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HomeMy WebLinkAbout06-1154 JENNIFER J, HALL, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, Db -/ /{''j : ACTION IN DIVORCE Civil Term JAMES D, HALL, Defendant NOTICE TO DEFEND AND CLAIM 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 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, Where 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 at the Office of the Prothonotary, Cumberland County Courthouse, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 32 South Bedford St. Carlisle, Pa, 17013 (717) 249-3166 JENNIFER 1. HALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, O&,- //~'I ACTION IN DIVORCE Civil Term JAMES D. HALL, Defendant COMPLAINT IN DIVORCE I. Plaintiff is Jennifer J, Hall, a competent adult individual, who has resided in Carlisle, Pennsylvania during the past six months, 2, Defendant is James D. Hall, a competent adult individual, who has resided at 437 Middletown Road, Hummelstown, Pa. 17036 since May 2005, 3, Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4, The Plaintiff and the Defendant were married on May 21, 2005 in Union County, Illinois, 5. There have been no prior actions of divorce or for annulment between the parties, 6, Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling, 7, Plaintiff and Defendant have no children together. 8, Plaintiff and Defendant are both citizens of the United States of America, 9. Plaintiff is a member of the Armed Forces of the United States; she currently stationed in Afghanistan; Defendant is not a member of the Armed Forces of the United States or any of its allies, 10, The Plaintiff avers that the grounds on which this action is based are: (a) that the marriage is irretrievably broken pursuant to 23 Pa.C,S, 3301(c); (b) that Plaintiff has suffered such indignities as to render her condition intolerable and life burdensome pursuant to 23 Pa,C,S. 3301(a)(6), WHEREFORE, Plaintiff requests the court to enter a decree in 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, rlt&L Respectfully submitted, Date: ~~00 i \ ~"J (,1. ,No, 79465 64 South Pitt Street Carlisle, Pa, 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 7::J (J ~ l:i::. A. ....0 >7 II ,D ~, ~ 8 .. - , ---.2 "',' ..8 CJ ~ 6"- 0[ ~ .. ~ -.,'. - .. ~ f,'j -- JENNIFER J, HALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 1154 Civil Term JAMES D. HALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this March 23, 2006, I, Jane Adams, Esquire, hereby certify that on March 13,2006, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: James D. Hall 437 Middletown Road Hummelstown, Pa. 17036 DEFENDANT . 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 cartHo the back of the mailpiecB, or on the front if space permits. 1. Article Addressed to: o Agent o Addressee cj/r: 3' /6(:; D. Is delivery address different from Item 1? 0 Yes If YES. enter delivery address below: ~ No JI\.'~1':<; D HALL 437 'HDDLETn:m HU'P1E:LSTO'rl'>1 PI'. RD 17036 \ 3. Service Type ,KL Certified Mall 0 Express Mall o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) as 2. Article Number (Transfer from service label) ; PS Form 3811 , February 2004 7004 1350 0003 7288 4745 Domestic Return Receipt 1 Q2595-Q2-M-1540 '/I ~ e Adams, Esquire . No, 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF () r:; .{:;" "" .~ \:'.:::J ':~", () '1'1 ::::if: :\'I'~ :::0 1'\.1 'i!_ f'np=-~' '1:.1 'Y -.,., :J.:;: N JENNIFER J, HALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, No, O\r -- IlsLj Civil Term ACTION IN DIVORCE JAMES D, HALL, Defendant NOTICE TO DEFEND AND CLAIM 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 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, Where 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 at the Office of the Prothonotary, Cumberland County Courthouse, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa, 170 I 3 (717) 249-3 I 66 JENNIFER J. HALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, No, Civil Term JAMES D. HALL, ACTION IN DIVORCE Defendant AMENDED COMPLAINT IN DIVORCE I, Plaintiff is Jennifer J. Hall, a competent adult individual, who has resided in Carlisle, Pennsylvania during the past six months. 2, Defendant is James D. Hall, a competent adult individual, who has resided at 437 Middletown Road, Hummelstown, Pa. 17036 since May 2005. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4, The Plaintiff and the Defendant were married on September IS, 1993 in Union County, Illinois. 5, There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling, 7, Plaintiff and Defendant have no children together. s, Plaintiff and Defendant are both citizens of the United States of America, 9, Plaintiff is a member of the Armed Forces ofthe United States; she currently stationed in Afghanistan; Defendant is not a member ofthe Armed Forces of the United States or any of its allies, 10, The Plaintiff avers that the grounds on which this action is based are: (a) that the marriage is irretrievably broken pursuant to 23 Pa,C.S, 330 I (c); (b) that Plaintiff has suffered such indignities as to render her condition intolerable and life burdensome pursuant to 23 Pa.C,S. 3301(a)(6). WHEREFORE, Plaintiff requests the court to enter a decree in divorce, Respectfully subrpitted, / Date:~ . 3\ '7 .D l.p " ) fa e Adams, Esquire 1. ,No, 79465 4 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ATTORNEY VERIFICA nON Undersigned counsel, Jane Adams, Esquire, hereby verifies and states that: 1. She is the Attorney of record for Jennifer 1. Hall, 2, She is authorized to make this verification on her behalf, as Plaintiff is currently out of the country, 3, The facts set forth in the foregoing response as known to her and not necessarily to her client. 4. The facts set forth in the foregoing response are true and correct to her to the best of her knowledge, information, and belief. 5. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities, Date: '~ ,~) . to \....L! / J e Adams, Esquire (6 S, Pitt St. arlisle, Pa, 17013 (717) 245-8508 Attorney for Plaintiff JENNIFER J, HALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, No, 06 - 1154 Civil Term JAMES D. HALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on February 28, 2006 and served on March 13,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree, 1 verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa,C,S. 4904, relating to unsworn falsification to authorities. Date: ~/ /11 ~ ~ ~,~ Je er J. Hall, P intiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 63301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. [understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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. [understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: ~) ",/ ble? ,~ Je fer J. Hall, PIa tiff ,..;> (") = r:.:::l "Yl ,:.;.-~ .-1 ., ~ rrl "') ~ c .~> \.,'~< JENNIFER J, HALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, 06 - 1154 Civil Term JAMES D. HALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) ofthe Divorce Code was filed on February 28, 2006 and served on March 13, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry ofa final decree of 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. I also understand that false statements herein are made subject to the penalties of 18 Pa,C,S. 4904, relating to unsworn falsification to authorities. Date: & !:A{; ~0 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 63301(d) OF THE DIVORCE CODE I, I consent to entry of a fmal 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, ~4904 relati to unsworn falsification to autho ities. Date: 0 (~(P I 0 ~ "-' = 0 ~:.~") ~.n c",--. -' "t:- ;-nF~ \""" rv c- o.{:) ~J; (.,) ~ ,~)' -"' -";Y C_~j ~ JENNIFER J. HALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : No, 06 - 1154 Civil Term JAMES D. HALL, : ACTION IN DIVORCE Defendant PRAECIPE TO WITHDRAW COUNT TO THE PROTHONOTARY: Please withdraw Plaintiff's count for divorce under 3301(a)(6), whereby Plaintiff claimed she suffered indignities. Plaintiff's count for divorce under section 3301(c) shall remain, Respectfully Submitted, ~I R;;l:?j;~ e Adams, Esquire 1. . No, 79465 4 S. Pitt St. Carlisle, Pa, 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF (') r-.> 0 = F; c::'::} .'n C,;/. \,- :.rJ rii "'-) p v:l :?':' ",. ~n Co -< JENNIFER J. HALL, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 1154 Civil Term JAMES D. HALL,' : ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, return-receipt requested, on: March 13,2006. 3, Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: June 21, 2006 By Defendant: June 21,2006 4. Related Claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: June 29,2006. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: June 29,2006. Date: ro }30 I 0 /p J I. . 0, 79465 64 . Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ;r; 1 C'\ -;'J cr. C' . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Jennifer J. Hall, Plaintiff No. . VERSUS . James D, Hall, Defendant . . DECREE IN DIVORCE . . Jennifer J.~ /)- . AND NOW, . . . DECREED THAT . . . . . James D, Hall AND . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, PENNA. No. 06 - 1154 Civil Term . ~3:3~P.ht . ~, IT IS ORDERED AND . , PLAI NTI FF, , DEFENDANT, 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; ATTEST:/S/~'.-e.. ~ , ~,...~ . None, . . . . . . . . . . . . . . J, ~~.y~ PROTHONOTARY - ~z. ,,~.~"" ~ ?(?-/J'/'~ ..c;; ~ fr f2. ~ ..." ~ -r:'? '~Jt?hl.L.