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Home My WebLink About06-1088 d V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DOCKET NO: 0(.,- /or? ~ I.......... JOSEPH L. HITCHINGS, Plaintift: LORI A. HITCHINGS, Defendant CIVIL ACTION - LAW IN DIVORCE 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 action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING AN A TIONEY. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFOMRAITON ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY COURTHOUSE 4TH FLOOR CARLISLE, PA. 17013 #717-240-6200 .. v. IN THE COURT OF COMMON PLES OF CUMBERLAND COUNTY, PENNSYL VANIA NO. o~'loH W/u-.-. JOSEPH L. HITCHINGS Plaintiff LORI A. HITCHINGS, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OF THE DIVORCE CODE AND NOW, this 23rd day of February, 2006, comes the Plaintiff, Joseph L. Hitchings, and avers in support of his Divorce Complaint as follows: 1. Plaintiff, Joseph L. Hitchings, is an adult individual currently residing at 2413 Cope Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Lori A. Hitchings, is an adult individual currently residing at 2413 Cope Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to filing of this Complaint. 4. Plaintiff and Defendant were married on September 24, 1994, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The ground on which the divorce action is based is that the marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling 8. Plaintiff requests the court to enter a decree of divorce. 9. Three children have been born ofthis marriage, Connor K. Hitchings, born September II, 1996, Madison A. Hitchings, born November 29, 1997, and Braiden R. Hitchings, born December 17, 2001. WHEREFORE, pursuant to 23 Pa. C.S.A. S3301 (c), Plaintiff, Joseph L. Hitchings, respectfuIIy requests this Court grant a Decree of Divorce, divorcing the parties from the bonds of matrimony. RespectfuIIy Submitted, /"-, , , j'6seph L. itchings, E Attorney 1D No. 65551 4811 Jonestown Road, Suite 125 Harrisburg, PA 17109 (717) 657-3900 VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Z /-).;3 I D b Dale o 2-i/JuFo Joseph L. itchings ~ JOSEPH 1. HITCHINGS, Plaintift~ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA V. DOCKET NO: 06-1088 CIVIL TERM LORI A. HITCHINGS, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Lori A. Hitchings, accept service, on my own behalf, of the attached NOTICE TO DEFEND and COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OF THE DIVORCE CODE, which were filed with the Court of Common Pleas, Cumberland County, Pennsylvania, on the 24th day of February, 2006. Date: ;,. -,:}~- ()!/' Q c~ --' '~~.S ;.--..... .....,~ \'-' (J\ C2. -,. ::::l.... i~r:-. \~.:,; -.-( '-,:' ;::- < !;-7~ ~(J, '-I\l 0' ~-<~ ~~ -<- C;': C:::'l -' MCSHANE & HITCHINGS, LLC By: Joseph L. Hitchings, Esquire J.D. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, pennsylvania 17109 (717) 657-3900 Attorneys for Plaintiff JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-1088 Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant AFFIDA VIT I, LORI A. HITCHINGS, being duly swom according to law, depose and slate: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. 94904, relating to unswom falsification to authorities. Date: 5-;)5- ()~ :218827 o ,~~: <-" ;(0 t;'/~ 1",,1 r.o..... ~ :.,,~ ~ .-\ -~ -<1 \~le, ~n\...:.." -' ;-- ~ >.,(~J C:? (":J -, '~(-7i ;)\\ '---'"'. :'i~ .- MCSHANE & HITCHINGS, LLC By: Joseph L. Hitchings, Esquire J.D. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, Pennsylvania 17109 (717) 657-3900 Attorneys for Plaintiff JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-1088 Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 24, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of seNice of the Complaint. 3. I consent to the entry of a final decree in divorce after seNice of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and J to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. !34904 relating to unsworn falsification to authorities. Date: 5~ C} 5- ()~ :218827 -----------.-..- -----.' "" c::;:, C:::::7 C.:7~ o -n .-1 T h1::IJ r- "!'iS~3 ~~ ,:., -< t'-' G" :'.:''' _,..>e c:~ .-::;yn --4 ,';j :< 9? C:) _l MCSHANE & HITCHINGS, LLC By: Joseph L. Hitchings, Esquire J.D. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, Pennsylvania 17109 (717) 657-3900 Attorneys for Plaintiff JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-1088 Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE TO: LORI A. HITCHINGS, Defendant 1. I consenl 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. ( 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. 94904 relating to unsworn falsification to authorities. Date: 5~ ~_') - () ((7 :218827 --,------_.- 0 r-.> 0 (~ c.=:' c:::::.' -n =, ~,.~,. :;;:l :;-:,;11 61;2 -'.~ ;:c: N G' (-', :3::-,1'> -- ::;: ("'5 '.) ." co -A ~);.. C) :'D -.I -< MCSHANE & HITCHINGS, LLC By: Joseph L. Hi1chings, Esquire J.D. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, Pellllsylvania 17109 (717) 657-3900 Attorneys for Plaintiff JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-1088 Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant AFFIDA vir I, JOSEPH L. HITCHINGS, being duly sworn according to law, depose and state: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. 94904, relating to unsworn falsification to authorities. :. :- ,") ( I Date: -" -- C. ) JOSEPH L. - ~- :218827 ---- ~ ~ o -0 #-4 -r.:.....,., fl"\~~ '-, ~ \ ,-".- \"'.> v' . (/ ........ ..,.~,,~ _:.... -: -';:, )J;~t <l 2: ~ Cf) .' c:> Cf) MCSHANE & HITCHINGS, LLC By: Joseph L. Hitchings, Esquire J.D. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, Pennsylvania 17109 (717) 657-3900 Attorneys for Plaintiff JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-10BB Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 24, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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. 4. J have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. ~4904 relating to unsworn falsification to authorities. Date:'J-zS . c:: (, -j /./ J \ i ',-.~ ~, :218827 0 ,..., c: ,~.:;l 0 ;,-:.;J <.:>"'" -n .-1 -< ;;J~-r'\ '" ~~S (71 ~'.) ....~. ..'~ ::>:.:'" ""'"" -. ) <;? ;;:~l 0 'cc3 0;; :< --------..-.------ MCSHANE & HITCHINGS, LLC By: Joseph 1. Hitchings, Esquire LD. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, pennsylvania 17109 (717) 657-3900 Attorneys for Plaintiff JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-1088 Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE TO: JOSEPH L. HITCHINGS, Plaintiff 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. 34904 relating to unsworn falsification to authorities. Date: ;; - ) '\ i..; ~. . /l _ ~__../ ~ \ !J)~~.,\ ""jlisEPH L. HITCHINGS, Plain'titt ::, ;218827 Q (. ~~ ... -; o~ -"'~ ~J '0-" ~'h :? -T) 0~ (:f~ :!,~\ C{ .~)C) C!? ,-> '00 -", \)"~~~\ \ ::\ ~'.:.-'I ::4 ~----,-' ..--. JOSEPH L. HITCHINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-1088 Civil Term v. CIVIL ACTION - LAW LORI A. HITCHINGS, IN DIVORCE Defendant 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 93301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified copy of Divorce Complaint served upon Defendant, Lori A. Hitchings on February 24, 2006. A copy of the Defendant's acceptance of service is being filed concurrently herewith. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: May 25, 2006; by the Defendant: May 25, 2006. 4. Related claims pending: None. 5. Both Plaintiff and Defendant are filing Waivers of Notice of Intention to Request Entry of Divorce Decrees dated May 25, 2006, and May 25, 2006, respectively, concurrently herewith. M /;:foseph l.!. Hitchings, Esqu, e ./ Attorney I.D. No. 65551 4811 Jonestown Road Suite 125 Harrisburg, PA. 17109 (717) 657-3900 Attorneys for Plaintiff Dated: ~ / \,$.0 b :222183 (") '"'" ?:~~ c:'"_":> c; {:;:';~, G' -n (, ...., , ;..1:::7< ~ -< ill 1'-0 c. 2'; ':'? .::::'l _J ..----. ,., Of. ,., Of. Of. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY ,., PENNA. ,., ,., STATE OF .In!=:Aph T., Hif-~hing!=: ,., No. Civil 06-10AA Plaintiff Term In Divorce VERSUS Lnri lI., Hi f-C"hing!=: n~fAnnElnf- ,., DECREE IN ;+; DIVORCE ~ \ s"( 6{ Of. ''', ~ c\ ... '( Me.1- ' ;+; AND NOW, ?OOh, IT IS ORDERED AN D DECREED THAT Joseph L Bif-~hin~9 , PLAI NTI FF, AND Lori A_ HitC"hing5=: , 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 The divorce settlement Aqreement dated March 11,2006 shall be incorporated, but not merqed into this Decree in Divorce and is enforceable as an Order of Court as provided in 23 pa.C. Sec. 3105 By THE COURT: PROTHONOTARY Of. Of. Of. Of. Of. ;+; ;+; ,., J. ;+; .~ .2 ~'7J1tI ~ ~'1/'? ~ ?-~-~-rw ~.1/, > . . ..." J'"'- ..... ~ '- ..." .... ~,.,,,\.... .. . I .~ .. '*