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OF
CUMBERLAND
COUNTY
STATE OF
PENNA.
WAYNE L. HOFFMAN, JR.,
______.__n.u__u__.._____u_. ...u__________.____
pm_m.mm..m._.__ I
II
N o. JO_o.~::-,5.~_5.3. C~1T_r.~..,T.F;llM
CIVIL ACTION - LAW
Plaintiff
un___ "__._ __ ___. _u.__ un____ _. .. _.___u.. __ '.u. ___n___.
Versus
__I,QR); ft._. ,1!()I!;F!1NlL.m,
IN DIVORCE
,,_, _._ p_' _Def en_d_<,p.t
DECREE IN
DIVORCE
AND NOW. .. .~P\-'.<?,~.~. 2.'1......,
2000
... ."-1
it is ordered and
decreed that. .. . . . . .w:,\Y.~~ .~'. .~~~~'. .~~'. .. ., .. .. .. . , .. .. . . . " plaintiff,
and...... _......... .~~~r..~: .I:I~~~.......................... 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;
The Marriage Settlement Agreement dated September 7, 2000 and signed by
.............. ,........................... .................. ..............,
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By T eMurt
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Allest p'...a
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Prothonotary
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MARRIAGE SETTLEMENT AGREEMENT
TillS AGREEMENT made this 7th day of September, 2000, by and between LORI A.
HOFFMAN (hereinafter Ieferred to as "WIFE") and WAYNE L. HOFFMAN, JR.,
(hereinafter referred to as "HUSBAND ").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on October 7, 1989, in
Carlisle, Cumberland County, Pennsylvania, and were separated on August 4th, 2000. The
parties are the natural parents of two children, namely, JENNA L. HOFFMAN, born June 3,
1992, age 8 years; and TRISTAN W. HOFFMAN, born October 5, 1995, age 4 years.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and pennanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
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3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten OI interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(1) is represented by counsel of his or her own choosing;
(2) is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agreement; and
(6) fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
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5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due Iegard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party repIesents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further repIesents that he OI she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
3
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7.
MARITAL DEBTS & BANKRUPTCY: Each party will be responsible for their own
debt incurred after the date of separation. HUSBAND will be solely responsible for his
outstanding debts and agrees to hold WIFE harmless and indemnifies her for any debt incurred
after the date of separation. WIFE will be solely responsibility for her outstanding debts and
agree to hold HUSBAND harmless and indemnify her for any debt incurred after the date of
separation.
WIFE agrees to refinance into her own name the Mortgage on the real estate and hold
HUSBAND harmless and indemnify him for any amount due on said Mortgage and the second
Mortgage.
It is hereby understood and agreed by and between the parties that their obligations
pursuant to this agreement shall not be affected by any bankruptcy proceeding and shall not be
deemed to constitute or be a dischargeable debt of a bankruptcy. Both parties warrant that he/she
has not heretofore instituted any proceeding pursuant to the bankruptcy laws nor are there any
such proceedings pending with respect to him/her which have been initiated by others.
8.
SUPPORT. ALIMONY. CHILD SUPPORT AND TAX EXEMPTIONS:
HUSBAND will not pIovide spousal support or alimony pendente lite to WIFE, and WIFE will
not provide spousal support or alimony pendente lite to HUSBAND. After the entry of a
DivoIce Decree, neither party will seek alimony from the other.
HUSBAND agrees to pay to WIFE child support in the amount of $300.00 per month
payable $75.00 per week. WIFE will be entitled to use both children each year as Federal
Income Tax exemptions.
4
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9.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his current possession; a copy of which is attached and
marked as Exhibit "A".
b. His bank: accounts;
c. Any Life Insurance Policy;
d. His IRA retirement account;
e. His Mutual Funds;
f. The real estate will be conveyed to WIFE from HUSBAND in return for
the payment of the outstanding credit card bills.
WIFE shall receive the following items:
a. The personal property in her current possession; a copy of which is attached and
marked as Exhibit "B".
b. Her bank: accounts;
c. The term life insurance policy upon the life of the WIFE;
d. Her employee benefits from employment; and
e. The marital real estate situate at 79 Horsekiller Road, Shippensburg,
Pennsylvania 17257.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
5
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description and wheIever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
10.
AUTOMOBILES:
a. WIFE agrees to waive any and all interest which she may have in HUSBAND'S
motor vehicle.
b. HUSBAND agrees to waive any and all interest which he may have in WIFE'S
motor vehicle.
11.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies except as otherwise stated herein on the life of HUSBAND or any other
employee benefits, including but not limited to retirement, pIofit sharing or medical benefits of
either party, shall be his own. WIFE waives all right, title and claim to HUSBAND'S employee
benefits. HUSBAND waives all right, title and claim to WIFE'S employee benefits, including
but not limited to retirement, profit sharing and medical benefits.
12.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE.
6
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13.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the DivOIce shall pay all
the costs and legal fees of the party who is seeking the divorce.
14.
BREACH AND COUNSEL FEES AFTER DIVORCE: The parties agree with respect
to counsel fees incurred after the divorce, as follows:
(a) In the event that future legal proceedings of any nature may be necessary for the
interpretation or enforcement of this Agreement OI any valid modifications hereof, the prevailing
party shall be entitled to reasonable counsel fees incurred.
(b) Reasonable counsel fees hereunder shall be defined as reasonable hours expended
at the then hourly rate of counsel fOI the prevailing party.
(c) Such counsel fees shall extend to any independent proceedings necessary to
collect counsel fees or to enforce any other judgment or decree in connection with this
Agreement.
(d) Such counsel fees shall be payable as alimony so as to constitute an exception to
discharge in bankruptcy but shall not be deductible by the payor or taxable to the payee for
income tax purposes.
15.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
Iequest of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be Ieasonably required to give full force and effect to the provisions of this
Agreement.
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16.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is
not the result of any duress or undue influence.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily,
and that it is not the Iesult of any duress or undue influence.
17.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants OI undertakings other than those
expressly set forth herein.
18.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
19.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
8
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20.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the pIesent or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiveI and Ielinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
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RIA.HOF N
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WAYNE L. HOFFMAN, JR.
(SEAL)
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ~\.j..J) day of September, 2000, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, LORI
A. HOFFMAN, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
~~~
Notarial Seal
Martha L. Noel, Notary Public
Carlisle BolO, Cumberland CouIllY
My Commission Expires Sept, 18, :a\lO~
Member, Pennsylvania Association of Notarj~l:l,~
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this !1b
day of September, 2000, a
Notary Public, in and fOI the Commonwealth of Peunsylvania and County of Cumberland,
WAYNE L. HOFFMAN, JR., known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement , and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
~~Wn
Notarial Seal .
Betzi A. Morrison, NolalY Public
Carlisle Bora, Cumberlend County
My Commission Expires Dec. 15. 2000
Member, Pennsy\V8lll8 AU<lllIllflOn gf NntcOO$
10
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Lori Hoffmall
Living Room
JVC CD Player
Couch, Love seat, End table
Emersion TV
Symphonic VCR
Wall mirror
All Cross-stitch pictures
Coo-Coo Clock
Kitchen
Big mixer
Rechargable mixer
Tea maker
Bread maker
Refrigerator
Dishwasher
1/2 cups, plates, silverware
1/2 pots and pans
Canister set
1/2 towels
Apple peeler
DiningRoom
Table & chairs
Computer and stand
Curio Cabinet
Plant stand
Bathrooms
!/2 towels
Bedrooms
Bed
3 dressers
Kids picture boxes (2)
Ammunition box
Sony Camcorder
Pentech camera
Photo Albums
Bakers rack
2 Phones
Answering Machine
Kids Rooms
Dressers, beds
1/2 toys
1/2 movies
Wooden toy chest
Basement
Wooden storage chest
Freezer
Green wooden chest
1 sleeping bag
2 wooden folding chairs
Mountain bike
1/2 canning jars
Sewing machine
1 kid pool
Tripod
Filing cabinet
Garage
Corolla
shovel
rake
~__ _ i" " .
Divsion Of Martial Items Between Wayne & Lon Hoffman
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. Wavne Hoffman Jr.
Living Room
Recliner
Two Lamps
Kitchen
Microwave
Hand mixer
1/2cups, plates, silverware
1/2 pots & Pans
1/2 towels
Cutco carving set
Dining Room
Filing Cabinet
Wooden cabinet
All animal mounts
Clock
Bathrooms
1/2 Towels
Bedrooms
Guns and cabinet
Safe
Humpback Chest
Small wall shelf
Whole encyclopedia set
2 phones
Kids rooms
1/2 toys
1/2 movies
Basement
Metal shelf
freezer
Thomas the tank train set
Mountain Bike
Desk
Hunting Cabinet
electrolux
Garage
Altima
Truck - chevy
!/2 garden tools
EXHIBIT "A"
-
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step [adder .
garden hose
1/2 garden tools
kids bikes
Tractor to use
Grill
Small basic tools
extension cord
4 wheeler - power wheels
Deck furniture
Wheel- borrow
Split coolers
Split Christmas items
Plants and hanging baskets
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Divsion Of Martialllems Between Wayne & Lon Hoffman
. Large Ladder
, Garden hose
old frig
Tractor (Lori can use for House)
Push mower (Lori Can Use)
Weed wacker (Lori can use)
Chains saws
tools
park bench
three wheeler
yard cart
Spilt coolers
Spilt Christmas items
Power wheels Jeep
EXHIBIT "A"
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WAYNE L. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit lhe record, togelher with the following information, to the court for entry of a divorce decree;
I. Ground for Divorce: irretrievable breakdown under Section 330 I ( c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Lori A. Hoffinan, on August 17, 2000, by certified, restricted delivery mail, addressed to her at 79
Horsekiller Road, Shippensburg, Pennsylvania 17257, with Return Receipt Number Z 166670576.
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: November 20, 2000; by defendant: November 20, 2000.
(b}(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiff's affidavit upon the defendant:
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: November 22, 2000.
Date defendant's Waiver of Notice in Section 3301(c)
Prothonotary: November 22, 2000.
QUIRE
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H105.157REV. S.97
COMMONWEALlH OF PENNSYLVANIA
OEPARTMENT OF HEAL lH
VITAL RECORDS
STAlE ALE NUMBER
Cumberland
DIVORCE
W
RECORD OF
OR ANNULMENT
(CHECK ONE) 0
STAlE ALE DATE
CO\JNl'I
HUSBAND
1. NAME
(Rrst)
Wayne
StreetorR.D,
(Last) 2. DATE
OF
L. Hoffman, Jr. BIRTH
City, Bora. or Twp. County $tBte 4. PLACE
Shipp ens burg , Cumberland, PA B~
RACE 7. USUAL OCCUPATION
WHITE BLACK OlHER (Specify)
IKI 0
WIFE
(Middle)
(Month)
10
(Day)
11
(Year)
67
3. RESIDENCE
(State or Foreign Counoy)
Pennsylvania
71 Horseki11er Road,
s. NUMBER a
OFlHlS
MARRIAGE 1
Inventory Control Specialist - Exe1
8, MAIDEN NAME (Rrst) (Middle) (Last) 9. DATE (Month) (Day) (Year)
Yohe A. Hoffman OF 07 67
Lori BIRTH 30
10. RESIDENCE Stmet or R.D. City, Bora. or Twp. County State 11. PLACE (State or FOteign Country)
79 Horsekil1er Road, Shippensburg, Cumberland, PA OF Pennsylvania
BIRTH
12. NUMBER I. RACE T4. USUAL OCCUPATION
OFlHlS 1 WH~E BLACK O~R(S_I Medical Lab Technician - Chambers burg H
MARRIAGE 0
1S. PLACE OF (County) (State or Foreign Country) 6. DATE OF (Month) (Day) (Year)
THIS Cumberland Pennsylvania THIS 10 07 89
MARRIAGE MARRIAGE
17A. NUMBER OF 78. NUMBER OF DEPENDENT 18. PLAINTIFF 9. DECREE GRANTED TO OTHER'(Specify)
CHILDREN lHlS CHILDREN UNDER 18. HUSBAND WIFE OTHER (Specify) HUSBAND WIFE
MARRIAGE 2 2 ~ 0 0 IKI 0 0
20, NUMBER OF HUSBAND WIFE SPUT CUSTODY OTHER (Specify) I 21. LEGAL GROUNDS FOR
CHILDREN TO 0 0 I1l 0 DIVORCE OR ANNULMENT Section 3301(c)
CUSTODY OF
22. DATE OF DECREE (Month) (Day) (Year) 123. DATE REPORT SENT (Month) (Day) (Year)
TO VITAL RECORDS
asp
24. SIGNATURE OF
TRANSCRIBING CLERK
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304. I (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: November 22, 2000
DOCKET NUMBER: 2000-5653 CIVIL TERM
PLAINTIFF~ SS# 202-46-6334
NAME: WAYNE L. HOFFMAN, JR.
DEFENDANT~ SS # 166-56-9141
NAME: LORI A. HOFFMAN
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WAYNE L. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-5tjj'CIVIL TERM
LORI A. HOFFMAN,
Defendant
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 in divoIce or annulment may be entered against you by the
court. A judgment may also be entered against you for any other claim OI relief Iequested 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 Iequest 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 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, Pennsylvania 17013
717-249-3166
1-800-990-9108
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AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
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WAYNE L. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6Zsj CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the plaintiff, Wayne L. Hoffmau, Jr., by his attorney, Marcus A. McKnight, ill,
Esquire, and files this complaint in divorce against the defendant, Lori A. Hoffmau, representing as
follows:
1. The plaintiff is Wayne L. Hoffmau, Jr., an adult individual residing at 71 Horsekiller Road,
Shippensburg, Pennsylvania 17257.
2. The defendant is Lori A. Hoffman, an adult individual residing at 79 Horsekiller Road,
Shippensburg, Pennsylvania 17257.
3. The defendant has been a resident of the Commonwealth of Pennsylvania at least six months
prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on October 7, 1989 in Carlisle, Pennsylvania.
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5. There have been no prior actions of divorce or for annuhnent between the parties.
6. There were two (2) children born to this marriage; namely Jenna L. Hoffman, born June 3,
1992, age eight (8) years and Tristan W. Hoffinan, born October 5,1995, age four (4) years.
7. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which
this action is based that the marriage between the parties is irretrievably broken.
8. The plaintiff avers that he has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
Respectfully submitted,
By:
Marcu A. McKnight, III, squ e
Attorney for Plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 25476
Date: August
112000
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsellll1d me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
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WAYNE L. HOFFMAN, JR.
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Date: August 110/ , 2000
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WAYNE lL. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- 5t 5)CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
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 the 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 that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify 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. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: August ,1./'fA, 2000
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WAYNE L. HOFFMAN, JR.
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
L A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
August 15,2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a [mal decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses in do not claim them before a divorce is granted.
I verify 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. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: November 20th
,2000
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WAYNE L. HOFFMAN, JR.
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WAYNE L. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a [mal Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 made are subject to the penalties of 18 Pa. C.s. Section 4904 relating to
unsworn falsification to authorities.
Date: November 20th
,2000
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WAYNE L. HOFFMAN, JR.
Plaintiff
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDA VII OF CONSENT
1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on
August 15,2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing ofthe complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights conceming alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
I verify 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. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: November 20th
,2000
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WAYNE L. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a [mal Decree of Divorce without notice.
2. I understand that I may lose rights conceming alimony, division of property, lawyer's
fees or expenses if! 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
,2000
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LORI A. HOFF N
Defendant
Date: November 20th
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WAYNE L. HOFFMAN, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. RC.P. RULE NO. 192M (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. 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, Lori
A. Hoffinan, on August 17, 2000, by certified, restricted delivery mail, addressed to her at 79
Horsekiller Road, Shippensburg, Pennsylvania 17257, with Return Receipt Number Z 166 670
576.
3. That the said receipt for certified mail is sigued and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties 0 18 Pa. C. . Section 4904, relating to
unsworn falsification to authorities.
Date: November 20th , 2000
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Postage
Certified Fee
Spedal Delivery Fee
Resf!icied Delivery Fee
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m R~m ':Receipt ShoWing to '-
- WhOm & Date Delivered
.~ Rebi!l l\O:eiptShowing to Whom.
~Dat&,'&Address"'SAddress
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(W) Postinark or Date
e O)i'FMAN. WAYNE
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.... Complete items 1, ~?:T and 3. Also complete
ijem 4 if Restricted.Delivery is desired.
. Print your name and address on the reverse
so that we can retuJ::Q the card to you.
. Attach this card to,li~'e back of the mailpiece,
or on the front if splice permits.
1. Article Addressed to:
lIS LORI A HOFFMAN
79 HORSEKILLER ROAD
SHIPPENSBURG PA 17257
2. Article- Number (Copy from_service label)
c.
x
o Agent
Addressee
DYes
IIlI No
D. Is d Ivery address different from item 1?
If YES, enter delivery address below:
3. Service Type
Xl Certified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
o C.O.D.
4. Restricted Delivery? ra Fee) II Yes
Z 166 670 576
102595-99-M-1789
PS Form 3ll11, July 1999
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-5653 CIVIL TERM
LORI A. HOFFMAN,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly swom according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list ofinariiage 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 counseling prior to a divorce decree being handed down.
I verify 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. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: November 20th
,2000
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