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Home My WebLink About02-1306DANIEL D. HILL, Plaintiff COURTNEY B. HILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : CIVIL TERM : IN LAW - 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 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 relief requested in these papers by the Plaintiff. You may loose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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, First Floor, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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, Pennsylvania 17013 Telephone (717) 249-3166 DANIEL D. HILL, Plaintiff Vo COURTNEY B. HILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0o -/3 G : CIVIL TERM : IN LAW - DIVORCE COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, Daniel D. Hill, by his counsel, William L. Grubb, Esquire, and complains of the Defendant, Courtney B. Hill, as follows: COUNT I COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Daniel D. Hill, who curremly resides at 2522 Alessandro Boulevard, Harrisburg, Dauphin County, Pennsylvania, 17110. 2. Defendant is Courtney B. Hill, who currently resides at 231 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania, 17112. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 29, 2000 at Johnstown, Cambria County, Pennsylvania. parties. There have been no prior actions of divorce or for annulment between the 6. Neither party is in the Armed Services of the United States or its allies. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the marriage between the parties. COUNT II EQUITABLE DISTRIBUTION 10. Plaintiff incorporates the allegations of paragraphs one (1) through nine (9) by reference as if set forth at length herein. 11. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Respectfully submitted, William L. Grubb, Esquire I.D. # 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 Attorney for Plaintiff VERIFICATION I, DANIEL D. HILL, verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. /Da~fiel 13~1~11, ~-aintiff CERTIFICATE OF SERVICE I, WILLIAM L. GRUBB, Esquire, certify that I have served a copy of the foregoing document on the individual listed below by depositing the same in the United States Mail, Certified, First Class, restricted delivery, postage prepaid, at Shiremanstown, Pennsylvania: Courtney B. Hill 213 Beacon Drive Harrisburg, PA 17112 Date: William L. Grubb, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 DANIEL D. HILL, Plaintiff COURTNEY B. HILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1306 CIVIL : : CIVIL TERM : IN LAW - DIVORCE PROOF OF SERVICE BY M~IL I hereby certify that a true and correct copy of the Complaint in Divorce filed in the above matter, was served on Courtney B. Hill, by first class, certified mail, return receipt requested, deliver to addressee only, at 213 Beacon Drive, Harrisburg, PA 17112, on March 18, 2002. Addressee acknowledged receipt of the same on March 19, 2002, as shown by the return receipt card attached hereto as Exhibit "A". I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Dated: William L. Grubb, Esquire I.D. 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 al Complete items 1, 2, and 3. Alan complete item 4 if Rest~cted 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 mailpiece, or on the front if space permits. 2. Article Number (Copy from serv/ce "-/oo,~ '7,,-'c-z~ o~)o PS Form ~8'~ 1, July 1999 A. Received by (Please Ptfnt Cieaffy) ff YES, enter ~ address below: [] No 3. Se~ice*lype [] ~glste~d [] Insured Mail [] Express Mail li~Ra~u~ ~ for MerchandM? [] C.O.D. 4. I~ Det~ (Extra F~e) [~ Yes oSqo Domestic Return Receipt Exhibit "A" DANIEL D. HILL, Plaintiff COURTNEY B. HILL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1306 CIVIL : : CIVIL TERM : IN LAW - DIVORCE AFFIDAVIT OF MARRIAGE COUNSELINC Daniel D. Hill, being duly sworn according to law, deposes and says: 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 Office of the Prothonotary, 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 understand that false statements herein are made subject to the penalties of Pa. C.S. §4904, relating to unswom falsification to authorities. Date:~/,~ I/9 9~ / Daniel D. Hill DANIEL D. HILL, Plaintiff COURTNEY B. HILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1306 CIVIL : : CIVIL TERM : IN LAW - DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned action discominued. Respectfully submitted, Date ~---~/- ~ 2.- William L. G-mbb, Esquire Attorney for Plaintiff 3105 Old Gettysburg Road Camp Hill, PA 17011 (717)763-5580 I.D. 72661 DANIEL D. HILL, Plaintiff COURTNEY B. HILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1306 CIVIL : : CIVIL TERM : IN LAW - DIVORCE REQUEST TO WITHDRAW AND DISCONTINUE TO: William L. Grubb, Esquire: Please withdraw and discontinue the above captioned Divorce Action. Respectfully submitted, Date ~arfiel~9~. Hill