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HomeMy WebLinkAbout07-2490LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Raymond A. Jock Jr. RAYMOND A. JOCK, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - o2g96 (21 U i L ""-FSz-s-n JILL S. JOCK, Defendant CIVIL ACTION - LAW IN 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 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 of Cumberland County, One Courthouse Square, Carlisle, Pennsylvania 17013. 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 1-800-990-9108 RAYMOND A. JOCK, JR., Plaintiff vs. JILL S. JOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. I/ 9d (2 . CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Raymond A. Jock, Jr., an adult individual whose current address is 5312 Oxford Circle, Apartment 8, Mechanicsburg, Cumberland County 17055, and whose social security number is 172-60-1015. 2. The Defendant, Jill S. Jock, is an adult individual, whose current address is 3334 South York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, and whose social security number is 198-62-8963. 3. Plaintiff and Defendant were married on August 8, 1998, in York, Cumberland County, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children born of the marriage. 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, Y: iane M. Dils, Esquire 1400 North Second Street Harrisburg, PA 17102 (717) 232-9724 Date: ?f 71d /7 I.D. No. 71873 2 VERIFICATION I verify that the statements made in this Complaint in Divorce 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 unswom falsification to authorities. Date: April 25, 2007 W ED d c ? c V RAYMOND A. JOCK, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-2490 JILL S. JOCK, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. r% Complaint in Divorce under Section 3301(c) of the Divorce Code was tiled on April 30, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 made herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 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. 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 Waiver are true and correct. I understand that false herein are made subject to the penalties of 18 Pa. C.S. §4904 relatin nsworn falsificat' tc Date: q/& /? 7 ac,, ay nd A. Jock, Jr. , ainti ?a t.5 L:'? V F,' 6_? -..I "` -", ?? _ ? (? ? ? ?;,, . RAYMOND A. JOCK, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA VS. No. 07-2490 JILL, S. JOCK, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under Section '1301((;',,.)f th:? Divorce Code was F?Jed -gin April 70,1-907. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. V I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. WAIVER OF NOTICE OF LNTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(() 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 rigi-#s c bt e'rring alimony, division of property, iawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I Will nbf 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unswom falsification to authorities', Date:. 0 Cl 2-2 _. ?. Jill S. Jock, Defendant .... rn RAYMOND A. JOCK, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLV vs. NO. 2007-2490 JILL S. JOCK, CIVIL ACTION - LAW Defendant DIVORCE CERTIFICATE OF SERVICE I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the Complaint In Divorce, under Section 3301(c) of the Divorce Code, has been ser?ed upon the Defendant, Jill S. Jock, at her address of 1334 S. York, Str et, Mechanicsburg, PA 17055, by First Class United States Certified Mail No. 7 06 2150 0000 8774 7875 by depositing the same at the post office at Harrisbu g, Pennsylvania, addressed to the Defendant, Jill S. Jock, at 1334 S. York Str et, Mechanicsburg, PA 17055. Attached hereto is the return receipt card executed by the Defendant, ill Jack, dated May 21, 2007, evidencing receipt of said Complaint in Divorce un er Section 3301(c) of the Divorce Code. Respectfull submitted, B iane M. Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Attachment Alt. • O nrpbfs Rams 1, 2, and 3. Also w p Me lWn 4 If PA@k krtsd Ds YWY is dseked. • ftd your name and address on the reverse se that we can mtum the card to you. ¦ Aftch this cmd to the back of the mdoleoe, or on the front If apace permRs. 1. Ar" Addressed to: A. SV*tL ns X s 0 AWM IQAddMM B by (P?fr?rsd C. .f 'i I' yi ro*-7 D. Is d*my Z *&W- dMM-. from hem 1? 0 Yes If YES, errter delkwy address below 10 ,5; ? 13ocK ? 33 y S . ?eR?? St. mew !? l` '?.J b uR? , pfl ??ef,? o r? f] Re*WW Q'f rmn Mmelpt for Mwdlerxft 1-7 O kmnw Mal C3 c.o.D. 4. Raddcted D~ pft roo Qpflr 2. ArftbN mbw 7006 2150 0000 8774 7875 Aallt I fto swAw m f w w• ps Fore 3811. Feb. ---y 2w4 Dsnnars nwn Reoso lown4a-wim ??vna?,d jo?K t') rv Q ca p- T ' i '` C,?? G1 ?Y7'i .,-, . RAYMOND A. JOCK, JR., Plaintiff vs. JILL S. JOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-2490 CIVIL ACTION - LAW 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: Irretrievably broken under Section (X) 3301(c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Service upon Defendant: Certified Mail on May 21, 2007. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 33QI(c) of the Divorce Code by Plaintiff, signed September 6, 2007, filed, October 4, 2007; by Defendant, January 26, 2008. (b) Date of execution of Plaintiff's affidavit required by Section 33011 (d) of the Divorce Code: N/A; Date of service of Plaintiff's affidavit upon Defendant: N/A. . ,. 4. Date of service of Notice of Intent to Finalize under Section 3301(d) Of the Divorce Code: N/A; 5. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff. October 4, 2007 and by Defendant: Simultaneously herewith. 6. Related Claims Pending: None B iane A Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 Attorney for (x) Plaintiff ( ) Defendant Date: January 31, 2008 C`3 C- ? 7!4 -cs F 771 > IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. RAYMOND A. JOCK, JR. Plaintiff VERSUS JILL S. JOCK No. 07-2490 Defendant DECREE IN DIVORCE AND NOW, -bc%,) 06'r %4 10 IT IS ORDERED AND DECREED THAT RAYMOND A. JOCK, JR. , PLAINTIFF, AND JILL S. JOCK 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; BY THE COURT: PROTHONOTARY ??. Iif -'r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. 0-1 -Q-H90 IN DIVORCE r S. FOLK Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of Ho Ce (n o 1 , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: 7naAt?, a y 9NY Signature ignature of name being r ed COMMONWE TH OF PENNSYLVANIA. ) COUNTY OF Glm fA' c.. /C a6 ft?7V7 On the Nt day of , 200, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. /-,/? A ProthonotafYotaryy`ublic O Y 1 ?r 1 O ? I 'V V ? i '^ w ^V A ' y u`