAlOIS, FLOWER & LINDSAY A:nOIlNEW.~folAW 26 West High Street Carlisle. PA II JANET Z. HILBISH. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 05-6103 v. ROBERT F. HILBISH. JR.. Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 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 0; 18 ~a.c.s. 4904 relating to unsworn falSificati~on to authorities. . I / Iii, . . / Date: 7/d-./6c' -2 ~ I ' Ja t Z. Hilbish:J ' PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERi 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 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:~ JUl 0 '7 2006 f",.' :~--:-) 0' L. ::< SAIDIS, FlOWER &. LINDSAY AI......""'.'"""".IAW 26 West High Street Carlisle, PA JANET Z. HILBISH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05.6103 IN DIVORCE v. ROBERT F. HILBISH, JR., Defendant DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (cl 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: 07/20 I b f, I I _ iJ:;!ivt .4 obert F. Hilbish, Jr. rr-- DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER' 3301 leI 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 conceming alimony, division of properly, 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: 01/21\ loe. I I f{!4-1?-~ obert F. Hilbish, Jr, g ; -00:" ,\H" '.--7,- ?<:::-"- -71 <::q }t :<",,', -, ~, v~ ~,-~ -", ':'- x: \.....1 Y"~ :2 ~ ~ l"'~ :'6q ::s 0,6 ~::!f\ ~ '%r v> "" ;:.:, ?ii c:P ~ ~ ~ G") . ~ SAIDIS, FlDWER &. LINDSAY ..... I~__..........IAW 26 West High Street Carlisle,PA " JANET Z. HILBISH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-6103 v. ROBERT F. HILBISH, JR., 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: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant was served by certified mail on December 13, 2005. Proof of service was filed with the Court on December 21, 2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: July 2, 2006 and filed with Prothonotary on July 7, 2006 By Defendant: July 20, 2006 and filed with Prothonotary on August 17, 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. executed: Date Waiver of Notice under Section 3301 (c) of the Divorce Code was By Plaintiff: July 2, 2006 and filed with Prothonotary on July 7, 2006 By Defendant: July 20, 2006 and filed with Prothonotary on August 17, 2006 Y Carol J. Lindsay, s Supreme Court I o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 . . . . SAIDIS FlDWER'& LINDSAY ...... ___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; Jeffrey M. Cook, Esquire 234 Baltimore Street Gettysburg, PA 17325 SAlOIS, FLOWER & LINDSAY Carol J. Lindsay, Supreme Court I o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Dated: g- ~ J -0(. . g ~ ~ = = ;;;: CT" -otT' ",. ~~ r\'\h c:: 7"-, G} zC N f!) ..~ 159 '=":~ ;:~--.~ ".-JO ~~.~ -0 ~~ :r.:: "-r;l - S -? ,- ~ ~ ;;:- Ol .:'fi:+' :+. :+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ""'f'f'f'f . .. <+; +.:Ii:li:+: Of. :+. '+':+. Of Of Of:+.;tO:+, :+::+oOf :+o:+. :+. '" ~~ :+. +:+.:+.:+0++ +:+. 'f~:+' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. JANET Z, HILBISH No. 05-6103 VERSUS ROBERT F. HILBISH, JR. AND NOW. DECREE IN DIVORCE ~+ JANET Z. HILBISH 27 ~.L. , IT IS ORDERED AND DECREED THAT , PLAINTIFF, AND ROBERT F, HTI BISH. JR. , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF REC~rD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; J(Q\A.e.. The terms of the Separation and Property Settlement Agreement dated August 15,2006 are incorporated, but not merged, into this Decree in Divorce. ~4A.,s -'l By THE~tOURT: Am'T(]~~ ) /ROTHONOTARY . . ~+. :+.:+.++ '+':f'+':+'++:++:f + :+:+ :+.:+. 'I':+' '" 'f 'f 'f 'I';f 'I'~~~ :+.'f'f+++'f++.:+':+''+':f:f:f +++;\' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . . . . . . . . . . . . . . . + . + . . . . + + + + + . + . . . . J, . . . . . . . + . . + . . + + . + ..+ ?,,"",? ~ z /fT"- ~ 7,;1;; . & ~ frJ" fl rifT"'" 467.f'P "/IJ 51;> .. -,.-' .. .----------.------