The URL can be used to link to this page

Home My WebLink About06-5897GRETCHEN L. HORS T, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 06- gq 7 CIVIL TERM JOHN A. HORST, 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 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 CUMBERLAND COUNTY COURTHOUSE CARLISLE PENNSYLVANIA 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 10, Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street WAYNE F. SHADE Carlisle, Pennsylvania 17013 Attorney at Law s west Pomfret Street Telephone: 717-243-0220 Carlisle, Pennsyhania Attorney for Plaintiff 17013 GRETCHEN L. HORS T, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 06- CIVIL TERM JOHN A. HORST, Defendant : IN DIVORCE COMPLAINT COUNTI DIVORCE 1. Plaintiff in this Action in Divorce is GRETCHEN L. HORST, an adult individual who resides at 94 Station Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is JOHN A. HORST, an adult individual and citizen of the United States of America who resides at 34 Trine Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. WAYNE F. SHADE II Plaintiff and Defendant were lawfully joined in marriage on April 22, 1995, in Attorney at Law 53 West Pomf'et Street Carlisle. Pennsylvania 17013 Walnut Bottom, Cumberland County, Pennsylvania. 5. The parties have been living separate and apart since on or about March 17, 2006. 6. Plaintiff avers ai the grounds on which this action is based that the marriage of the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any ether jurisdiction. 8. Both parties to this Action in Divorce are legally capable of managing their own concerns. 9. Defendant herein is not a member of the armed forces of the United States of America. 10. There were three children born to the parties, namely, Wyatt Daniel Horst, born May 12, 1996, Savannah Ilene Horst, born June 21, 1998, and Caroline Mae Horst, born February 14, 2001. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle. Pennsylvania 17013 -2- 11. Plaintiff has no adequate means of support for the children. 12. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. COUNT II EQUITABLE DISTRIBUTION 13. The averments of Paragraphs 1 through 12 inclusive above are incorporated herein by reference as though (ully set forth. 14. Plaintiff and Defendant possess various items of marital property which are subject to equitable distributior by the Court. WHEREFORE, Plaintiff demands judgment equitably distributing all marital property owned by the parties and such further relief as the Court may deem equitable and just. WAYNE F. SHADE. Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -3- COUNT III COUNSEL FEES, EXPENSES AND COSTS 15. The averments of Paragraphs 1 through 12 inclusive above are incorporated herein by reference as though fully set forth. WHEREFORE, Plaintiff demands judgment compelling Defendant to pay counsel fees, expenses and costs of Plaintiff. GEC./ /-' Wayne F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attornev at law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -4- I verify that the Statements made in this pleading 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: October 6, 2006 Gretchen L. Horst WAYNE F. SHADE Attornev at Law ?3 West Pomfret Street Carlisle. Pennsvlvania 17013 i4=?r Q 1t,11? W 1 ?'1 O Cal GRETCHEN L. HORS F, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 06-5897 CIVIL TERM JOHN A. HORST, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHI?DE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on October 10, 2006, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on October 12, 2006, as evidenced by the return receipt card attached hereto bearing Certified No. 7001 2510 0006 5864 2458. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: October 13, 2006) /C_4/_ Wayne/F. Shade WAYNF. F. SHADE Attornev at Law 53 west Pomfret Street Carlisle. Pennsylvania 17013 C to rur R3 ( L Postage $ .63 Ln Certified Fee 2 40 Postmark - --? l.? . Xll O Return Receipt Fee (Endorsement Required) p 1.85 Here October 10, --.. - O O Restricted Delivery Fee (Endorsement Required) 3. 70 2006 - - - C3 Total Postage & Fees $ 8. 58 ' Ln ru Sent To CC) --J-ahn-.-A---Har s-t----------------- --------------------------------------- r-l 0 Street, Apt. No.; or PO Box No. 34 enue-------------- Av Trine O r` -City, State, ZIP+4 ------- Mt. Holl __ ___ ------ S rin s PA 17065 ¦ 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 card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Mr. John A. Horst 34 Trine Avenue Mt. Holly Springs, PA 1706 A Signature X ? ? ? Agent Addressee ectived by (Printed ame) C. Date Deli ry It Nn ?(d1 2d /a/ Dp D. Is delivery address different from item 1? 13 Yes ff YES, enter delivery address below: WNo 3. Service Type 19 Certified Mail 13 Express Mail E3 Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. R941c611d DeNvery4 (Fxba Fee) 10 Yea 2. Article Number 7001 2510 0006 5864 2458 (Ransfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 GRETCHEN L. HORST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 06-5897 CIVIL TERM JOHN A. HORST, Defendant : IN DIVORCE PRAECIPE FOR WITHDRAWAL OF COUNSEL AND APPEARANCE OF PLAINTIFF PRO SE TO THE PROTHONOTARY: Please enter the withdrawal of the undersigned as counsel for Plaintiff GRETCHEN L. HORST in the above-captioned matter. Date: September 24, 2007 4(_ _ Wayn F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Please enter my appearance on my own behalf, pro se, in the above-captioned WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 matter. Date: September 25, 2007 I C Gretchen L. Horst 94 Station Road Newville, Pennsylvania 17241 f-., ,?. ' . " "? J) _- -.? .? i c ,- r ?,?, r,_?,