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HomeMy WebLinkAbout99-042580 aI C.) o. ?A VIRGINIA E. TAYLOR, Plaintiff VS. JACK D. HOFFMAN, Defendant : IN THE, COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. ya5g ?i : CIVIL ACTION - DIVORCE 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 or property or other rights important to you, including custody or visitation of your children. When the ground 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, Cumberland County Court House, Cumberland County Courthouse, One Court House Square, 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 VIRGINIA E. TAYLOR, Plaintiff VS. JACK D. HOFFMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- f T S' 8 : CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301fc1 or fdl OF THE DIVORCE CODE COUNT NUMBER 1 DIVORCE 1. Plaintiff is Virginia E. Taylor, an adult individual residing at 502 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Jack D. Hoffman, an adult individual residing at Post Office Box 1152, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 31, 1993, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 7. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 8. Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. 9. Plaintiff requests the Court to enter a Decree of Divorce. 1) COUNT NUMBER 2 DIVORCE UNDER 3301 (a)(6) OF THE DIVORCE CODE 10. The averments of Paragraphs 1 through 9 above are incorporated herein. ll. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 12. Plaintiff requests the Court to enter a Decree of Divorce. COUNT NUMBER 3 CLAIM FOR EQUITABLE DISTRIBUTION 13. The Plaintiff and Defendant are owners of various items of personal property, furniture and household furnishings acquired during the marriage which are subject to equitable distribution by the Court. 14. The Plaintiff and Defendant are owners of various motor vehicles acquired during the marriage which are subject to equitable distribution by the Court. 15. The Plaintiff and Defendant singly or jointly have interests in various bank accounts acquired during the marriage which are subject to equitable distribution by the Court. 16. The Plaintiff and the Defendant have acquired during the marriage other marital property which is subject to equitable distribution by the Court. COUNT NUMBER 4 ALIMONY PENDENTE LITE, ATTORNEY'S FEES AND COSTS 17. Paragraphs 1 through 16 above are herein incorporated by reference. 18. By reason of this action, Plaintiff will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 3 19. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 20. Plaintiffs income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 21. Defendant has adequate income to provide for the Plaintiff's support and to pay her counsel fees, costs and expenses. COUNT NUMBER 5 ALIMONY 22. Paragraphs 1 through 21 above are herein incorporated by reference. 23. Plaintiff lacks sufficient property and income to reasonably provide for herself. 24. Plaintiff requires support to adequately and reasonably maintain herself. WHEREFORE, Plaintiff requests the Conrt to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; (b) Equitably distributing all marital property owned by the parties hereto; (c) Ordering the payment of alimony pendente lite, counsel fees and costs; (d) Ordering the payment of permanent alimony; (e) Such further relief as the Court may determine equitable and just. Dated: 4 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 67!-9600 I.D. # 53200 VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. . NO. .JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE VERIFICATION I, VIRGINIA E. TAYLOR, 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 the statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. VIR -, IA E. AYL a w 1``wv\N\?, `? w w o `? V \v1`f?v\\ p N ?.. OI y .,? m u 2 Q e r- F ? ? L ? r V ? eJ M? V d' p K ?' 1? is i';. CV ?'6 1 W m a w l V "¢ Lil ro 1 NIOG.197 ASV.040 COMMONYIIALTM 01 PSNNSYLVAMIA Ol PARTMENT OF NSALTM VITAL RECORDS 9 ?q - yas? COUNTY RECORD OF DIVORCE OR ANNULMENT ® (CHECK ONE( 11 • lIll.; NYMESA STATE I1LS CATS .1 HUSBAND Witt !. MAIOIN NAME 11/Rr IFF.- 1r..1 -. -.... \ T OF -4 n , I IA 10. RESIDENCE EYmrM R.O. Ci1Y. IP0, S, (bKIKY SNIP 11. PLACE r FPIISR ONMOY/ fA f I G r\'l I..?rlnocl_. QnT? rn.?rL. .(... C. 1\,rl,,A -D/? l-1 AT ,, // ?? pF'Y 13. RAINIER - 1 54 SLACK THSR Ilwnbl Y I X OPTHIS MARK co ? J 1E. PLACE OF ICAIPevI ObM N FpW/I covArml IE. DATE OF / OFTME J Two ? - - 3 MARMAO. e. C l MARRIAGE \ 11A. NYMIIR OI CMIL• 111. NYR OP OIIIXDINT DNIL' . .. 14. MUA.FIND I WIFE OTXIR IlM11T1 RA XY!!MD W F, OTMIR IMMIIPI IN TH9 .. DIA I/ D.. . © a ? Q ? OARR1I1G3 20. NUMSEROI HUSBAND WIFE SPLIT CUSTODY OTHER (SPRIT) r DIVORCE OR ANNULMENT CNILDAIN TO O ® O a. TOOV OF T OF DATE G/ DECREE IMPINRI IOPYI IYNII ]]. GATE wEPOAT SENT IYPAMI Y FM TO VITAL RECORDS ]A. SIONATUR/OP TRANECRISING CLUK VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - ?a 5g JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Virginia E. Taylor, in the above-referenced matter. DATE: I/,/?y Supreme Court ID #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717)671-9600 c q - C LLJ F yd l_ U ON a+ 7 U VIRGINIA E. TAYLOR, Plaintiff V, JACK D. HOFFMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4258 Civil CIVIL ACTION - DIVORCE AFFIDAVIT OF SERVICE I, Diane S. Baker, Esquire, hereby certify that a true and correct copy of the Complaint for Divorce was served on the Defendant by certified mail, restricted delivery, return receipt requested, on July 19, 1999, at the Defendant's last known address of: Post Office Box 1152 Mechanicsburg, PA 17055 The return receipt card is attached hereto as Exhibit "A". ran e S. Baker, Esquire Attorney for Plaintiff Sworn to and subscribed before me this 41 '-? day of J vl?t 1999. Nota ublic NOTARIAL SEAL KATHY M. SHUGHART, Notary Public Lower Paden Twp., Dauphin County My Comndssion Expires Jury 9, 2001 tiy 3 • •Cangate gems t anNor 2 for additions sa vkee. •Cedams 3 4a and 4b I also wish to receive the §$$ , , . so:Mr ? add=@ on the reverse of this lam so that we cart mum tNe -A following 9e1VICBB for an extra lee): S TS 0 ft e bnn to the We N IM meilgece, a an the back a spac W la e dose not 1, p Addressee's Address 4 5 • f RNum Rxe/pf Requested,w then jlpgM bebw the adid. mmiDar. -The RNum Receipt Wl show to 'tom du amide wp deevered and the date 2" RasfActed Delivery p dNNered..i.' consult posml8ster for fee. 3. ANCIe Addressed to: 4a. Article Number 1 \ JGCl li, r1U C1 EE \ c od 1 ?JG7( 4b. . Service Type ? R LL.-. e a Certlfled a (YlccyckC (Z t(1l x f , a Insured - J se p m rot ate ofl)llivery -? J o ?' 5, Received By: (Print Name) Y (Only If requested 8. Sip e: ( e or of 0 a = PS Fo6n 3811, Decem r t e4 Domestic Return Receipt f i EXHIBIT "A" VIRGINIA E. TAYLOR, Plaintiff V. JACK D. HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-DIVORCE AND RELATED CLAIMS NO. 99-4258 CIVIL NOTICE TO PLEAD To: Virginia E. Taylor C/o Diane Baker, Esq. P.O. Box 6443 27 South Arlene Street Harrisburg, PA 17112-0443 You are hereby notified to file a written response to the enclosed preliminary objections within twenty (20) days from service hereof or a judgment may be entered against you. WOLFE & RICE By: U John A Wolfe, Esq. Attorn ys for Defendant 47 West High Street Gettysburg, PA 17325 (717) 337-3754 JAW/sls VIRGINIA E. TAYLOR, Plaintiff V. JACK D. HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-DIVORCE AND RELATED CLAIMS NO. 99-4258 CIVIL PRELIMINARY OBJECTIONS TO COMPLAINT IN DIVORCE AND NOW, comes the Defendant, Jack B. Hoffman, by and through his attorneys, Wolfe & Rice, and files the following preliminary objections to complaint as follows: I. LACK OF JURISDICTION OVER PERSONS 1. Plaintiff has initiated an action for divorce with related claims by complaint filed July 13, 1999 in Cumberland County, Pennsylvania, a copy of which is attached hereto as Exhibit "A" 2. Plaintiff alleges in paragraph 1 of her complaint that Plaintiff resided at the time of the filing at and address in Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff has, since well prior to her execution of the verification and the filing of the complaint resided in and continues to reside in Cowansville, Butler County, Pennsylvania with an address of R.R. #1, Box 217B, Cowansville, PA 16218-9801. 4. Plaintiff alleges in paragraph 2 of her complaint that Defendant lives in a post office box in Mechanicsburg, Pennsylvania. 5. Plaintiff lives and has lived during the periods relevant to these preliminary objections at 1561 Town Hill Road, York Springs, Adams County, PA 17372. 6. Neither Plaintiff nor Defendant live in Cumberland County either at the time of the execution of Plaintiff's verification on the complaint or at the time of the filing of the complaint. WHEREFORE, Defendant respectfully requests that the Court dismiss for lack of jurisdiction the Complaint filed by Plaintiff against Defendant. II. IMPROPER VENUE 7. The allegations in paragraphs one through 6 of these preliminary objections are incorporated herein by reference as though set forth in full. 8. Defendant has initiated and action for divorce and custody against Plaintiff in Adams County, Pennsylvania where Defendant resides by complaint filed July 6, 1999, a true and correct copy of which is attached hereto as Exhibit "B" WHEREFORE, Defendant respectfully requests that the Court dismiss for lack of jurisdiction the Complaint filed by Plaintiff against Defendant or, in the alternative, transfer said action to Adams County pursuant to PA.R.C.P.NO. 1006 (e). III. PENDENCY OF PRIOR ACTION 9. The allegations in paragraphs 1 through 8 of these preliminary objections are incorporated herein by reference. 10. This Court should not exercise jurisdiction in this case as a prior action with the same parties for the same initial relief, divorce, is pending and has been pending in Adams County, 2 Pennsylvania at the time of Plaintiff filing this complaint. WHEREFORE, Defendant respectfully requests that the Court dismiss for lack of jurisdiction the Complaint filed by Plaintiff against Defendant or, in the alternative, transfer said action to Adams County pursuant to PA.R.C.P.No. 1006 (e). Respectfully submitted, WOLFE & RICE By: o o n A. Wol, Esq. 3 VIRGINIA E. TAYLOR, Plaintiff V9. JACK D. HOFFMAN, Defendant : IN THE COURT OF COMMO LTAS p, : CUMBERLAND COUNTY, PES1yYVAN NO. 99 - `1v?S? `' 'y CIVIL ACTION - DIVORCE b ` a o -? 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 or property or other rights important to you, including custody or visitation of your children. When the ground 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.. Cumberland County Court House, Cumberland County Courthouse, One Court House Square, 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 VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301f0 or fdl OF THE DIVORCE CODE COUNT NUMBER 1 DIVORCE 1. Plaintiff is Virginia E. Taylor, an adult individual residing at 502 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Jack D. Hoffman, an adult individual residing at Post Office Box 1152. Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 31, 1993, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 7. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 8. Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. 9. Plaintiff requests the Court to enter a Decree of Divorce. 2 COUNT NUMBER 2 DIVORCE UNDER 3301 (a)(6) OF THE DIVORCE CODE 10. The averments of Paragraphs I through 9 above are incorporated herein. 11. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 12. Plaintiff requests the Court to enter a Decree of Divorce. COUNT NUMBER 3 CLAIM FOR EQUITABLE DISTRIBUTION 13. The Plaintiff and Defendant are owners of various items of personal property, furniture and household furnishings acquired during the marriage which are subject to equitable distribution by the Court. 14. The Plaintiff and Defendant are owners of various motor vehicles acquired during the marriage which are subject to equitable distribution by the Court. 15. The Plaintiff and Defendant singly or jointly have interests in various bank accounts acquired during the marriage which are subject to equitable distribution by the Court. 16. The Plaintiff and the Defendant have acquired during the marriage other marital property which is subject to equitable distribution by the Court. COUNT NUMBER 4 ALIMONY PENDENTE LITE, ATTORNEY'S FEES AND COSTS 17. Paragraphs I through 16 above are herein incorporated by reference. 18. By reason of this action, Plaintiff will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 3 11-1 19. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 20. Plaintiffs income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 21. Defendant has adequate income to provide for the Plaintiffs support and to pay her counsel fees. costs and expenses. COUNT NUMBER 5 ALIMONY 22. Paragraphs 1 through 21 above are herein incorporated by reference. 23. Plaintiff lacks sufficient property and income to reasonably provide for herself. 24. Plaintiff requires support to adequately and reasonably maintain herself. WHEREFORE, Plaintiff requests the Court to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; (b) Equitably distributing all marital property owned by the parties hereto; (c) Ordering the payment of alimony pendente lite, counsel fees and costs; (d) Ordering the payment of permanent alimony; (e) Such further relief as the Court may determine equitable and just. Dated: Fie. r, Esquire 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 I.D. # 53200 4 VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. . NO. .JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE VERIFICATION 1. VIRGINIA E. TAYLOR, 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 the statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. - ?xr LCL VIR E. AYL JACK D. HOFFMAN, IN THE COURT OF COMMON PLEAS Plaintiff OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION-DIVORCE AND CUSTODY V. No. -s- VIRGINIA E. TAYLOR, Defendant You, Virginia E. Taylor, Defendant, have been sued in court to obtain custody of the child: Brandon Jack Hoffman. You are ordered to appear in person at the Adams County Courthouse, Courtroom No. 3, 2nd Floor, Gettysburg, PA, on I? , 1999, at 1:L o'clock -L.M. for. X a conciliation or mediation conference. -X_ a pretrial conference. a hearing before the Court. -X_ The presence of the children is not required The presence of the children is required. If you fail to appear as provided by this Order or to bring the children, if so ordered, an Order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Court Administrator Adams County Courthouse Gettysburg, PA 17325 Phone: (717) 337-9846, 1-888-337-9846 FAX: 334-8817 C 14, sir "13 AMERICAN WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Adams 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. BY THE COURT, Dated: uk f 91 131 ROBERT G. BIGHMA Robert G. Bigham, J. COURT ADMINISTRATOR'S NOTICE: Attention is directed to Local Rule 1915.1 which requires submittal of a memorandum at the time of the conference or hearing. NOTE: Bring calendar - hearing, if needed, will be scheduled at conference. DOC-17 y, J 19 This being a true tt ed copy taken from d,comp reo with the original 2 Attest: / r". JACK D. HOFFMAN, IN THE COURT OF COMNON PLEAS Plaintiff OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION-DIVORCE AND CUSTODY V. VIRGINIA E. TAYLOR, N0. Defendant NOTICE TO DEFEND AND CLAIM RTrHrPq YOU ARE BEING 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 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 Adams County Courthouse, First Floor, Gettysburg, 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. Court Administrator Adams County Courthouse Gettysburg, PA 17325 Phone (717) 334-6781 Ext. 213 _ r. . JACK D. HOFFMAN, IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION-DIVORCE AND CUSTODY V. NO. VIRGINIA E. TAYLOR, Defendant COUNT I-DIVORCE UDDER SECTION 3301(c) 1. Plaintiff is Jack D. Hoffman, who currently resides at 1561 Town Hill Road, York Springs, Adams County, Pennsylvania 17372, since June 18, 1999. 2. Defendant is Virginia E. Taylor, whose current resides is unknown. 3. Plaintiff has been bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 31, 1993, at Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. COUNT I1-CUSTODY 9. The allegations of paragraphs 1 through 8 are incorporated herein by reference as though set forth in full. 10. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE Brandon Jack Hoffman 1561 Town Hill Road, 6 York Springs, Adams County, Pennsylvania 17372 The child was born out of wedlock. The child is presently in the physical custody of Plaintiff, who resides as set forth above. During the past five years, the child has resided with the following persons and at the following addresses: LIST OF ALL PERSONS LIST OF ALL ADDRESSES DATES Plaintiff and Plaintiff's 1561 Town Hill Road, June, 1999 sister, Sandra Sassman York Springs, Adams to present County, Pennsylvania 17372 Plaintiff and Defendant 502 Hogstown Road 1993 to Mechanicsburg, PA 17055 June, 1999 The mother of the child by adoption is Plaintiff. The father of the child by adoption is Defendant. 11. The relationship of Plaintiff to the child is that of adopted father. 12. The relationship of Defendant to the child is that of adopted mother. Plaintiff does not know with whom she resides. 2 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court except for the adoption proceeding in Cumberland County, Pennsylvania. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth other than as set forth above. 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. 14. The best interest and permanent welfare of the child will be served by granting Plaintiff primary physical and legal custody because it would be in the best interest of the child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child to him. WOLFE & RICE By: U John Wolfe, Esq. Attor eys for Plaintiff 47 West High Street Gettysburg, PA 17325 3 JACK D. HOFFMAN, IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION-DIVORCE AND CUSTODY V. NO. VIRGINIA E. TAYLOR, Defendant I verify that the statements made in this Complaint 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 author 6-? Date: 7 3 ?? J ck D. Hof Pt p , Plaintiff VIRGINIA E. TAYLOR, Plaintiff V. JACK D. HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-DIVORCE AND RELATED CLAIMS NO. 99-4258 CIVIL VERIFICATION The undersigned, Jack D. Hoffman, hereby verifies that the facts set forth in the foregoing Preliminary Objections are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. i Date: !TV G . %Z /99c) By: ack D. Hoff ,,.. c ? L: G ?`" ,1 : ;t 1 i_ ?' ._ - .. '.; U lJ ?' WOLFE & RICE Attorneys at Lam 47 West High S'.Focr Gemsburg, Pennsylvania 17325 (717) 337-3754 VIRGINIA E. TAXLOR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - DIVORCE AND RELATED CLAIMS V. NO. 99-4258 CIVIL JACK D. HOFFMAN, Defendant CERTIFICATE OF SERVICE The undersigned, Lucinda M. Chrismer, hereby certifies that a true and attested copy of Preliminary Objections were served upon Plaintiff, through her counsel, by depositing same in the United States mail, first class postage prepaid, at Gettysburg, Pennsylvania, on August 9, 1999 and addressed to Virginia E. Taylor, c/o Diane Baker, Esquire, P.O. Box 6443, 27 South Arlene Street, Harrisburg, PA 17112-0443. ` / QI ?- Date: / ( ( " ?CfLC Lu lnda MSC rismer o C-.• cq car .;_ .?,> v CU ccn VIRGINIA E. TAYLOR, : IN THE, COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99 - 4258 Civil JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE RULE TO SHOW CAUSE AND NOW, this ,yMday of , 1999, upon consideration of the attached Petition to Withdraw as Counsel, a Rule is issued upon the Plaintiff/Respondent, Virginia E. Taylor, to show cause why Diane S. Baker, Esquire, should not be permitted to withdraw as counsel. re f is Rule returnable / 6 days from the date of service. By The Cou Judge I ^,. 'I Y r?',?15YU.'R. i VIRGINIA E. TAYLOR, Plaintiff V9. JACK D. HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4258 Civil : CIVIL ACTION - DIVORCE PETITION TO WITHDRAW AS COUNSEL AND NOW, comes the attomey for Virginia E. Taylor's, Diane S. Baker, Esquire, and petitions the Court to withdraw as counsel and in support thereof, avers as follows: 1. Plaintiff in this divorce action is Virginia E. Taylor, hereinafter referred to as Respondent, an adult individual with a last known address of 502 Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Jack D. Hoffman, who is represented by John A. Wolfe, Esquire, 47 West High Street, Gettysburg, Pennsylvania, 17325. 3. Respondent's counsel, Diane S. Baker (hereinafter referred to as "Petitioning Counsel"), requests leave of court to withdraw as counsel as follows: a) On or about July 27, 1999, Petitioning Counsel advised Respondent that she would not be able to attend a support conference scheduled for August 10, 1999. Counsel had just received the notice of the support conference and had a prior court appearance scheduled for the same day and time. Petitioning Counsel advised Respondent that the support conference could be postponed, she could attend without counsel, or she could obtain alternate counsel. b) On July 27, 1999, Petitioning Counsel received a correspondence via e-mail from the Respondent indicating that she had hired Melissa Greevy, Esquire to represent her and that her file should be sent to Ms. Greevy. The correspondence also requested that her final bill be sent to her. Counsel discussed the matter directly with Ms. Greevy, who confirmed that she was going to take over representation of Ms. Taylor. Counsel sent the entire file to Ms. Greevy, including a final bill for services, which remains outstanding. A copy of the e-mail correspondence is attached hereto as Exhibit "A" and incorporated herein by reference. C) On or about August 12, 1999, Petitioning Counsel received a correspondence from Ms. Greevy indicating that she was not going to represent Ms. Taylor in the divorce and had advised her that she should obtain another attorney. Petitioning Counsel immediately sent Ms. Taylor an e-mail correspondence requesting the name of her current attorney, so that a Praecipe to Withdraw could be properly filed. d) Respondent has not contacted Petitioning Counsel nor has Petitioning Counsel received correspondence from any other attorneys indicating representation of Ms. Taylor. 4. Petitioning Counsel, requests leave of court to withdraw as counsel for the following reasons: a) Respondent has told Petitioner that she does not want to be represented by her any further and has requested that the contents of her file be forwarded to another attorney. b) Respondent has not contacted Petitioning Counsel to confirm that she has obtained alternate counsel. WHEREFORE, Petitioner. Diane S. Baker, respectfully requests this Honorable Court issue an Order upon the Respondent, Virginia E. Taylor, to show cause why Diane S. Baker should not be permitted to withdraw as counsel and in the interim, directing that Petitioning Counsel, Diane S. Baker, be relieved of further responsibility as counsel in this action pending final disposition of this Petition. ";/,q o Dim S. Baker, Esquire Supreme Court ID #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99 - 4258 Civil JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE VERIFICATION I, DIANE S. BAILER, ESQUIRE, verify that the statements made in the foregoing Petition to Withdraw as Counsel are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. DATE: E S. BAKER, ESQUIRE VIRGINIA E. TAYLOR, Plaintiff VS. JACK D. HOFFMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4258 Civil CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE 1 hereby certify that on this -I I day of Au ,)1 7 1999, a true and correct copy of the foregoing Petition was served on the following person by United States Mail, postage prepaid, addressed as follows: Virginia E. Taylor 502 Hogestown Road Mechanicsburg, Pennsylvania 17055 John A. Wolfe, Esquire 47 West High Street Gettysburg, Pennsylvania 17325 Djane-S. Baker, Esquire Supreme Court ID 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 ,n N J ?? Jl W m .. a a w o Cr: N ? y F ' - . Q m m i.lr:^ cn ? a m va 0 w n e go a. a: D jr V G1 CJ Z = _Q AUG 2 3 199'. VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99 - 4258 Civil JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE ORDER AND NOW, this 1qA day of , 1999, upon consideration of the attached Petition to Make Rule Absolute, Diane S. Baker, Esquire, is granted leave of court to withdraw as counsel for Plaintiff, Virginia E. Taylor. BY THE COU JUDGE EDWARD E. GUIDO '? r. ?. I n 1; :,?., ;i?l VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99 - 4258 Civil JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE PETITION TO MAKE RULE ABSOLUTE AND NOW, the comes Diane S. Baker, Esquire, and Petitions the Court to withdraw as counsel for Virginia E. Taylor and in support thereof avers as follows: 1. On August 24, 1999, the Honorable Edward E. Guido issued a Rule upon the Plaintiff/Respondent, Virginia E. Taylor, to show cause why Diane S. Baker, Esquire should not be permitted to withdraw as counsel. The Rule was returnable ten (10) days from service. 2. On August 26, 1999, Petitioning Counsel served the Rule to Show Cause upon the Respondent, Virginia E. Taylor, and upon the Defendant, Jack D. Hoffman's attorney, John A. Wolfe, Esquire. A copy of the Certificate of Service is attached hereto marked Exhibit "A" and incorporated herein by reference. 3. It has been more than ten (10) days since service of the Rule to Show Cause, the mail has not been returned and there has been no response from filed by any interested party in this matter. WHEREFORE, Petitioning Counsel, Diane S. Baker, Esquire, respectfully requests this Honorable Court issue an Order granting her leave of court to withdraw as counsel. ctf ?s mitted, DATE: C, iane S. Baker, Esquire 1-/ID - 9 I Supreme Court ID #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 VIRGINIA E. TAYLOR, Plaintiff V3. JACK D. HOFFMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99 - 4258 Civil : CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this - Z?g day of _ /our U f Zj 1999, a true and correct copy of the Rule to Show Cause, which was executed on August 24, 1999, for the Petition to Withdraw as Counsel, was served on the following person by United States Mail, postage prepaid, addressed as follows: Virginia E. Taylor 502 Hogestown Road Mechanicsburg, Pennsylvania 17055 John A. Wolfe, Esquire 47 West High Street Gettysburg, Pennsylvania 17325 Respectfully e , n? Baker, Esquire Supreme Court ID 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 171 12-0443 (717)671-9600 Exhjb1 "Pt" VIRGINIA E. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99 - 4258 Civil JACK D. HOFFMAN, Defendant : CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE hereby certify that on this day of 1999, a true and correct copy of the Petition to Make Rule Absolute, was served on the following person by United States ;Mail, postage prepaid, addressed as follows: Virginia E. Taylor 502 Hogestown Road Mechanicsburg, Pennsylvania 17055 John A. Wolfe, Esquire 47 West High Street Gettysburg, Pennsylvania 17325 Res 7 Baker 7Esquire Supreme Court ID 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 ift 1 i. t P UI 0 m m a a w O W w N Y ? m m tl1 v° W n z m N j Q q p ¢ 4 n I71 m a V m O 0 a o 7 n O wN N N ¢ W Z Q = O 4 19 V" VIRGINIA E. TAYLOR, Plaintiff VS. .JACK D. HOFFMAN, Defendant : IN 'rHE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4258 Civil : CIVIL ACTION - DIVORCE PRAECIPE TO WITHDRAW To The Prothonotary: Please withdraw my appearance on behalf of the Plaintiff, Virginia E. Taylor, in the above-referenced matter. DATE: 1©/2111 Supreme Court ID 453200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 u,ID ? j.: Q !.'1 Q.. 1 cn J VIRGINIA E. TAYLOR, Plaintiff Vs. JACK D. HOFFMAN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET # 99-4258 CIVIL PRAECIPE Please enter my appearance as attorney for the Plaintiff, Virginia E. Taylor, in connection with the above captioned action. Resp xtf_ily submitted, WION, ZULLI & SEIBERT: BY: t 109 0? st Street P.O. B x 1121 H sbur , PA 17108 (717) 32 1488 LD. #1 16 Dated: July 11, 2001 VIRGINIA E. TAYLOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. JACK D. HOFFMAN, Defendant TO THE PROTHONOTARY: DOCKET #99-4258 CIVIL PRAECIPE Please mark the above referenced case settled and discontinued with prejudice. Respectfully submitted, WION, ZULLI SEIBERT: BY: F s A. Zulli, s cuss Street ox 1121 burg, PA 17108 (7 7) 232-1488 I.D.#15316 Dated: July 11, 2001