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HomeMy WebLinkAbout06-5466 S ~~ 1~- ~` ~ ~l I Qr ; >N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. No. 06- ~~ 4 CIVIL TERM SCc~t~ ~ ~ ~ Defendant IN 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 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 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, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Sn~ ~~- ~~~ ~(.,~ l ~ ; 1N THE COURT OF COMMON .PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. No. 06- ~GCIVIL TERM SC©t~ ~~ ~~1~ Defendant IN DIVORCE COMPLAINT UNDER 3301 c or d OF THE DIVORCE CODE 1. Plaintiff is ~f`1Q~ 11 ~ (~~~ h ~'(,~,~ ~ ,~_, who currently resides at ~~ G ~hnrl~i I.n ~nnl~ ~~ t~(7~''l , Cumberland County, Pennsylvania. 2. Defendant is C~a~_~,~-L(,t I ~ ,who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ~~ ~ 1 1 pQ' ©p~ at 5. The marriage is irretrievably broken, and the parties separated on ~Fmb~r a~ 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is xet in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. -~ (jCp ~ G~~v.c.~t Date Plaintiff, Pro Se I, s~~-~_~~ ~ ~~, ~ Q` , 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 made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. ~..~SdJ~ •l)W Date: ~l V., ~ . ,._.~ ,. Mkt' nom' /c.J~l _ _ . ~/1 Plaintiff, Pro Se Assisted by: Hannah Herman-Snyder, Esquire Griffie & Associates 200 N. Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5551 ~, ~~~ _. ~; _ ~ ~ _ - ~ ti.ra `~ __ _1 ~, ~, Plaintiff v. ~ (~ot~ ~ . N-oc,~ ~ ~ Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.06- ~~~ CIVIL TERM DIVORCE PRAECII'E TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Shawna L. Houle ,Plaintiff, to proceed in forma ap uperis. I, Hannah Herman-Snyder, attorney for the party proceeding in forma ap Uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. cs.~~_ei lh ~ ~_ Hannah Herman-Snyder, Esqui e Attorney for Plaintiff 200 N. Hanover Street Carlisle, PA 17013 (717) 243-5551 ,~ ,'~~ _R~ - . 4,- ,n/~ ~~~ ~ 1 111~~W~~' ~- ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. Defendant IN DIVORCE No. 06- 5 y ~ ~ CIVIL TERM ACCEPTANCE OF SERVICE I, ~ ~CoT7 ,~, ftOCJ/2 (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. 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 Scott A. Houle, Defenda `~ ca -~ `¢ ~g ~ r- ~~ `-~ r~ }' i`Tl t =' ~ .,, `--i ~,. -~ Q ^'` SHAWNA-LEA' HOULE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION -LAW SCOTT A. HOULE, N0.06-5466 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 19, 2006_ and served on September 29, 2006, as indicated in Affidavit of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.5. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: a ~ ~ ~' C ©~ n~ ~~fi}tE`J~-(' SHAWNA-LEA' HOULE ~~. t~- -c3 r~?_ ~,,,' m j~, ~ ~- , -t3 :Z st"~ ~~ '• ~ cr ,~ .•c SHAWNA-LEA' HOULE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION -LAW SCOTT A. HOULE, N0.06-5466 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER $3301(c) OF THE DIVORCE CODE 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 THE FOREGOING 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: o`~ ~ d ~ S~.l~ni~.Tl"~ 0~;-b'&.% `b ~ SHAWNA-LEA' HOULE ~} ~ ry : ~ '- ° c... ~. , E. a ~ :~ _- ~-' t ~ ~ C`-,' ~ ~. ~ ^~' •.J SHAWNA-LEA' HOULE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION -LAW SCOTT A. HOULE, N0.06-5466 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 2. A Complaint in Divorce under §3301 (c} of the Divorce Code was filed on September 19, 2006 and served on September 29, 2006, as indicated in Affidavit of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. DATE: ~~ ~,~ GL~~/~ COTT A. H C'> I rS ~.' uC'" = X ` t'st '~ ~ , „_. ~ Q .. ~, r..,i .I., ~~' > ~ ..G SHAWNA-LEA' HOULE, Plaintiff vs. SCOTT A. HOULE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.06-5466 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 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 THE FOREGOING 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: I ~ a~ COTT A. d p - ~, n ~-. ~ n-~r ~ ~ =; N ~~ <`-'~- ~ "~ ~ --`~ - _ _, ; ra -t= -n ~ ~~: ~ ~ ;~ C_ 1N THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY SHAWNA-LEA' HOULE, Plaintiff . v. Civil Action No. 06-5466 Civil Term SCOTT A. HOULE, Defendant 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By acceptance of service- September 29, 2006 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: By plaintiff ~2/28/06 ; by defendant 4/12/07 4. Related claims pending: t,~,~ 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A OR Date plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: January 8, 2007 Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the porthonotary: April 24, 2007 Attorney for Pa. Att'y ID P.O. Box 21 ~ 76281 Carlisle, PA 17013 (717) 571-2088 ~ c .. ~~"°- ~ Q -,-~ ~~r ~ ax;' ~ '~ E~~ r° 4Y7 ~:~ ~~~-.~ -r1 r }~= ~ ~jC ~= s C1 r _ 'r `L7 ~ r. -r __ i, 1= t.,N .~- rn .:. .~ ~% n.~ ~,~ :,{ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SHAWNA-LEA' HOULE VERSUS SCOTT A. HOULE N O. 06-5466 CIVIL TERM DECREE IN DIVORCE AND NOW, ~~~~~ ~ ~~, IT IS ORDERED AND DECREED THAT Shawna-Lea' Houle AND Scott A . Houle ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD 1N THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; TO WIT: NONE /l PROTHONOTARY ,. ,.-