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Home My WebLink About07-5871ROBERT P. YOHO, Plaintiff, V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007- S971 JILL K. YOHO, Defendant. IN DIVORCE NOTICE CIVIL TERM 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 in 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, Cumberland County Courthouse, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 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. ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 5 S71 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND D) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Robert P. Yoho, by and through his attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Jill K. Yoho, representing as follows: 1. The Plaintiff is Robert P. Yoho, an adult individual residing at 478 Berkshire Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Jill K. Yoho, an adult individual currently residing at 15 Loop Drive, Hanover, York County, Pennsylvania 17331. 3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on March 3, 2007 in Owens Mills Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN & McKNIGHT By: arcut A. McKnight, II, Esquire S reme Court I.D. No. 5476 We mfret Profess' al Building 60 West Porn a treet Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Dated: October 3, 2007 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ROBERT P. YOHO Date: October 3, 2007 ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - -? 7 / CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ROBERT P. YOHO Date: October 3, 2007 ?J ;_- ??, ?._? //?? ? ?? (? ? ? ?' ?_ r..' r .._ ,` ?A .? t c a ? W r_?.3 °°7 ? c~ ? _?.? ?? •-c ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. CIVIL ACTION - LAW 2007 - 5871 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Jill K. Yoho, on October 9, 2007, by certified, restricted delivery mail, addressed to her at 15 Loop Drive, Hanover, Pennsylvania 17331, with Return Receipt Number 7004 1350 0003 7289 3358. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. n : IN THE COURT OF COMMON PLEAS OF I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. M CU GHT, III, ESQUIRE A rney for aitiff Date: October 12, 2007 : CUMBERLAND COUNTY, PENNSYLVANIA CD Ln m M Er CD n.i r- m C3 0 0 O Ll m rq O O r- Total Postage & Fees Moo O N UNIrZo 0 n IQ ® sr oM-U TA 7100 e`re ti v s_? ¦ Complete items 1, 2, an 3. Also complete . Item 4 If Restrict I 8,? ¦ Print your name bn6`- so that we can return the card to you. B. Reblvdr'?y (,(+• O C ¦ Attach this card to the hack of the mallpiece, YV? or on the front if space permits. i) from roam 1? O Yes 1. Article Addressed to: YE eater below: 0 No J NS JILL B YOHO r9 `l 15 LOOP DRIVE ??Q HANOVER PA 17331 V 00,? 13. Service lype-- lb Cerflfled Mall 0 Express Mail 0 Realsto ise Mail Cl C.O.D. SRed&-Wd Deliveryl (Extra Fee) Yes 2• Article Number MWMfSr fora servoa kw 7004 1350 0003 7289,!5-1:)6 PS Form 3811, February 2004 Dornwelc Return Recdpt 102595-024A-1540 : SJ ril ?F3 ?+ , fti7 ??} t r., p` W ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 5871 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 4, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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 verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: c.. uP 3 . ? XC7-e. As- ROBERT P. YO 140 Plaintiff C? ?'? ? :?,. ? ` c?. c?? ? _ r r ? ? ?}? ?? ?Z ?? ? ? *"1 i ? ,, i ? , . '? ,` ? ?'' '?'? ?fN ROBERT P. YOHO, Plaintiff, V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 5871 CIVIL TERM JILL K. YOHO, Defendant. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. I Date: ?I t) 4 -0- dA- ROBERT P. YO Plaintiff 0 1 ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 5871 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 4, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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 verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: f JILL K. HO Defendant ` C? ? rt c?. ? .? "?7 r {;._ f? {F.? ;-?:. M' (,;:? ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 5871 CIVIL TERM 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: JILL K. Y O Defendant N ? cT'. t:: ,,?; , ?---; ? T? ;: i:?{?? ..a..- -?a r' . ?. -?? ?r ?.;-; -:. _? , {_ c?a =_ ?,, ROBERT P. YOHO, Plaintiff, V. JILL K. YOHO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 5871 CIVIL TERM IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ko 13' JILL K. YO Defendant I-`? ?':.7 S?_? C . C...- ?? ? ?;j T? - ? ?? ?'t ? ??,, ..- `3 ? ? ?7 ,1 -1 ROBERT P. YOHO, IN THE COURT OF COMMON PLEAS OF Plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007-5871 CIVIL TERM JILL K. YOHO, , 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) and or (d) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Jill K. Yoho, on October 9, 2007, by certified, restricted delivery mail, addressed to her at 15 Loop Drive, Hanover, Pennsylvania, 17331, with Return Receipt Number 7004 1350 0003 7289 3358. 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: January 3, 2008; by defendant: January 8, 2008. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 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 plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: January 4, 2008. January 14, 2008 Date defendant's Waiver of Notice in Section 3301(c) D' rce"was fi with the Prothonotary: . Marcus . Me , uire Attorney Plaintiff Date: January 14, 2008 ,` t . G.3 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROBERT P. YOHO, Plaintiff VERSUS JILL K. YOHO, Defendant AND NOW, DECREED THAT AND JILL K. YOHO 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 BY THE COURT: PROTHONOTARY NO. 2007-5871 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DECREE IN DIVORCE -10.1 %sor -j 1y 1 2008 , IT IS ORDERED AND ROBERT P. YOHO ,?°??? ti ? " J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robert P. Yoho Plaintiff Vs Jill K. Yoho 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, hereby elects to resume the prior surname of J ; 1 1 u _ Pnt t s , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: 2 ?1c;/0 8 Signature of name bemg resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF !? On the 4?s /21day of 6 ?.-.,a T7 , 200S<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. or _x after the entry of a Final Decree in Divorce dated 1 ? 14? (),q , File No.?007-5871 IN DIVORCE Signature In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Martin P. Eisenhart, Notary Public Penn Twp., York County W Commission Expires July 25, 2009 Member, Pennsylvania Association of Notaries Notary Public r`0 C) C) r Z