HomeMy WebLinkAbout01-06281
.-"^'-' )-~'-';:;;;", .-~ hC .' -,'.. nli:lif
.<
.
- ., '"
Dl:.ti 1 2 zoOt vv
KIMBERLY M. HOFFMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
RONALD K. HOFFMAN,
Defendant
01-628t CIVIL TERM
IN DIVORCE
ORDER OF COURT
AND NOW, this
~1
day of
flt&.d
, 2001,
the attached Stipulation and Agreement is hereby incorporated as an
Order of Court.
BY~
.
/
J.
Andrew C. Sheely, Esquire I!. 6p..U.D
Attorney for plaintiff L!l-13'~/-
Ronald K. Hoffman, Pro se
Defendant
oJJ
~
'"Ii:
~W'~ ~, ._,< _~,___ ". ..~ ,~' ~ ~ ,,_~~ ~w. '~_',""__ >..~ 'H"'_ ~-
llf'('fllillii"''j','
.:'.1
.i
".
'iN
5'~
.::1
n'
i,., ~
3: :?L:,
GU\<L_:"L':i :-;C\X<TY
Pr-\l~~(:'-/l' \ Ii 1'< rl'~
I ~l - ..,,-,! .'/i'\i\.r\
.
" ,
_ "__,.~ ,_,." _0 _ .r_ """_ >~"""",,_,"~~_,, '_~~_<,__'e,' ,~_ ,,~,~~Jl1JTill(WJ ~~""- L'~, , !~, 0','-"< '''':i''':~'-''<''- ~,],~,lJ1I\I'!'.~~r~1\Wii'1~j~~~!~~~~
.
.' '
,~: --"
-
.
,.
KIMBERLY M. HOFFMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
RONALD K. HOFFMAN,
Defendant
01-628~ CIVIL TERM
IN DIVORCE
THIS
CUSTODY STIPULATION AND AGREEMENT ~
AGREEMENT AND STIPULATION entered into this Ib
day of
DECEMBER, 2001, by and between Kimberly M. Hoffman, Plaintiff,
(hereinafter referred to as "Mother") and Ronald K. Hoffman, Defendant,
(hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Samuel Robert
Hoffman, D.O.B. January 17, 2000., (hereinafter referred to as the
"child"); and
WHEREAS, Mother is the natural mother of the aforenamed child and
Father is the natural father of the aforenamed child; and
WHEREAS, the parties live in separate residences and are currently
separated; and
WHEREAS, the parties wish to enter into an Agreement and Stipula-
tion relative to custody and partial custody of the child; and
NOW, THEREFORE, in consideration of the mutual covenants, promises
and agreements as hereinafter set forth, the parties agree as follows:
(1) Mother and Father shall have shared legal custody of the
child, meaning that both parents shall have an equal right, to
be exercised jointly with the other parent, to make all major non-
.
I
, :~, "-,--"",-~"" 'o'~ ,-,~":';-'--,,-~.,,, ~~-'"J~
..
~
,
emergency decisions affecting the child's well being including, but not
limited to all decisions regarding her health, education and religion.
Pursuant to the terms of this Agreement, each parent shall be entitled
to all records and information pertaining to the child including, but
not limited to, school and medical records and information, as avail-
able. To the extent one parent has possession or control of such re-
cords, that parent shall be required to share the same or copies thereof
with the other parent within such reasonable time as to make the records
and information of reasonable use to the other parent. In the child
requires a major medical procedure or medical appointment for a signifi-
cant illness, the Mother shall notify the Father fourteen (14) days in
advance, or as soon as the Father himself receives notice.
(2) Father and Mother agree that Mother shall have primary physi-
cal custody of the child in accordance with the terms of this Agreement.
(3) Mother and Father agree that Father shall have periods of
partial physical custody on the following basis:
(a) On every other weekend, commencing on Friday after
Father's work's but not later than 5:30 p.m. and continuing
through Sunday evening at 6:00 p.m.; and
(b) During the off-week, on Monday and Thursday evenings which
are currently nights when Mother is not working, from after
Father's work but not later than 5:30 p.m. and continuing
through such evening until 7:30 p.m.; and
(c) On Christmas Day, beginning at 3:00 p.m. on Christmas Day
and continuing until 7:30 p.m. on Christmas Day; and
2
I'~:
>.,
,',.. <-' "' ",-,' --'"'-~"'-i:;'o ~- , "'"0'_". <," \'d
-
,
(d) During the Thanksgiving Holiday, beginning at 3:00 p.m.
on Thanksgiving Day and continuing until 7:30 p.m. the day
after Thanksgiving Day; and
(e) During the Easter HOliday, beginning at 1:00 p.m. on
Easter Day and continuing until 7:30 p,m. on Easter Day; and
(f) On New Years Eve, beginning at 10:00 a.m. on New Years Eve
and continuing until 7:30 p.m. on New Year's Eve; and
(g) In addition to the dates and times set forth above, the
child shall always spend Mother's Day with Mother and Father's
Day with Father. Mother and Father agree that custody with
child shall commence at 9:00 a.m. and end at 7:30 p.rn, on such
day.
(h) And any other times as the parties may agree.
(4) Father shall provide transportation for pick-ups and drop-offs.
(5) The parties will keep each other immediately advised to any
emergencies concerning the child and shall further take any necessary
steps to insure that the health and well being of the child is always
protected. The parties shall provide each other with all home and work
telephone numbers, as well as current addresses for the residence of the
child.
(6) Neither parent shall do anything which may estrange the child
from the other party, or injure the opinion of the child as to the other
party, or which may hamper the free and natural development of the
child's love or affection for the other party.
(7) Mother and Father agree that each shall communicate to each
other through one-another whenever possible in accordance with the terms
set forth in this Agreement and that they shall not use child as a
3
~
I
1<
^'";~''' ., '~,{, 'i:;'~.~"-.,,', ".
;';.,,;;';':j-t;
-
liaison to communicate with each other as to oral modifications of this
Agreement and Stipulation.
(8) Any modification or waiver of any of the provisions of this
shall be effective only if made in writing and only if executed with the
same formality as this Agreement and Stipulation. In the event any Court
deems this Agreement and Stipulation unenforceable due to changed or
unforseen circumstances, such decision shall have no effect on the
remaining portions of the Agreement and Stipulation.
(9) Neither party shall use or be in possession of any illegal
substances during any period of custody contact and neither party shall
use or consume excessive amounts of alcohol during any period of custody
with the child. Further, both parties shall ensure that, during his or
her period of custody, that the child is not exposed to third parties
who may be using, selling or possessing illegal drugs or consuming
excessive alcohol.
(10) The parties agree that any Court of competent jurisdiction may
enforce or modify relevant portions of this Agreement and Stipulation.
The parties further acknowledge that either party may petition any Court
with appropriate jurisdiction over the child should circumstances change
and either party desire modification of this Agreement and Stipulation.
(11) This Agreement and Stipulation shall be construed under the
laws of the Commonwealth of pennsylvania.
(12) Father and Mother acknowledge that Andrew C. Sheely, Esquire,
4
~i\'
1-- ~_-, ,_
I,: ',,-"",
,",~-' ,,;, ,.-;-,)~-:'-,,-.-
's;. ';'iii
-
is counsel for Mother and that Father is presently unrepresented. The
parties further acknowledge that they fully understand the legal effect
of the within Stipulation and Agreement and have fully reviewed the same
in its entirety prior to execution of this Stipulation and Agreement.
Furthermore, both parties acknowledge that their execution of this Agree-
ment and Stipulation has been done voluntarily and knowingly and that
their execution is not the result of any duress, undue influence, fraud,
concealment, overreaching, coercion, or other unfair dealing on the part
of the other.
(13) Both parties agree that an Order of Court shall be entered
which incorporates the terms of this Stipulation and Agreement. Not-
withstanding such Order of Court, the parties may, by mutual consent,
modify the terms of this Agreement. In the absence of mutual consent,
the terms of this Stipulation and Agreement shall control.
IN WITNESS WHEREOF, the parties have hereunto set their hands and
seals the day and year first above written.
W;;:J~
&)~
(SEAL)
R~ /I--~
Ronald K. Hof n
(SEAL)
5
:t';''"'j~'j<- ,~-.;;., =t.~'tII:'-~~ii!-:.Iltil:!:~,~)df'.j,'\!$1t"'~@Ii~.,j~l!i1"'lI6!i~ '~)'It'l1'1 ~~ '"'
,I." IUJ!, JI
w
L
II
"""'," ,.,.L"~.,, .,,,m '" ,.
-
Iii
lftfrf'
^~ .
'~~ ;'-''''''- '~~
., 1jlli11
;:J
[i~
;;~:'- r
(/) .~;
-<,~ .,.
r;-\, ,
~:: ;-:'
5-':: ~~~\
'.
?:j
"""
II
"'c'
-.,
'1
.,
.1''::;
-' ~'~)
-:',i=i
__;.c)
(~:5m
.:;.:.~
::0
-<
t::)
:v
(;0
,~" -", -
:f. :tiff. :ti:t:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
KIMBERLY M. HOFFMAN,
.
No. 01-6281
PLAINTIFF
VE:R$US
RONALD K. HOFFMAN,
DEFENDANT
DECREE IN
DIVORCE
AND NOW,
.~ 2.-b
~2 , IT IS ORDERED AND
DECREED THAT
KIMBERLY M. HOFFMAN
, PLAINTIFF,
AND
RONALD K, HOFFMAN
, 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
ATTEST~
~
( d PROTHONOTARY
. c
Yr:':~
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
J,
. ,___J"..," _ '. ~"""""_ ., 11"1.._, ~_~ _ ~~
,
,'"
, < . ,:t.(
,I~/"e!);;' /a;I. ~~.4/~ ~~",ZA/l
J ;;270;2 71~ ~ Z; ~~~
~
~
",..---.., ~
..,,41II!l1m_F~~"'llWWfl1'1'~"~~W'i,_~!P;;~'lfI.'Wl~[~~1i't~~~~,~~'"
,
.....
~ ~
,l
.','
~,' ""', '-'-"~~'-,~~~
KIMBERLY M. HOFFMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
RONALD K. HOFFMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following
information to the Court for entry of a Divorce Decree:
1. Grounds for Divorce: Irretrievable breakdown under
Section 3301 (C) of the pennsylvania Divorce Code.
2. Date and Maj1ner of service of the complaint:
Certified Mail, Acceptance of Service November 16, 2001.
3. Complete ei therparagraph ( a) or (b).
(a) Date of execution of affidavit of consent required by
Section 3301 (C) of the pennsylvania Divorce Code: by Plaintiff on
March 14, 2002 and by Defendant on March 14, 2002.
(b) (1) Date of execution of the affidavit required by
Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of
filing and service of the plaintiff's affidavit upon the
respondent: Not applicable.
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:
Not applicable
(b) Date Plaintiff's Waiver of Notice in Section 3301 (C)
was filed with the prothonotary. March 22. 2002
Date Defendant's Waiver of Notice in Section 3301 (C)
Divorce was filed with the prothonotary. March 22, 2002
A~.~h~qUire
Attorney for Plaintiff
~
~,
"" "" ---
~, ,~,-~.,
,0
"j';l<'''',~!!:;jj~'!i~~''''"''''o;<l
l6Ji' .-J:!iI:lA..~ if~'~ ~- ~,"'=~" ~~,;" ~ Illil
~. -~ ., ,,,'-
-rJf-!'"
rn;:'i
;-::::;
--::""1'
~t.,
(n.
.<'
r:;:
~i~
on;;
o_~
~~, . ~" "".
Q
?c-:::
. -~,
;:'\')
~>. ...
I',,)
'"I
;t:;;.,
ill
),0;:::.
f~;'/i
~
5cJ
-<
OJ
....-
-
~- ~
",~;J.
"--~
,- ~-',
_._(-. !1lIi1~,Hl!!;'-'bl:&;,;;;;i
KIMBERLY M, HOFFMAN
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA .
v.
01-6281 CIVIL ACTION LAW
RONALD j(, HOFFMAN
DEFENDANT
IN CUSTODY
ORDER OFCOlJRT
AND NOW, Wednesday, November 14, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Semite Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, December 11, 2001 at 1:00 PM
for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. AIl children age five or older may also be present at the conference, Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Melissa P. Greevy. Esq. ~
Custody Conciliator '
\ lbe Court of Common Pleas of Cumberland County is required by law to comply with the Americans
~ Disabilites 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,
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY 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
Telephone (717) 249-3166
Ol')
~
':;p
~
., -
-,"^--'"',^",,.;
,','o,.<c,,,-,,,-,,,,:-,,o,,.,, i"-~",
'<i!:Il"",J;tiu~~i!h'.&~_!':~""l',i""!I>~>il\I&im.wli'&i~~;Cl3W~'f'W,j~,,,,;,&_~'ll:liii"'",,,!"",;;,-
O~
",," ~C ,....f.li'S
~'L~. 1-.,,-,," -I'...'L
, "c'cv'j'J(',r.'(1T';Hi
. , ",,- ....I',,-,jr'\
I ". ."IO....c
OJ NO\ I;) lit] '.J';
" '--.~1 ," ,,' 1 ("'~,I lNT\!
CUrvit:H:hL.r\,\JU \..},)VI I
PEI~NSYLVAN!A
/I/I~-;Ol- Ckd, cor'!. m~\l'i-cl --+0 Miy !t..a:-fy
A)af.1C'Z:-lna I &:.c( --Ie::, ~.
CoP'! vn~ Lbc -.Jo fJ+I.y ~U,/
_n."~. ,_"
. "."
~-~-,~"~< .", ,,,- -, ,,-"""-",~.~~. ~ --.-. ~ -~~,-'",,,~,," -. ,~~"
.....-.,,,",,,"
~"~-~",
~<~ ,",,,"","",~',..'
,,< "
..,j,
-';,
J;.>- '" c- ""'-_ '. ',",~~ ~'-~i'~;'<'--"-"">~- ,
- ',-,:,tb
,
KIMBERLY M. HOFFMAN,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - Law
IN DIVORCE
vs.
.
.
RONALD K. HOFFMAN
Defendant
01-(od81 CC\}\l
ORDER OF COURT
AND NOW, r 2001 , upon consideration of
the attached Custody Complaint, it is hereby directed that the
parties and their respective counsel appear before
, the
conciliator, at
on the day of
2001, at o'clock___.m., for a Pre-Hearing Custody
Conciliation Conference. At such conference, an effort will be made
to resolve the issues in dispute; or if this cannot be accomplished,
to define and narrow the issues to be heard by the court, and to
enter into a temporary order. Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order.
,
FOR THE COURT,
By:
Custody Conciliator
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.
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
717-249-3166
;,)
,,-,.-,.
J ,,__
~','<' - -"<',' , ,; ,.
" ;,;
KIMBERLY M. HOFFMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - Law
: IN DIVORCE
RONALD K. HOFFMAN
Defendant
01-w;>31
NOTICE TO DEFEND AND CLAIM RIGHTS
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 r the case may
proceed against 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 with your
children.
When the grounds 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 the Cumberland County Courthouse,
Carlisle, pennsylvania.
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) 249-31~ St. ~
BY (! -~.
Andrew C. Sheely, Esq ire
PA. I.D. No. 62469
127 S. Market Street
P.O. BOx 95
Mechanicsburg, PA 17055
717 697-7050
Attorney for Plaintiff
~
I'", , -~"""' ,-"',-",,,~,~ ~,>'. i'~h
~"' ;;_:,;'~::;':~j
Andrew C. Sheely, Esquire
127 s. Market street
P.O. BoX: 95
Mechanicsburg, PA 17055
PA 1D NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
KIMBERLY M. HOFFMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - Law
IN DIVORCE
RONALD K. HOFFMAN
Defendant
:
01 - ~ J3 {
COMPLAINT
1. Plaintiff is KIMBERLY M. HOFFMAN, an adult individual who
currently resides at 633 Williams Grove Road, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
2. Defendant is RONALD K. HOFFMAN, an adult individual who
currently resides at 247 East Ridge Road, Lewisberry, York County,
Pennsylvania, 17039.
3. Plaintiff and Defendant have been bona fida residents of
the Commonwealth of pennsylvania for at least six (6) months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on May 4, 1997, in
Annapolis, Maryland.
5. There have been no prior actions of divorce or annulment
between the parties.
6. Neither party is a member of the armed forces of the United
States of America.
7. Plaintiff has been advised of the availability of marriage
counseling and understands that she may have the right to request
~B'
i _,'
, ~1
,;..;;,';-;<
- :~:. ,i-' '-'-C';',...l- - .I;~'~--: '--<'~::':"";J-:J
"
that the court require the parties hereto to participate in
counseling.
a. The marriage between the parties is irretrievably broken.
9. Plaintiff avers that she is the innocent and injured spouse,
and that the Defendant has offered such indignities to Plaintiff so
as to render her condition intolerable and life burdensome.
10. This action is not collusive.
11. The parties separated on February 22, 2001.
WHEREFORE, Plaintiff requests your Honorable Court to enter a
decree in divorce divorcing Plaintiff and Defendant absolutely.
COUNT II - CUSTODY
12. paragraphs 1 -12 of this Complaint are incorporated herein
as if set forth at length.
13. Plaintiff seeks the entry of a custody order involving the
minor child, SAMUEL ROBERT HOFFMAN, D.O.B. January 17, 2000.
14. The parties previously resided together and are the natural
parents of the child.
15. During the past year, the child has resided with Plaintiff
at 633 Williams Grove Road, Mechanicsburg, Cumberland County,
Pennsylvania.
16. No present custody order exists and Plaintiff has no
knowledge of any other litigation concerning custody of the
child in this or another court and Plaintiff has no information of a
custody proceeding concerning the child pending in a court of this
Commonwealth.
2
~
-~-
H"
..
. ,
"'I
--,--"",.;',,'
1',<'"
. - "'<:-"':-'''''',--'
>, ; ;; :,,,-,-,:~;.,-- , .
tBi"'i&j
17. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to have
custody or visitation rights with respect to the child.
lB. An Order of Court is necessary to develop a routine period
of custody along with holiday schedules and terms which address
other important dates for custodial purposes.
19. The best interests and permanent welfare of the child will
be served by ordering that both parties share legal custody of the
child and directing that Plaintiff have primary physical custody of
the child because Plaintiff is a fit parent who can take care of the
child and who can provide him with a supportive, safe and healthy
environment.
20. Plaintiff is capable of insuring a supportive and loving
environment for the child, a home with appropriate lodging and
insuring that the child is afforded proper care.
WHEREFORE, KIMBERLY M. HOFFMAN, Plaintiff herein, respectfully
requests that your Honorable Court enter a Custody Order which
grants Plaintiff legal custody and which grants Plaintiff primary
physical custody of the child.
Date: November L, 2001
A:ZJ~~'
Andrew C. Sheely, Esquire
Attorney for Plaintiff
Pa. I.D. No. 62469
127 S. Market Street,
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
3
~
" '. ~ ,I
I~~
, ,- - - - '- .-,. "":~' ' , j.' ','j
,~; ':'~''''.':/-'i; ~::, ,c""",, ;'" -" ~;" '~l\"j
"
" .
VERIFICATION
I verify that the statements made in this Complaint for Divorce
and Custody 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.
Date: November :2, 2001
""0
"'d...~-",~,'.
-- ""-'''--'.rl1lillll~i~lm._.
"""'"'~'I.>-.w-~""WjlMdillil
--'-- "~.n~~""._ ,
J... " '-- -' "- L. --if,.,;jl:@:J'J!!ijdlli1W~
~' ':~Zk1,M~
"
p
C
N~
~~
-. -
~ ~
:t~
--.
'-=~\i.i:.i<~< -ltC' ,- ,- ,"'.
~
<;0 ~
-.t::. ~
err <;>
t.. ~
t>' 8
~& t
e=~
~~-~-'
, ,~
(')
~.;
o<.:'~
"lJij-.-i
fTIPI
2. ~~:~'
;2: c-
S?<-
r;'~:
:.,c-\..",
~~r~
)..-,\...,
s
~~
'-<
Mi~'-
[-,.:,
-TO
en
~
~J:::
-<;.
1.--" ,. " ""-"--"-
'_.[
".,.,
, ",
I
mJi"i
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
KIMBERLY M. HOFFMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
RONALD K. HOFFMAN,
Defendant
01-6280 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c} of the
Divorce code was filed on November 2, 2001.
2. ~he marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service the Complaint.
3. 1 consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
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.A. Section 4904 relating to
unsworn falsification to the authorities.
DATE:
M,arc]1 14, 2002
K,~~"-
Kimberl M. Hof
'1'\\.
!.,j~~~llli~~(' ;(~~~~~.~'ii;i$~J%,;~ci;,l~~~~-'~~d.fjir'
~.~~
i(\llr1V
f-l!lIiIi~"-'
"l'ji
>~,.~<
;~r:-'
L~::, '
-',..,--,
Sl.'::'
!;Sic
5~~~:'
'-";'"'-'<-
(')
C
:::...
..<:::
-0
-.<
C:-J
[',-)
(~i
-~ci
:"[,:
-,
;'::J
f"'J
f'''
1.f;J
0,
.
''-1 . , , ~', - --" . "
I,
',_,', .;\,,-J' " ":-"~.4;"'
,'__""""C;j
Andrew c. Sheely! Esquire
121 S. Market street .
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
711-697-7050 (Phone)
711-697-7065 (Fax)
KIMBERLY M. HOFFMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
RONALD K. HOFFMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on November 2, 2001. I acknowledge that I
received a copy of the divorce complaint on November 16, 2001.
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 of divorce after
service of notice of intention to request entry of the decree.
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.A. Section 4904 relating to
unsworn falsification to the authorities.
DATE: ~.. MOlt':c:JlI4, 2002
~~ ~man-
11M
~'~-::-;;{'-:ii!ij~~~~il~;Jiili:.Jfl~~,,;-li!l~{~fU!.'~~t~iI~fi1~~IIII'lii
,
l!i;liiioiil('l' 1- ':lii.~ -~."
{i
.,i:
(:::) C)
~'"0 Tj
-rJ :;.,,"
fl'f Ii
Z :;:;,J " i--
:..::: ;"v ~.,
(r) r..... ~,
;:-::, c--.::)
:;.. ::-::--" ._~ i
~ c=S
)> '-;9 - ~-n
,~
::;::!
. -J :r~
~,
,. ~ ~ >
, j ,. , 'C <' -~, '
~-, ,'. --, ,-" - =-~ ='o''''''y"",''
Andrew C. Sheely, Esquire
127 S. Market street ~
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
KIMBERLY M. HOFFMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
RONALD K. HOFFMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 decree 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.A. Section 4904
relating to unsworn falsification to the authorities.
DATE: :'"M'll;'!l':Ch, 14, 2002
"~j
~~",j<-'; ~'~ui~J't<#.!ll.-~!"k~m,\~."~1\'~i&i~,I11~iIllJ~ilit.!Jt.il~iJF>"" '.f~~ rillill~a
....~~~
c)
5;
~G.::'-,~':"
[U;-~'-.
L:,_.
C/,',
,'.---\
<-',:
~
=~
~ ~
"';:
;~
s-:)
"
: ~ '"
:0
:'''0
f"-...:'
,--
r---'"
:'j':'J:"
~,
,
,'-
':-;,)
-, .,
"\.:,:)
:.:,-;i.~
~,""j
:...;
.-1:--,
:r~
~.
, ' ,1- _.:,~ , _, .' ~ .'..
" """',j,"-,,",, ",
-- '~" ',.. -, , ",',
~'*-
Andrew C. Sheely, Esquire
127 s. Market Street .
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
KIMBERLY M. HOFFMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
RONALD K. HOFFMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301 lC) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 decree 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
I
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.A. section 4904
relating to unsworn falsification to the authorities.
DATE:
March 14, 2002
;:f~ ~(~
Ronald K. Hoff --
";
i~~hA fi c "',-,",""~,,, ~lliiliu'-:l-'~. ~'\~~~'~'-ji'tiunraiiM~~~.lftw,!,"$'~~~.'10j1ilhli~~4:L~~~:'" ~ ~..:'
J.lUJ.
-
~ -"
.,~ ,
,-,".,
, '''':'''-''",
"" 'lf1Ii!~~ _L,~'
.
-"'.., ~,~,-
~-'JlJlliiiiI;'" ,
<-
"TJ ~~::.
f'll ~.~~
Z~_~.
~=~
r-',- .
~S ....
~2'
:'.:j
-<
c'
d
II
.~~
C'
f\,.)
()
('I
:,-~3
~O
''0
f'0
CD
,
^")
"
--;~ -1'.
.~!~:f f~~
~
0--;
" I
'"
,:"....;L
,.,'___ "_.,'0'0_"
,
1iIi~~~
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7D65 (FaX)
KIMBERLY M. HOFFMANr
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
:
RONALD K. HOFFMAN,
Defendant
01-628/ CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVING COMPLAINT
COMMONWEALTH OF PENNS~LVANIA
S8
COUNTY OF CUMBERLAND ,
ANDREW C. SHEELY, being duly sworn according to law, deposes
and says that he caused a true and correct copy of the Divorce
'-"'.'-"'c..-'- '_ _'~/.
Complaint in the above-captioned matter to be served upon RONALD
K. HOFFMAN, by Certified Mail, Return Receipt Requested, as
indicated by the attached receipt cards, on November 16, 2001.
4A1c~
ANDREW C. SHEELY
SWORN to and subscribed before me
thi~~OOl.
Notary Public
My COIlUllission Expires :&f/UnW ;V},,Wo?t
NOTAIIIAL eEAl
ANNw. MARAN. NotaIY PlIbIlC
Mr~~-
".,)
...
,
::J-
l'-
::r-
eO
[J"'
[J"'
U1
ru
::r-
o
o
o
o
~ Ben To
~ RONALD K. HOFF
~ :;~::.;::i47-..EAS.T"-~.i~~~-.-.~OAD
o ....m'.......__..__..........................._..........................................-...-
d CI/f;_2IP+4 DILLSBURG PA
1"'- '.' - .,. . ,
Postage $
Certified Fee
Postmarl<
Retum Receipt Fee H.m
(End'orsement Required)
Restricted Delivery Fee
(Endorsement Required) $7.37
Total Postage & Fees $
.:C8mpll!t~;".ms''1;2; '~7 , ,3>', ~'ooffl'pl.l.r
item 4 if Restricted Delivery;s desired.
. P-rint your name and, address on the reverse
so that we can return the card to- you.
. -Attach this;~I\d:to the' back of the mailpiece,
or on the front if space permitS.
1. Article Addressed to:
RONALDK. HOFFMAN
247 EAST RIDGE RDAD
DILLSBURG,PA 17019
,..~..".
:~~ I" ;Jfl:'
,,j',;,,'
~ ,I
'1'1'
'~" ,~,~. ---.""'"
, -
.
Mechanicsburg Main Post Office
MECHANICSBURG, Pennsylvania
170553459
11/08/2001 (717)697-4641 05:20:35 PM
Sales Receipt
Sale Unit
Qty Pri ce
Product
Oescription
Final
Price
DILLSBURG PA 17019
First-Class
Restricted Del Ivery
Return Receipt
Certified
Label SerIal #:
$0,57
$3,20
$1.50
$2,10
70011940000425998474
Issue PVI:
$7,37
Total:
$7,37
Paid by:
Check
$7,37
Bill#: 1000500446769
Clerk: 04
- Thank VOll for- I/nllr h, ,ei .....^'"-'"'
'! j D. Is delivery addressdifferenf' ''Item 1?
If YES, enter de~lvery address below:
o Agent
Addressee
DYes
ONo
',';
-,0'-,
3. SerVice Type
~~JX Certified Mail D Express Man
D Registered D Return Receipt for Merchandise
D Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) IXI Yes
If/ IlIff I
ili !IIH j
J' f if-
\ ! .[1
if
.j;:^
1_$_-0952
'~
~,
q;::..:.L.: '- ~ 'i---lB:~~'--' ,',~'-",-";,,,-,~ '~;'W';0".;:;.;':;,f~'~,douJl2:i':~~;;,~r,~ im,o- li~
,~ ,--,
."
._~- . ~
O~ ,~ ," =_
; _~~';'~i,'.;;.o s_" ';':"'J _~
j.,. ".
"'
. ~C,0~_!
--~' "".""1('
___,_", '""';"'0,--'-'
'-i,?
...
0 CJ 0
C ,1
~- ~~
-0 --;-'-.
I:', '-:J
r~l ,..
"-::-:: , ;-q
.Z r~~)
(.') U) .-,:;::-:,l
-< , -=~()
,~.... "--,'
~8 --::J t~~
-~
N ~J
-~
Z ~ ?O
=< '0 -<
f:=-S
B#
.,-
. , .~'"
""
- " ~"-'
I _.
I~, "
,'1_. ~lJk,{jliliWhi_;
JAN 0 3 2002 p.
KIMBERLY M. HOFFMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 01-6281
RONALD K. HOFFMAN,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this /2U day of December, 2001, the Conciliator, having been notified
by counsel for Plaintiff that the parties have fully executed a Stipulation for Custody, hereby
relinquishes jurisdiction of the above-referenced custody matter.
FOR THE COURT,
Melissa Peel Greevy, Es
Custody Conciliator
~