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HomeMy WebLinkAbout87-0087IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. Versus .p.~V~_p__?.:___~_Z.~_: .......... ~-~-/4~-~i4~- ............. 19 87 DE. CRF. E. IN , ',oe ~. ne~~ 19 '8'7' it is °rdered and .... AND NOW,... "' ' ......... . , plaintiff, ... Donna ~i Hi ........... · ..... decreed mat .......... ', .... defendant, David T. Hines ......................... 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; .~.. 6~j ~'~ ................................ DONNA L. HINES, VS. DAVID T. HINES, Plaintiff : : : : : Defendant : IN THE COURT OF COMMON PLEAS ~6~g~Q COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 87 CIVIL 1987 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 (x) 201 (c) ( ) 201 (d) (1) of the Divorce Code. (Check applicable section). ~ 2. Date and manner of service of the complaint: U.S. regular mail on January 21, 1987 (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 201 (c) of the Divorce Code: by Plaintiff July 2, 1987 by defendant July 2, 1987 . (b) (1) Date of execution of the plaintiff's affidavit required by Section 201 (d) of the Divorce Code: (2) date of service of the Plaintiff's affidavit upon the Defendant: 4. Related claims pending: None Attorney fOr ( X ) ( ) Defendant FtI,~D-OFFiCE OF THE PROTHONOTARY CUHBEP, LAND OOUNTY PEN NS'~'LVANIA Court of Conmon Pleas C~nberland County, PA No. ~"7 Civil 1987 In Divorce Donna L. Hines, Plaintiff VS David T. Hines, Defendant COMPLAINT ARTHUR M. FELD ATTORNEY AT LAW P. O. BOX 11471 3003 NORTH FRONT ST. HARRISBURG, PA. 17]08-]47! Donna L. Hines, : Plaintiff : VS. : : David T. Hines, Defendant : Court of Cannon Pleas Cumberland County, PA No. ~t/ Civil 1987 In Divorce NOTICE TO DEFEND ANDCLAIM 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 wamed 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 be 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 imp- ortant 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 counsel- ors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER FEES OR EXPENSES BEFORE A DIVORCE OR ANNUIMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANYOFTHEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORDONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 249-1133 Donna L. Hines, : Plaintiff : VS. : : David T. Hines, Defendant : Court of Conmon Pleas Cumberland County, PA No. Civil 1987 In Divorce COMPLAINT UNDER SECTION 201(c) OR 201(d) OF THE DIVORCE CODE 1. Plaintiff is Donna L. Hines, who currently resides at 238 Walnut Street, 1st Floor, Lemoyne, Cumberland County, PA 17041, since October 1, 1986. 2. The Defendant is David T. Hines, who currently resides at 415 Herman Avenue, Lemoyne, Cumberland County, PA 17043, since October 29, 1974. 3. Donna L. Hines and David T. Hines have been bona fide residents in the Comnonwealth of Pennsylvania for at least six months inn~diately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on February 8, 1975 in Harris- burg, Dauphin County, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff requests the court to enter a Decree of Divorce. I verify that the statements made in this Complaint 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. Donna L. Hines January ~ , 1987 Arthur M. Feld, Attorney for Plainti[ f 3003 N. Front Street Harrisburg, PA 17110 (717) 234-4931 I.D. #07172 DONNA L. HINES, Plaintiff VS. DAVID T. HINES, Defendant COURT OF CO~ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 87 CIVIL 1987 IN DIVORCE AFFIDAVIT OF SERVICE I, Arthur M. Feld, do hereby certify that a Certified Copy of the Complaint in the above captioned matter was mailed to the Defendant, David T. Hines, postage pre-paid, U.S. Mail, at his address at 415 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043, on January 20, 1987. Said Complaint was received by Mr. Hines on January 21, 1987 in accordance with his Acknowledgment of Service of Complaint, which is attached hereto. This Affidavitis made subject to the 18 Pa. C.S. Sec. 4904, relating to unsworn falsification to authorities. Date: Arthur M. Feld DONNA L. HINES, Plaintiff VS · DAVID T. HINES, Defendant : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 87 Civil 1987 : : IN DIVORCE ACKNOWLEDGMENT OF SERVICE OF COMPLAINT I, David T. Hines, do hereby certify that a Certified Copy of the Complaint in the above captioned matter was served upon me on January 21, 1987. I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the 18 Pa. C.S. Sec. 4904, relating to unsworn falsification to authorities. Date: f~ ~!? David T Hines DONNA L. HINES, Plaintiff vs. DAVID T. HINES, De f enda nt : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY COURTHOUSE : : NO. 87 CIVIL 1987 : : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on January 14, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Compl a int. ~3. I consent to the entry of a final decree of divorce. 4. 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. Section 4904 relating to unsworn falsification to authorities. Date: Donna L. Hines (Plaintiff) 135/001 DONNA L. HINES, Plaintiff VS. DAVID T. HINES, Def enda nt : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY COURTHOUSE : : NO. 87 CIVIL 1987 : : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on January 14, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Comp 1 a int. 3. I consent to the entry of a final decree of divorce. 4. 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. Section 4904 relating to unsworn falsification to authorities. Date: ~ ,~ ~ / '---D~vid T. Hines' (Defendant) 135/002 COUNTY '117 FEE) Zt 3 29 I'~ '87