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HomeMy WebLinkAbout94-05713 I I I I \ . i 1 ; I I ~l t1 ::II -II 'f] I \ I I I ! , , I i ~ t , ! ~ I ! Jl : : , i ! : r<)j C' I 'l() I I I ~l o-~ , . ' ~j ! j 1 THOMAS ALBERT HUGHES, PIalntitr : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA \/. CIVIL ACTION - LAW 94-S7lJ CML TERM DIANE L HUGHES, 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) of the Divorce Code, 2. Date and manner of service of the complaint: On or about October 11, 1994 the defendant was served with a copy of the divorce complaint by personal service. 3, Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: November 8. 1995 By the defendant: November 8, 1995 4. Related claims pending: None MMember 8 , 1995 THOMAS ALBERT HUGHES, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . v. : CUMBERLAND COUNlY, PENNSYLVANIA CIVIL ACTION . LAW 94 .n 13 CIVIL TERM IN DIVORCE DIANE L HUGHES, Defendant NOTICE 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 in divorce or annulment may be entered against you by the coun. 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, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERlY, 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. Court Administrator Cumberland County Courthouse I Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 717-249-6200 THOMAS ALBERT HUGHES, Plalotl<< : IN THE COURT OF COMMON PLEAS OF v. . . : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94- j 7/3 CIVIL TERM DIANE L. HUGHES Defendant IN DIVORCE COMPLAINT lli. DIVORCE PURSUANT IQ SECTION 330J(c) QE THE DIVORCE CODE NOW, comes the plaintiff, Thomas Albert Hughes, by his attorney, Marcus A. McKnight, m, Esquire, and files this complaint in divorce against the defendant. Diane L, Hughes, representing as foUows: 1. The plaintiff is Thomas Albert Hughes, an adult individual residing at 1465 Hillcrest Court, Apartment #611, Camp Hill, Cumberland County, PeMsylvania 17011. 2. The defendant is Diane L, Hughes, an adult individual residing at 1783 Jonathan's Way, Apartment #E, Reston, Herndon County, Virginia 22090. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. THOMAS ALBERT HUGHES. Plaintiff : IN THE COURT or COMMON Pu:AS or . . : CUMBERLAND COUNTY, PENNSYL VANIA v. CIVlL ACTION. LAW 94 - CIVIL TERM DIANE L. Hl1GHES, Derendant IN DIVORCE PLA1NT1E.F'S MARRIAGE COUNSELING AFFlDA VIT The plaintiff, 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 Ihe court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request lhat Ihe court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verifY that the statemenls made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C,S. Section 4904 relating to unsworn falsification to authorities, October Stb. 1~4 C- C #4/~~ -" . THOmS ALBE T GHES. Plaintlll' - , , . THOMAS ALBERT HUGHES, rtabltilr : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION . LAW v. 94-571J CIVIL TERM DIANE L HUGHES. Deleadaat IN DIVORCE D~FENDANT'S MARRIAGE COUNSELING AFFIDA VII The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of Ihe availability of marriage counseling and undenland that I may request that the court require that my spouse and I participate in counseling, 2, I understand that Ihe court maintains a list of marriage counselors in the Prothonotary's Office, 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 coun5eling prior to a divorce decree being handed down, I veritY that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. e.s. Section 4904, telating to unsworn falsification to authorities. _~velY1he,.. g .1995 fo. . --'<--VLIc.;jL~0-:J DIANE L HUJIES THOMAS ALBERT HUGHES. P1alndlf IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION . LAW 9....S71l CIVIL TERM DIANE L HUGHES, Derendant IN DIVORCE AFFIDA VIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.c.P. RULE NO. 1920.4 (a)(J)(I) COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND NOW, l\-larcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: I, That he is a competent adult and attorney for the plaintiff in the captioned action in divorce, 2, That a certified copy of the complaint in divorce was served upon the defendant on October 11, 1994, by certified mail, "restricted delivery", addressed to her at 1783 Jonathan's Way, Apartment E, Resto", Virginia 22090, Return Receipt No. P 282 342 367. 3. That the said receipt for certified mail is signed and is attached hereto and made a part hereof. I verifY that Ihe statements made in this affidavit are true and correct. I understand 'lhat: false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities ,199S