HomeMy WebLinkAbout06-4997
BRIAN K. HURST, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
No. Colo- 14447 C'l?tC`Tti,
NICOLLE L. HURST,
Defendant CIVIL ACTION - LAW IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
AV
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.
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 COURTHOUSE, i
COURTHOUSE SQUARE, CARLISLE, PA 17013.
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 LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
BRIAN K. HURST, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. C. - 49?7
NICOLLE L. HURST,
Defendant
: CIVIL ACTION - LAW IN DIVORCE
COMPLAINT
COUNT I - DIVORCE UNDER 63301(c) or 43301(d) OF THE DIVORCE CODE
The Plaintiff is Brian K. Hurst, who currently resides at 500 Haldeman Boulevard, Apartment
C, New Cumberland, Cumberland County, Pennsylvania 17070.
2. The Defendant is Nicolle L. Hurst, who currently resides at 90 Roxberry Road, York Haven,
York County, Pennsylvania 17370.
Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 18, 1999 in Strinestown, Pennsylvania.
5. The parties are the parents of one (1) minor child: Zoe T. Hurst, born on March 7, 1998.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Neither party is presently a member of the Armed Forces on active duty.
8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, or
property division.
9. Plaintiff has been advised that counseling is available and that he may have the right to
request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not
request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued.
10. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are:
(a) §3301(c). The marriage of the parties is irretrievably broken; and
(B) §3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time,
Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at
least two (2) years.
11. Plaintiff requests This Honorable Court enter a Decree of Divorce.
WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the
marriage between Plaintiff and Defendant.
Dated: oc
Respectfully submitted,
WILEY, LENOX, COLGAN & MARZZACCO, P.C.
(2
Thomas M. Clark, Esquire
130 West Church Street
Dillsburg, PA 17019
(717) 432-9666
I.D. # 85211
VERIFICATION
I, Brian K. Hurst, verify that the statements made in this Complaint 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. CS. §4904, relating to unworn falsification to authorities.
Dater Wo a, A ?'.,/
BRIAN K. HURST
Plaintiff
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BRIAN K. HURST, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NICOLLE L. HURST,
Defendant
: NO. 06-4997 Civil Term
: CIVIL ACTION - LAW IN DIVORCE
ACCEPTANCE OF SERVICE
I, Nicolle L. Hurst, accept service of Plaintiff's Complaint in Divorce in the above-captioned
matter, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure.
Date: _
iL. Hurst, Defendant
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Curtis R. Long
Prothonotary
office of the Vrotbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
01,- 'q227 CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573