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Home My WebLink About95-03900 I ~ I I ~I II) 7- ;::r: . 7 i-\ -;c: f L ~ ~, OJ I J I i 81 ~l v 1 , "'Ji I I l()! 0-) , I 01 Zi ,. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95'. JeJtJ{) C'aJl.1t1J1. WENDY A. HYSER, PLAINTIFF MICHAEL G. HYSER, DEFENDANT CIVIL ACTION - LAW IN DIVORCE 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 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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 CARLISLE, PA 17013 (717) 240-6200 DIANE G, RADCLIFF ATTORNEY.AT.I.AW '''.11 TRINIl...: ROAH CAMP 11I1.1.. PA 17011 I t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE WENDY A. HYSER, PLAINTIFF v. MICHAEL G. HYSER, DEFENDANT COMPLAINT AND NOW, this /8.J..!J day of qlt f2ty , 1995, comes the , - U Pla1ntiff, WENDY A. HYSER, by her attorney, DIANE G. RADCLIFF, ESQUIRE, and files this complaint in Divorce of which the following is a statement: COUNT II DIVORCE l. The plaintiff, WENDY A. HYSER, is an adult individual residing at 6103 Locust Lane, Mechanicsburg, cumberland County, pennsylvania. 2. The Defendant, MICHAEL G. HYSER, is an adult individual residing at 6103 Locust Lane, Mechanicsburg, Cumberland County, pennsylvania. 3. plaintiff and/or Defendant have been bona fide residents of the commonwealth for at least six (6) months previous to the filing of this complaint. 4. plaintiff and Defendant were married on May 29, 1992 at Mechanicsburg, pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. DIANE G. RADCLIFF ATfORNU.AT.I.AW ,..., TRINIlI.f. ROA.n CAMP 1111.1., PA nOli 2 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The plaintiff avers that the grounds on which the action is based are: (a) That the marriage is irretrievably broken. Or in the alternative, (b) That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. Or in the alternating, (c) That Defendant has offered such indignities to the person of the plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this action is not collusive. Or in the alternative, (d) That the Defendant has committed adultery and that the Plaintiff is the innocent and injured spouse, and that this action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court to DIANE G, RADCLIFF AlIORNEY.AT.I.AW Sf.S TRISIU.F, ROAn {".AMP 1111.1.. PA 17011 enter a decree in divorce, divorcing the Plaintiff and Defendant. 3 DIANE G. RADCLIFF ATTORNEY.AT.tAW Uta TRINnLF. ROAn C.AMP 1111.1.. PA 17011 COURT II: BOUITABLB DI&TRIBUTIO. 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have legally acquired property, both real and personal, during their marriage from May 29, 1992 until the date of separation, all of which is "marital property". II. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property of the parties. Respectfully submitted, 4 VERIFICATIOR WENDY A. HYSER verifies that the statements made in this Complaint are true and correct. WENDY A. HYSER understands that false statements herein are made subject to the penalties of lB Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ,If ~ {l 1r'" ! DIANE C. RADCLIFF ATTORNEY.AT.LAW Uta TIUNDU. ROAD CAMP lULL. 'A 17011 U"> <T> - ;1-:= _-:f. m lr> = ,-~ ::;::J ,.1 .u; ~3]~ ! ~~~ c;~~~ ~~i~ Q a , . , .. \ .... WENDY A, HYSER, PLAINTIFF v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYVLANIA NO, 95-3900 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MICHAEL G, HYSER, DEFENDANT CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Complaint for Divorce has been served upon the Defendant, MICHAEL G. HYSER, by certified mail, restricted delivery on the 2nd day of August, 1995. The return receipt Is attached hereto as Exhibit "An and made a part hereof, Respectfully submitted, \ " DIANE G, RADCLI ,SaUIR L nn Ie Road Cam , PA 17011 (717) 737-0100 Attorney for Plaintiff DIANE C, RADCLIFF ATTORNEY.AT.LAW Uti TRINPI.t ROAn CAMP IIILI.. PA 17011 '" ! ! ,,; 0' '" ... E If <n Q. Z 435 660 497 ...4- Recl5JPt1or ~., Certified Mail _ No IW;lHiHl(;O COVllfilfjll P10vulcd .:::~;t<>.l~:} On lint USt' '1Jt IflhHllilfll)r.ill M;:uJ ISCll 'itlVH'~uJ cq d',_, , $ .55 1.10 .'1',.,. . "",', "1' .....'. '., ~.50 1./0 '-".. .,. 1.,0." 'C.,.'_, ., -"I" ',," , " . '~" r.. '.' $ .~~ I ~"",,.. ',.'.' ,/.:is /q <:;; 'I', l" . DtANE G. RADCLIFF ATTORNEY.AT.LAW '<H. TRINOLE ROAO CAMP 1111.1.. PA nOli E : . Campte.e Item. 1 andlor 2 for addltlonalllrvlclI. . Compl.t. It.m. 3, .nd 4. " b. . Print your name end add,... on the feVe'1e of thll form 10 thet WI can return thl, card to you. . Attach thl, form 10 the front of the mallplecl, or on the beck If apaCI doe. not permit. ,. . Write "Return Receipt R.qu8.t4d:~"on the m811plece next to the artlcl. number. . \~~...~: .\.\u<lu- ~ l D5 l..t,c,W)t ULu.-- ~ ~ nos$" I .1.0 wl.h to 'ec.ly. th. loIlowlng ....Ic.. 110' .n ext,. 1..1, 1, 0 Add'....... Add,... 2. 1'i'R..t,lct.d O'lIv.ry Con.~o.tme.t8r for fee. 48. Article Number Z 4b, SerYlc. TVp. o R.gl.ter.d 0 In.u..d Certlfl.d 0 COO o Exp,... M.II 0 R.tu,n R.c.lpt fo, I O.t. 01 O.IIY,ry Add......'. Add.... IOnlv II ,.qu..t.d G> and f.. I. p.ldl PS Form DOMESTIC RETURN RECEIPT EXHIBIT "A" ... DIANE C, RADCUFF ATIORSEY.AT_LAW sua TRlsnLE ROAn CAMP lULL. PA nOli WENDY A, HYSER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYVLANIA NO. 95-3900 CIVIL TERM CIVIL ACTION. LAW IN DIVORCE \'. MICHAEL G. HYSER, DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 24, 1995, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree In Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 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. Dated: 11-/- <75 ,"I /J / ( ,~ u d f, cL WENDY A. HY ER l ' / dr'l/ - ,,-I ~:<. =-- <=> c ... c , ." " ., tI' : ~ .>1 - ;r ,- ... ..' .'''' . ,- '~t = . . ',1..-1 ,- - .., .... ~, , - ~ a .- .- " " >=- " ::><: - . ~. . ,., - -~ :'. <.0 U1