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Home My WebLink About99-06743e ?t a ' `1 PAUL L. I IOFFMAN, Plaintiff' V. DIANE M. HOFFMAN, Defendant IN TFIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99-/.7q3 CIVIL TERM IN DIVORCE NOTICE TO DEFEND ANI) CLAIM RIGIVII'S 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 wamcd 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 Prothonotary's Office 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 ANNULMENTIS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF TI IEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPI-IONE 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 ; 2A I IOFFMAN, : IN TI18 COURT OI' CONINION PIA-AS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION - LAW 4. I I01'FMAN. NO. 99 - l0 7V CIVIL TERM Defendant IN Df VORCP. COMPLAINT 1N DIVO)I2C1 Plaintiff; Paul L. I foflinan, is an adult individual currently residing at 710 Dogwood oiling Sprin,, s, Cumberland County, Pennsylvania, since 1937. 2. Defendant, Diane M. 11offinan. is an adult individual currently residing at 710 Dogwood Terrace, Boiling Springs, Cumberland County, Pennsylvania, since 1937. 3. Plaintill' and Defendant have been bona fide residents of' the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. 'rhe panics vvere married on August: I, 1974 in Auburndale, Polk County, Florida. 5. There have been no prior actions ofdivorce or for annulment between the parties. 6. The marriage between the parties is irrctrieNabh' broken. 7. Plaintifl'bas been advised that counseling is available and that Plaintifl'may have the right to request that the Court require the parties to participate in counseling. 1 GRLPOU, the Plaintill'requests your Honorable Court to decree that the Plainti l9' from the Defendant pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. J- f C, Attorney for the Plaintiff 401 Last Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX Vh:RIFICATION I verih, that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of I3 Pa.C.S. $ 4904, relating to unworn falsifications to authorities Q. PAUL L. I IOP' tAN PAUL L. I IOFFMAN, IN TI IH COURT OP COMMON PLI'AS OF Plaintiff CUMBERLAND COUNTY, PHNNSYLVANIA v. CIVIL DIVISION - LAW DIANI- M.IIOFFMAN, NO. 99-67-1_ CIVILI'I RM Defendant : IN DIVORCE AhFIDANTI, OF SFRVIC'I? AND NOW, this 29°i day of November 1999, conics Thomas S. Diehl, I-squire, Attorney for the Plaintiff', Paul L. Ilol'lman, and slates that he personally mailed a certified copy of a Complaint in Divorce to the Defendant, Diane M. liofiinan, at 710 Dogwood Terrace, Boiling Springs, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on November 18, 1999. Respectfully submitted, Thomas S. Diehl -- Attorney for the Plaintiff 401 East Louther Street, Suite 10: Carlisle, PA 17013 (717) 240-0833 (717) 240-0893 - FAX 1 Z _1:-119 U67 4611 in m m 0 O O W n tl o. US Postal Service Receipt for Certified Mail No Insurance Coverage PICYIded. Do not use for International Mail (See reverse) Sent In DIANE M. HOHMAN SITiV efWOOD TERRACE Past Office. State. b 21P Cale BOILING SPRINGS PA 17007 Postage $ .55 Certified Fee 1.40 Special Delivery Fee Restricted Delivery Fee 2.75 Return Receipt Showing to 1.25 Whom a Dale Del vmed Rehm Pece'pt Shoring to valam, Dale. A M'ucssces AENess TOTALP ,IgcB FCes s 5.95 Post I. o a n rn f m SENDER: I also wish to receive the v • Complem Arms l andbr 2 W adWllanal sorvices. follo.ving services (for an u • Complclo,nmrs 3.4a. and 4b. •Print Yom..; eandaddress on fhereverse of tblo form so Ih at v,o can return this Calm ICOY Ci .H. 0 card to yall • Attach 111isfora to the Imnt of dierra.1pmce. or on fire back it 5paco does not 1.0 Addressee's AdtlrCSS V Z 0 ,a,lne. • l'hlln 'Return Receipt RegresleJ' nn the nhmfn«e hero- the nd¢le nundlar. 2. ?aostrictotl a (very N L • The nefunl necopt wdl show to whom flm article was dolimre tl and the lobe CO151111 ROShttaslCf Ior fee. n deb,ow:l. u 0 3. Anc?le Addressed to: 4a. Article N umber u 13 DIANE M. HOFFMAN 7 339 067 261 a: E E 710 DOGWOOD TERRAcr, 41). Service Type }M Certified ? Re istered ¢ 0 ? BOILING SPRINGS, PA 17007 g ? Eapressr\1?' ? Insured c .N ?RCImnR :.? rtd?kych 7. Dal, of ery arid too y 7 ff Add/e55CC Or Ager _ A 12 PS Form 3811, December 1994 102595 911 If Q: i a COD ? ue o v1 0 V eque5(ed Y c L H Return ? : , ? r L ? .. ? l' ?? =3 .. i=', "i n. ?'? U i:; PAUL L. HOFFMAN. : IN'H II? COIJR'I' OI: CUMNION I'Ll'AS OP Plaintiff : C'UNIBI-ALAND C'OUN'I•Y. PHNNSYL.VANIA CIVIL DIVISION - LAW DIANE ivt. HOFFMAN. :NO. 99 - 6743 CIVIIAT'RINI Defendant : IN DIVORCI? AFFIDAVIT OF CONSIiN'1' 1. A complaint in divorce under §3301(c) ol' the Divorce Coda was filed on November S. 1999. 2 The marriage ol• the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of Kling and service of the Complaint. 3. I consent to the entry ol? a Final Decree 01' Divorce alter service ol? notice ol? intention to request entry of the Decrec. I verify that the statements made in this al'lidavit are true and correct. I understand that false statements herein are made subject to the penalties of I S Pa.C.s. § 4909 relating to unsworn falsification to authorities. i Date: o 3. ?2 c>c-3 I_ I cu.? L.?A1014W ?---1 A PALL L. 'lill nllll WAIVER OF NOTICE OF INTENTION'1'0 REQUEST' ENTRY OF A DIVORCE DECREE UNDER §3301(c) OFTIIE DIVORCE CODE I consent to the cnty ol'a Final Decree in Divorce without notice. 3. 1 understand that 1 may lose rights concerning alimony. division of properly lawyer's Ices or expenses if I do not claim them before a divorce is granted. I I understand that I will not be divorced until a Divorce Decree is entered by the Court and a copy of the Decrce will be sent to nu immediately tiller it is filed with the Prothonotary. I verify that the statements made in this al'lidavit are true and correct. I understand that false statements herein are made subject to the penalties of 1 S Pa.C.S. § 4909 relating to unswom falsification to authorities. i Date: 03. 13. PAUI. 1_. li F'i IAN. Plaintiff---- QI C _ - _/ ? ? ? ?? 1 •. \. .? ?_? _ !?? _? .Ij.iJ -J -. CJ U PAUL L. HOFFMAN. Plaintifl' F. DIANIE M. HOFF MAN. Defendant IN'I'I Ili COl1R'I' OF COi%-Ii%dON PLHAS OF C'1,11%,11WRLAND C'OUN'Il'. I'I:NNSYI.V:\NIA CIVIL DIVISION - LAW NO. 99-6743 CIVIL'fl"RM IN DIVORCE NO'I'ICI? If you wish to deny any of the statements set forth in this affidavit, you must file a counter- aftWavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(4) OF THE DIVORCE CODE 'I"he panics of this action separated on November 8, 1999. and have continued to live separate and apart for a period of at least two years. 2. "fhe marriage is irretrievably broken. 3. I understated that I may lose rights concerning alimony. division of property. lawyer's Ices or expenses it 'l 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 suawn?atts borvin ;m: made subjcct in the nonalties of 18 Pa.C.S. § 4901 relating to unsm,orn falsification to authorities. Dater z- 2UO Z? 1 ?T- PAUL .I IOFFMAN. P a mtif ?.? PAUL L. HOFFMAN, ) Plaintiff ) VS. ) DIANE M. HOFFMAN, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1 . Check either (a) or (b): _ (a) I do not oppose the entry of a Divorce Decree. _ (b) I oppose the entry of a Divorce Decree because (check (0, (ii) or both): _ (i) The parties to this action have not lived separate and apart for a period of at least 2 years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _ (a) I do not wish to make any claims for economic relief. 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. X (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this Counter-Affidavit 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. ?l Dater II DIANE M. HOFFMA . , CD LL ! _ l'J IL - r? ?.ai. CI o 0 PAUL L. HOFFMAN, : IN TI IE COURT OP COMMON PLFAS OF Plaintil, : CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION - LAW DIANE M.HOFFcMAN, NO. 99-6743 CIVILTE-RM Defendant : IN DIVORCE PRAECH'E T01V1'1'11DRANV AND I'N'TER AI'I'EARANCE' TO THE PROTHONOTARY: Plcasc withdraw the appearance of Thomas S. Dichl, Esquire, on behalf of Paul L. Hoffman, the Plaintiff in the abovc-captioned case. Date: (?- 3-,), C)3 TO THE PROTHONOTARY: Thomas . Dichl, Esquire One Nest I ligh StreeL, Suite 208 Carlisle, Pennsylvania 17013 (717) 240-0833 Please enter the appcnrmicc of Jacquclinc M. Verney, ESquirc, on behalf of Paul L. Hoffman, the Plaintiff in the above-captioned case. Date: 6 -/.f 'O 3 ? v4L? cquc ne M. Vcmey, Esquire 44 South I-lanovcr Su'cct Carlisle, Pennsylvania 17013 (717) 241-9190 lra3, 4- 7 £OOZ 6 T Nnr - ?` J U J PAUL L. HOFFMAN, Plaintiff vs. DIANE M. HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM IN DIVORCE DEFENDANT'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and makes the following Petition for Economic Relief: COUNT I - EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT II - ALIMONY 2. Defendant lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 3. Defendant is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Plaintiff is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Defendant and to pay her alimony in accordance with the Divorce Code of Pennsylvania. 3`. is 'i WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant in the station of life to which she has become accustomed during the marriage. COUNT III -ALIMONY PENDENTE LITE 5. Defendant is without sufficient income to support and maintain herself during the pendency of this action. 6. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable reasonable alimony pendente lite during the pendency of this action. COUNT IV - COUNSEL FEES AND EXPENSES 7. Defendant is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 9. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expenses of this litigation. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in the litigation of this action. n aamuel L. AndeBtiJ Attorney for Defendant Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 Court to order Plaintiff to pay her I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 711.?/f)?w??- DIANE M. HOFFMA i I ''s .? ?" ?'' ?- Ly -t? ti-- " L:j _. 1 L?_ - u ._ AS OF )) - a9- tao? CASE#, lqqq. (,743 HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. PAUL L. HOFFMAN, ) Plaintiff ) VS. ) ) DIANE M. HOFFMAN, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 8 November of 1999 and was served upon the Defendant 18 November 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 in divorce without notice. 2. I understand that T 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. Section 4904 relating to unworn falsification to authorities. C?. .p4 Dated: PAUL L. HOFFMAN _0 r^ M rr, C :D M3 L PAUL L. HOFFMAN, Plaintiff vs. DIANE M. HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 8 November of 1999 and was served upon the Defendant 18 November 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 in 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. 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. Section 4904 relating to unsworn falsification to authorities. 04 L,,2 606 F Dated: DIANE M. HO c-5 PAUL L. HOFFMAN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM DIANE M. HOFFMAN, Defendant TO THE PROTHONOTARY: IN DIVORCE PRAECIPE Please withdraw all claims for economic relief filed on behalf of the Defendant, including claims for alimony, alimony pendente lite, counsel fees and expenses, and equitable distribution. DATE: 6 t Sa u 1 L. An e Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 r._a •? ?-? ? s k..? rr ?4 r}....? ?} ?'?. r. _ ?i?? ?. Y t"mot _ {?i -?- ? . > " - i .? ; r G. a, PAUL L. HOFFMAN, Plaintiff VS. DIANE M. HOFFMAN, ) Defendant ) PRAECIPE TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM IN DIVORCE Please withdraw any and all claims for economic distribution, alimony, alimony pendente lite, costs and fees, or any other economic claims which have previously been filed in this matter on my behalf. L.LQ.66 a -?- DATE. PAUL L. HOFFMAN 4 C.3 ? L? f -_ c? --? ?., ..? -J C`,y i"T r, `, ? ! _?? _r ("_ r ?. .. ?? ___; f.? ?. (?. "'" PAUL L. HOFFMAN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6743 CIVIL TERM DIANE M. HOFFMAN, Defendant 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. Ground for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Personal service on 18 November 1999 b certified mail Affidavit of Service filed on 29 November 1999). 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: 6 November 2006 by Defendant: 4 December 2006 (b) Code: Respondent: 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: Dated 6 November 2006, filed 29 November 2006. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 4 December 2006, filed contemporaneously herewith. Date: 125 cbP-e2-4Z7a B I ??? Sa el L. An Ns Attorney for Defendant (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce (2) Date of filing and service of the Plaintiff's Affidavit upon the f , ?y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ark STATE OF PENNA. PAUL L. HOFFMAN, Plaintiff VERSUS DIANE M. HOFFMAN, Defendant 99-6743 CIVIL TERM No. _ DECREE IN DIVORCE 2006 AND NOW, IT IS ORDERED AND PAUL L. HOFFMAN DECREED THAT AND DIANE M. HOFFMAN ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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 -??-COr