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Home My WebLink About99-03014?? ? 'I I I 'v .? ?` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Denise D. Hoch, ? Civil Action-Law Plaintiff, ) ) VS. ) No. 99-3014 Civil Term ? William H. Hoch, ? Defendant, ) In Divorce a v.m. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF FRANKLIN ? SS: ) Martha B. Walker, Esquire, being duly sworn according to law, deposes and says that she is the attorney for the Plaintiff, Denise D. Hoch, in the above-captioned matter; that she did serve a true and attested copy of the Complaint Under Section 3301(c) or 3301 (d) of the Divorce Code by mailing the same to William H. Hoch, Defendant, by certified mail, restricted delivery, article number Z 284 176 288 on May 20, 1999, to his mailing address of 2262 Pine Road, Newville, PA 17241; that said certified mail article was delivered to Defendant, William H. Hoch, on May 29, 1999, all as appears from the receipt for certified mail and the return receipt attached hereto. WALKER, VAN HORN & MACBRIDE, a division of Barley, Snyder, Senft & Cohen, LLC By: Mart a B_ Walker, Esquire Atto ney for Plaintiff Sworn_ nd subscribed to before me this _LL) dayof.J If1)C. , 1999. 64 ?) 1. lduAt 11j, . ?6 Notary Public Notarial Seal Lisa M. Ecksline, Notary Public Cbambersburg Bom, Franklin County My Commission Erplres.lunc. 3, 2003 I Marmot, Ponnrylvania ,lssoaatuon of ^,o1a..os1 .07,Torm/AtYd+vd of SfNICC SENDER: =3 f « 1 to •dMtiona •• HOn. a •CanpM• /a end 1b I also wish to receive the , , . S ¦PtlM ye«naMW•dd=$wIII Warn. Of thle form DO that wi on rerun tints & cmd to o aAR h i following services (for an extra fe): CF Ac t onn to the front of the malpl•ca. or on the back a Opew do, not 1. ? Addressee's Address Q roMoto, y &Rw Rapt VAN Ohm 100 M ? am? I AFVdO• WON ddMW And y,?? 2. teatrktetl Delivery UJ l mm K. H( k saga Plw Road NcwV%?)c, PA I7ay1 ti. Signatu (Add ea or nq 9 X QM R ed r (Pnnr iJ e ? i , (C PS Form 3811, December 994 Consult postmaster for fee. 4a. Mcfe Number z ?,p q ! 71, d?JJ Q. Servke Type ? Registered ?CCar?lata ? Express Mail ? Insured ? Retum Reoelpi for Meadwt9ee ? COD Date of Delivery sL9-99 i aqd fee to paid) rase (Only 11 requested B. t 102595-97-B-0179 Uornestlc Return Receipt 284 176 288 Us Postal Service Receipt for Certified Mail No insurance Coverage Provided. • :J5 CeniliW Fea !• 9n Spe6al Delivery Fee ree ? -7 vl _r. /J m R nr _ c AI I 74 . .. +. I = t c. Ci cn .G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Denise D. Hoch, Civil Action - Law Plaintiff, VS. William K. Hoch, No.?F.R. 1999- nn 99 -30, q eIut L TrLrn Defendant, ) In Divorce a v.m. 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, 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 of the Cumberland County Court House, 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, PA 17013 (717) 249-3166 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Denise D. Hoch, VS. William K. Hoch, Civil Action - Law Plaintiff, ? 1 1 No. -R 1199- 99- 1 1 Defendant, ? In Divorce a v.m. COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE COUNT 1 DIVORCE 1. Plaintiff is Denise D. Hoch, a sui juris adult, who currently resides in Cumberland County, Pennsylvania, her post office address and residence being, 2262 Pine Road, Newville; Pennsylvania 17241, since February 19, 1982. 2. Defendant is William K. Hoch, a sui juris adult, who currently resides in Cumberland County, Pennsylvania, his post office address and residence being 2262 Pine Road, Newville, Pennsylvania 17241, since February 19, 1982. 3. The Plaintiff and Defendant are husband and wife, they having been married on August 2, 1980 in Walnut Bottom, Cumberland County, Pennsylvania. 4. Neither the Plaintiff nor Defendant is a minor or incompetent. 6. Plaintiff has lived and resided in the Commonwealth of Pennsylvania for a period of 44 years, and during the entire 6 months immediately preceding the filing of the Complaint, she has been a bona fide resident of said Commonwealth continuously and without interruption. 6. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Defendant has lived and resided in the Commonwealth of Pennsylvania for a period of 44 years, and during the entire 6 months immediately preceding the filing of the Complaint, he has been a bona fide resident of said Commonwealth continuously and without interruption. 8. There is not now pending nor has there ever been in this or any other state or jurisdiction any action for divorce or annulment of marriage between the parties except the action represented by this Complaint. 9. Plaintiff believes and therefore avers that the marriage subsisting between the parties has been irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a decree of divorce. COUNT II DIVORCE 10. The allegations of Paragraphs 1 through 8 hereof are incorporated herein as fully as though set out at large. 11. In violation of his marriage vows and laws of the Commonwealth, the Defendant, William K. Hoch, has offered such indignities to the person of the injured and innocent spouse, the Plaintiff, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a decree of divorce. COUNT III EQUITABLE DISTRIBUTION - SECTION 3502 12. The allegations of Paragraphs 1 through 8 hereof are incorporated herein as fully as though set out at large. 13. The parties have been unable to determine and equitably dispose of their respective rights and interests in the marital property. 14. Plaintiff will, within 60 days after service of this Complaint upon the Defendant, cause to be filed an inventory and appraisement of all property owned or possessed at the time this Complaint is filed. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide, distribute and assign the marital property pursuant to the provisions of Section 3502 of the Divorce Code. WALKER, VAN HORN & MACBRIDE, a division of Barley, Snyder, Senft & Cohen, LLC By: TMartha B. Walker, Esquire Attorney for Plaintiff I verify that the statements made in this Complaint are true and correct. 1 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: ,5 _ /--may Denise D. Hoch, Plaintiff L.:1 r; C i i r? tJ - u1. CL -r? Q u Q ?A (Z t t r Z-- ? ul qo rl Do v