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Home My WebLink About02-4993IN THE COURT OF COMMON PLEAS OF THE __ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Abigail Laigh Hockensmith, Plaintiff 1733 W. Carolina Ave. Harsville, South Ca'olina 29550 161-62-3857 Jeremy Alan Hockensmith, De~endant 1601 Walnut Bottom Road Newville, Pennyslvania17013 167-70-8889 CIVIL ACTION - LAW TERMj CASE NO. d),;?- c/,~,~ ~/ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTR You have been sued in Cou~t for divorce. If you wish to defend against the claims set forth on the other side of this page, 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 cla~n or relief requested h this paper bythe Plahtiff. You may lose money or property or other rights important to you, including custody or visitation of you child or 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, in Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone(qJq ) ~0- IN THE COURT OF COMMON PLEAS OF THE __ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Abigail Leigh Hockensmith, Plaintiff 1733 W. Carolina Ave. Harsville, South Carolina 29550 161-62-3857 Jeremy Alan Hock®nsmith, De~endant 1601 Walnut Bottom Road Newville, Pennyslvania17013 167-70-8889 CIVIL ACTION - LAW CASE NO. TERM IN DIVORCE COMPLAINT UNDER SECTION 330t(c) OR 3301(d) OF THE DIVORCE coor 1. Plaintiff is Abigail Leigh Hockensmith who resides at; 1733 W. Carolina Ave.; Harsville, South Carolina 29550. 2. Defendant is Jeremy Alan Hockensmith who resides at: 1601 Walnut Bottom Road; Newville, Pennsylvania 17013. 3. [] Plaintiff and/or [] Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on 09/26/1999 at Mount Holly, Cumberland County, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Plaintiff is not in the military or naval sen/ice of the United States or its allies within the provisions of the Soldier's and Saibr's Civil Reief Act of Congress 1940 and its amendments. Defendant is an active member of the United States Navy and has signed an Waiver and affidavit of consent. Complaint for Divorce; Page I 6. There has been no prior action of divorce or for annulment between the parties. 7.The marriage is irretrievably broken. 8. After 90 days have elapsed fr~rn the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divome. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the dght to request that the Court require the parties to participate in marriage counseling. 10. There are no children of the marriage. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divome be entered pursuant to Section 3301(c) of the Divome Code dissolving the maniage between the Plaintiff and Defendant. WHEREFORE, petitioner further request that the Wife's name be restored to: Abigail Leigh Ingrain. (-}~,biga~i~h Hockensrnith ( I verify that the statements made in this Complaint are true and correct. I understand that false statements hereh are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unsworn falsifica~ion~ ~ /J~ , __ ~..d~t° authodt~s. ~ - Al~igail'L-e~gh~ H°C~nsmith, I~ro Per Complaint for Divorce; Page 2 I,MARY C. LEWIS and for said County, as contained in Marriage License Docket, vol. 1999 page Marriage License No. 920 September 23, 1999 to HOCKENSMITH JEREMY ALAN (~as~, ~'irs~, middle> and INGRAM ABIGAIL LEIGH '(Lash, ~'irsn, said License shows at KINGS GAP , CLERK OF ORPHANS, COURT in hereby do certify that the records in this office, 920, show that was issued on Middle) that the Return to that said persons were married on September 26, 1999 by R. LINDSAY INGRAM PASTOR stated his date of birth HOCKENSMITH JEREMY ALAN was September 15, 1977 his birthplace CARLISLE PA and the names of his parents DENNIS S HOCKENSMITH PATRICIA A HOCKENSMITH stated her date of birth her birthplace CARLISLE PA STEPHEN P INGRAM and INGRAM ABIGAIL LEIGH was February 25, 1981 and the names of her parents REBECCA K INGPJtM IN TESTIMONY WHEREOF, I have hereunto set my hand and the seal of said court this 10th day ~October , A.D., 2002 CLERK ORP S' COURT IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUN'I'Y CUMBERLAND Abigai Leigh Hockensmith, Plaintiff 1733 W. Carolina Ave. Harsville, South Carolina 29550 161-62-3857 Jeremy Alan Hockensmith, Defendant 1601 Walnut Bottom Road Newville, Pennyslvania17013 167-70-8889 CIVIL ACTION - LAW TERM CASE NO. IN DIVORCE COUNSELING NOTICE The Divorce Code of Pennsylvania requires that you be notified of the availablity of counseling where a divorce is sought under any of the following grounds: Section 3301 (a)(6) Indignities Section 3301 (c) Irretrievable breakdown Mutual Consent Section 3301 (d) Irretrievable breakdown Two/Three year separation A list of qualified professions is available for inspection in the Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone( ) IN THE COURT OF COMMON PLEAS OF THE__ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Abigail Leigh Hockensmith, Plaintiff 1733 W. Carolina Ave. Harsville, South Carolina 29550 161-62-3857 Jeremy Alan Hockensmith, Defendant 1601 Walnut Bottom Road Newville, Pennyslvania17013 167-70-8889 CIVIL ACTION - LAW TERM CASE NO. IN DIVORCE AFFIDAVIT OF MILITARY SERVICE Defendant, Jeremy Alan Hockensmith, declares under oath that I am defendant herein, that I waive any further service and consent to the jurisdiction of this court to determine all issues raised in the pleadings as if I were served by persnal service within the State of Pennsylvania. I am in the active military service of the United States of America. After consultation with the base legal officer or other counsel of my choice, I waive the provisions of the Soldier's and Sailor's Relief Act of 1942, as amended, including my right to court- appointed counsel, and permit the action to proceed without furlher noticeto me/~ Date: /~ c::~c.'-T' ~--z..- ~~.` L/~,~/~.,//'-''~/7 "~"J~e/~y A~ock~en~Vrlfith, D~fendant ~J Sworn to and subscribed before me this the 10 ~'~ day of IN THE COURT OF COMMON PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Abigail Leigh Hockensmith, Plaintiff 1733 W. Carolina Ave. Harsville, South Carolina 29550 161-62-3857 Jeremy Alan Hockensmith, Defendant 1601 Walnut Bottom Road Newville, PennyslVania17013 167-70-8889 CIVIL ACTION - LAW TERM CASE NO. O~_- L-tqq5 IN DIVORCE AFFIDAVIT AS TO SIGNATURE Abigail Leigh Hockensmith, being duly sworn according to law, deposes and says that Abigail Leigh Hockensmith is the Plaintiff in the above-captioned divorce action; that Abigail Leigh Hockensmith is familiar with the signature of the Defendant; and that the signature on the Acceptance of Service attached hereto as Exhibit "A" is the signature of the Defendant, Jeremy Alan Hockensmith. - AbigaiI-Leigh Hockensmif~, Plaintiff Sworn to and subscribed before me this the ~ day of ~c~ff-ob ~ c~ ~ oo ~ ~ ~n"~ . ~.,~arY Public "NOTARIAL SEAL Elaine M. Regi, Notary Public North Ulddleton Twp., County of Cumberland My Commission Expiree Nov. 6, 2004 IN THE COURT OF COMMON PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Abigail Leigh Hockensmith, Plaintiff 1733 W. Carolina Ave. Harsville, South Carolina 29550 161-62-3857 Jeremy Alan Hockensmith, Defendant 1601 Walnut Bottom Road Newville, Pennyslvania17013 167-70-8889 CIVIL ACTION - LAW TERM CASE IN DIVORCE ACCEPTANCE OF SERVICE I, Jeremy Alan Hockensmith, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divorce filed in the above-caplioned matter. Date :(~ Alah/Hockensmith, defendant / IN THE COURT OF COMt~ION PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Abigail Leigh Hockensmith, Plaintiff 1733 VV. Carolina Ave. Harsville, South Carolina 29550 161-62-3857 Jeremy Alan Hockensmith, Defendant 1601 Walnut Bottom Road Newville, Pennyslvania17013 167-70-8889 CIVIL ACTION - LAW CASE NO. O?-- ~rqq~ IN DIVORCE TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the ~S day of ~Or" c~O0~ , 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301(c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. 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. 7. I verify that the statements made in this affidavit are lrue 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: ;Z_-3-(_~,.~ ~(~,~.~,(,~ Abigail4_eigh Hoc" :1~~ ABIGAIL LEIGH HOCKENSMITH, Plaintiff VS. JEREMY ALAN HOCKENSMITH, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL DIVISION : : NO. 02-4993 CIVIL TERM PRAECIPE TO TRANSMIT RECORD 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) (Strike out inapplicable section). Date and manner of service of the complaint: __October 15, 2002 Accepted service as evidence by acceptance of service filed by record Complete either paragraph (a) or (h). (a) Date of execution of the affidavit of consent required by {}3301 (c) of the Divorce Code: by plaintiff__February 3, 2003 ; by defendant April 7,2003 (b) (1) Date of execution of the affidavit required by {}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. (b) 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: Date of plaintiff' s Waiver of Notice in {}3301 (c) Divorce was filed with the Prothonotary: April 8, 2003 Abigail Leigh Hockensmith Date defendant's Waiver of Notice in {}3301 (c) Divorce was filed with the Prothonotary: April 8, 2003 JertKny Alan Hockensmith t . Richard P. Mislitsky,/~tt0~ey ~'dr P[all~tiff IN PLEAS THE COURT OF COMMON Of CUMBERLAND COUNTY STATE OF ~ ABIGAIL LEIGH HOCKENSMITH, Plaintiff VERSUS JEREMY ALAN HOCKENSMITH, Defendant NO. PENNA. 02-4993 AND NOW, DECREE IN DIVORCE Aprill~ DECREED THAT ABIGAIL LEIGH HOCKENSMITH AND JEREMY ALAN HOCKENSMtTH ARE DIVORCED FROM THE BONDS OF MATRIMONY. 2003 , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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 ATTEST: Jo PROTHONOTARY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ABIGAIL LEIGH HOCKENSMITH, Plaintiff JEREMY ALAN HOCKENSMITH, Defendant NO.02-4993 CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, Abigail Leigh Hockensmith, having been granted a Final Decree in Divorce on the 15 th day of April, 2003, hereby elects to resume the prior surname of INGRAM and gives this written notice pursuant to the provisions of 54 P.S. § 704. (r}~0~(~3 lJ~<~ med )~BIG~L LEITH 15NGRA~J name being resu COMMONWEALTH / STATE OF COUNTY OF On the /(a day of /4~3~t' ,2003, before me, a Notary Public, personally appeared the above affiant known to me (or satisfactorily proven) to be the person whose name is subscribed to the within document and acknowledge that she executed the foregoing for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Pt~lic ~//~2 5-//~o 0-)