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HomeMy WebLinkAbout04-0219KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DEBRA HOCKENBERRY, Plaintiff HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 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 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 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 Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 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 (800) 990-9108 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DEBRA HOCKENBERRY, Plaintiff Ve HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0¥.~/~ ~ CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I Request for a No-fault Divorce Under ~3301(c) of the Domestic Relations Code 1. Plaintiff is DEBRA HOCKENBERRY, who currently resides at 634 Mahanoy Valley Road, Duncannon, Perry County, PA 17020. 2. Defendant is HAROLD HOCKENBERRY, who currently resides at Apt. 84 Autumn Lane, Enola, Cumberland County, PA 17025. 3. Plaintiff/Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 11, 1973 in Perry County, 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. Defendant is not a member of the armed services. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(c) of the Domestic Relations Code. DATE: 1/15/04 KENNETH F. LEWIS, ESQUIRE Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document 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. Dated: 1/15/04 D~B~A HOCKENBERRY ~ - DEBRA HOCKENBERRY, Plaintiff HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O~'g/? ~"V// I~r~ CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. DATE: ~OLD HOCKEN~E~Y KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DEBRA HOCKENBERRY, Plaintiff HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-21'9 Civil Term CIVIL ACTION - L~W IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on January 16, 200.4. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. I consent to the entry of a Final Decree in Divorce of notice to intention to request entry of the after service decree. 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. Dated: ~/~/0~ ~A~ ~ ~~4~ KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DEBRA HOCKENBERRY, Plaintiff HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-219 Civil Term CIVIL ACTION - I2~W IN DIVORCE (c) AFFIDAVIT OF CONBEN'~ 1. A Complaint in Divorce was filed under Section 3301 of the Divorce Code on January 16, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. unsworn falsification to authorities. Section 4904, relating to HO~KE-N~RRY / KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DEBRA HOCKENBERRY, Plaintiff ,HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-219 civil Term CIVIL ACTION - LAW 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 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: 9JZq/~ ~RA HOCKE~BkRRY ~ KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DEBRA HOCKENBERRY, Plaintiff HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2].9 Civil Term CIVIL ACTION - LAW 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 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 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. 4. I verify that the statements made in the foregoing document 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. HAROLD HOCKENBERRY / DEBRA HOCKENBERRY, Plaintiff HAROLD HOCKENBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-219 civil Term 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: irretrievable breakdown under Section (X) 3301~c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service signed January 17, 2004; filed February 3, 2004. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on 7/29/04; by the Defendant on 8/5/04; all filed contemporaneously with this Praecipe. 4. Related claims pending: NONE, no economic relief requested by either party. DATED: 8/10/04 KEN~ETH/F. LEWIS, ESQ. Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF VERSUS PENNA. DECREE IN DIVORCE DECREED THAT ~_~//L it Is ORDERED AND , PLAINTIFF, , 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 VVHICH A FINAL ORDER HAS NOT ROT ONOTA + + + + + + +++ ++ ++++ +++ + ++ ++++++ + + ++++