HomeMy WebLinkAbout99-03713
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c? • ? cep ce• .e:• ;ex • r::•;?
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF ,?FPENNA.
ROBERT LEE HOSTER,
Not. 9973713 CIVIL
Plaintiff
Versus
KELLEY ANN HOSTER,
Defendant
DECREE IN
DI VORCE
AND NOW, .. U.J4 cC 7.. 1,` .......... 19.99... , it is ordered and
decreed that .... • .ROBERT LEE HOSTER plaintiff,
and . . . . . . . . . . . . . . . . K. ELLEY ANN HOSTER • defendant,
are 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
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been entered;
NONE
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By The Court
Attest
:U' J
/• Prothonotary
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ROBERT LEE HOSTER,
Plaintiff
V.
KELLEY ANN HOSTER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3713
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint:
By certified mail on June 24, 1999.
3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce
Code: by Plaintiff September 30, 1999; by Defendant September 30, 1999.
4. Related claims pending: NONE
5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: October 1, 1999.
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: October 1, 1999. n
Date: 1" t° n 5 c ?6a4 j Vk) L
Austin F. Grogan Es
Attorney for Plaintiff
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Id k 59020
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ROBERT LEE HOSTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO, ?W 0?
KELLEY ANN HOSTER, IN DIVORCE
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement 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, 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) 249-3166
ROBERT LEE HOSTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 9 % . 2'I /3 (?u* E Tu »?
KELLEY ANN HOSTER, : IN DIVORCE
Defendant
COMPLAINT
1. The Plaintiff is ROBERT LEE HOSTER, Social Security number 207-52-1796,
who currently resides at 513 East Coover Street, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
2. The Defendant is KELLEY ANN HOSTER, Social Security number 180-56-
4048, who currently resides at 26 Glebe Avenue, Newville, Cumberland County, Pennsylvania
17241.
3. Plaintiff and Defendant have been bona fide residents in 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 October 23, 1993 at Berks County,
Pennsylvania
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections
3301(c) and 3301(d), in that:
a) The marriage is irretrievably broken,
b) Plaintiff and Defendant have lived separate and apart since June 14,
1998 and continue to do so.
8. The 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.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
Respectfully submitted,
Dat w /C- (5f rJ
Austin F. Gro sq ire
24 North 32nd eet
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
I.D. #59020
VERIFICATION
I, ROBERT LEE HOSTER, verify that the statements made in the foregoing Complaint are
true and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn
falsification to authorities.
Date Aff
ROBERT LEE HOSTER
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ROBERT LEE HOSTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-3713 CIVIL
KELLEY ANN HOSTER, IN DIVORCE
Defendant
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Austin F. Grogan, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff, ROBERT LEE HOSTER, and that he did mail a true and correct copy of
the Complaint in Divorce in the above matter, by certified mail, return receipt requested, to the
Defendant, KELLEY ANN HOSTER, on June 21, 1999 at her last known address: 26 Glebe
Avenue, Newville, PA 17241 which satisfied the requirements of service by mail pursuant to
Pa.R.C.P.403. The signed receipt acknowledging receipt on June 24, 1999 is attached hereto as
Exhibit "A".
Austin F. Grojansq re
Attorney for Pla' tiff
11
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
ID #59020
m SENDER:
V- a Complete items l and/or 2 for additional services.
e • Complete items 3, 4a. and 40
.4r a Print your name and address on the reverse of this form so that we can return this
L card to You
j a Attach dlis fo/m to the front of the mellpiece, or an the back if space does not
yyermd.
d 'Return eipt will 10 Won hi mwlple the dato. numbor
y a The The Return Receipt still show to whom his article was cleh dehvemd ernd and the nn date
Oelrverod.
0 3. Aside Adtlressed h
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5. Race ed : (Print
6. Signatuur ((A?dd?e?sy:
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°_' PS Form 3811, December 1994
I also wish to receive the
following services (for an
extra fee):
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8. Addressee's Address(Onty it requested Y
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102595.99.9-o229 Domestic Return Receiot
EXHIBIT "A"
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ROBERT LEE HOSTER,
Plaintiff
V.
KELLEY ANN HOSTER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3713
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
June 18, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of 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. § 4904 relating to unworn
falsification to authorities.
Date 3° ! 9 4k?4
ROBERT LEE HOSTER
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ROBERT LEE HOSTER,
Plaintiff
V.
KELLEY ANN HOSTER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3713
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
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 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. §4904
relating to unworn falsification to authorities.
Date: 3
ROBERT LEE HOSTER
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ROBERT LEE HOSTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3713
KELLEY ANN HOSTER, IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
June 18, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of 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. § 4904 relating to unworn
falsification to authorities.
Date 6?J-2d99 JI si.L,
KELLEY N HOSTER
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ROBERT LEE HOSTER,
Plaintiff
V.
KELLEY ANN HOSTER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3713
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(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 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. §4904
relating to unworn falsification to authorities.
Date: wll 6??QD, _aiu,- KW
KELLEY NN HOSTER
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