HomeMy WebLinkAbout06-5955
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vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
JAMIE J. HOLLAND,
Plaintiff
CIVIL ACTION - LAW
NO. 0 ~ - SqS-:; ()J\ I
CHRISTIAN J. HOLLAND,
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
foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Courthouse
1 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
II
10.
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
JAMIEJ. HOLLAND,
Plaintiff
CIVIL ACTION - LAW
-~
NO. Ob ~ S-q ~5
CHRISTIAN J. HOLLAND,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302 (d) of the Divorce Code, you may request that the court
, require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
II
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
JAMIE J. HOLLAND,
Plaintiff
CIVIL ACTION - LAW
0(,- 5951 ~I T~
NO.
CHRISTIAN J. HOLLAND,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, JAMIE J. HOLLAND, by her attorney,
Samuel 1. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is JAMIE J. HOLLAND, an adult individual who currently resides at
35 Winding Hill Drive in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is CHRISTIAN J. HOLLAND, an adult individual who currently
resides at 2160 Camelot Drive, Apt. A-I in Harrisburg, Dauphin County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing of
this Complaint.
4. The Plaintiff and Defendant were married on 3 November 2005 in Dauphin,
Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
~
Samuel 1. An s
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
"
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
Date: ~. /'7, ~fh) {,
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JAMIE J. HOLLAND, ) IN THE COURT OF COMMON
PLAINTIFF ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 2006-5955
CHRISTIAN J. HOLLAND, )
DEFENDANT ) IN DIVORCE
ACCEPTANCE OF SERVICE
I, CHRISTIAN J. HOLLAND, hereby accept service of the original Complaint in
Divorce and acknowledge receipt of a copy of the Complaint.
Date: I air 3~{;
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CH S 2~ ;, OLLAND
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JAMIE J. HOLLAND,
Plaintiff
NO. 2006-5955
CHRISTIAN J. HOLLAND,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
11 October 2006 and was served on 13 October 2006 upon Defendant.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 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 this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
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JAMIE J. HOLLAND,
Plaintiff
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2006-5955
CHRISTIAN J. HOLLAND,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
11 October 2006 and was served on 1 3 October 2006 upon Defendant.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 ecl 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 this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
llrzJ67
Dated:
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II
JAMIE J. HOLLAND,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2006-5955
CHRISTIAN J. HOLLAND,
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 Section 3301 (c).
2. Date and manner of service of the Complaint: Personal service on 13 October 2006
(Acceotance of Service filed on 30 October 2006),
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the
Divorce Code: by Plaintiff: 18 Januarv 2007 by Defendant: 1 2 Januarv 2007
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce
Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the
Respondent:
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 18 Januarv 2007. filed contemooraneouslv herewith. Date Defendant's
Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: dated 12 Januarv
2007. filed contemooraneouslv herewith.
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Date: '<1 U~I , I",2saJ-r
B~~
el L. Andes
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
if.
JAMIE J. HOLLAND,
PENNA.
STATE OF
Plaintiff
No.
2006-5955
VERSUS
CHRISTIAN J. HOLLAND,
Defendant
AND NOW,
DECREE IN
DIVORCE
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JAMIE J. HOLLAND
, IT IS ORDERED AND
2007
DECREED THAT
, PLAI NTI FF,
CHRISTIAN J. HOLLAND
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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;
NONE
PROTHONOTARY if.
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JAMIE J. HOLLAND,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2006-5955
CHRISTIAN J. HOLLAND,
Defendant
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
NOTICE IS HEREBY GIVEN that JAMIE J. HOLLAND, Plaintiff in the above matter,
having been granted a Final Decree in Divorce on the 24TH day of JANUARY 2007, hereby
elects to resume the prior surname of JAMIE J. MORRIS, and gives this written notice
pursuant to the provisions of 54 P.S. ~ 704.
Date: 1-111 ( 01
?#rH~1J/~
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COMMONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUMBERLAND )
On the \ '2-.f't.. day of Febr~.,. , 2007, before me, the undersigned officer,
personally appeared JAMIE J. HOLLAND, known to me (or satisfactorily proven) to be the
person whose name is signed to the within Notice to Resume Prior Surname and
acknowledged that she executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notary PCiblic.
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