HomeMy WebLinkAbout08-2144
LAW OFFICES OF DILS & DILS
DIANE M. DILS, ESQUIRE
Attorney I.D. No. 71873
1400 North Second Street, First Floor, Front
Harrisburg, PA 17102
Telephone No. (717) 233-8743
Attorney for Teresa V. Hoffman
TERESA V. HOFFMAN : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
vs, NO. D8- al4q Ciy l Term
ROBERT D. HOFFMAN CIVIL ACTION -LAW
Defendant IN Divo"E
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
LAW OFFICES OF DILS & DILS
DIANE M. DILS, ESQUIRE
Attorney I.D. No. 71873
1400 North Second Street, First Floor, Front
Harrisburg, PA 17102
Telephone No. (717) 233-8743
Attorney for Teresa V. Hoffman
TERESA V. HOFFMAN
Plaintiff,
vs.
ROBERT A. HOFFMAN
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. NO. Of - aI YV
CIVIL ACTION -LAW
IN
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. The Plaintiff is Teresa V. Hoffman, an adult individual whose current
address is 842 Hummel Avenue, Lemoyne, Cumberland County,
Pennsylvania 17043, and whose social security number is 174-54-0828.
2. The Defendant, Robert A. Hoffman an adult individual whose current
address is 842 Hummel Avenue, Lemoyne, Cumberland County,
Pennsylvania 17043, and whose social security number is 203-54-6660.
3. Plaintiff and Defendant were married on February 14, 2003, in New
Cumberland, 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 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.
2
WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant
a Decree in Divorce.
Respectfully submitted,
B
iane M. ils, Esquire
1400 North Second Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
I,08
Date:
3
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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 unsworn
farsification to authorities.
TERESA V. HOFFMAN
Date: March 27, 2008
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT is made this TK day of - 2008, b
Y Y
and between:
TERESA V. HOFFMAN, hereinafter referred to as Wife;
--AND--
ROBERT D. HOFFMAN, hereinafter referred to as Husband;
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on February 14, 2003
in New Cumberland, Pennsylvania; and
WHEREAS, there are no minor children born of the marriage.
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WHEREAS, diverse unhappy marital difficulties have arisen between the
parties causing them to believe that their marriage is irretrievably broken, as a
result of which they have separated and now live separate and apart from one
another, the parties being estranged due to such marital difficulties with no
reasonable expectation of reconciliation; and the parties hereto are desirous of
settling fully and finally their respective financial and property rights and
obligations as between each other, including without limitation by specification:
the settling of all matters between them relating to the ownership of real and
personal property; and in general, the settling of any and all claims and possible
claims by one against the other or against their respective estate, particularly those
responsibilities and rights growing out of the marriage relationship.
NOW THEREFORE, in consideration of the mutual promises, covenants
and undertakings hereinafter set forth and for other good and valuable
consideration, the receipt of which is hereby acknowledged by each of the parties
hereto, Husband and Wife, each intending to be legally bound, hereby covenant
and agree as follows:
1. SEPARATION
It shall be lawful for each party, at all times hereafter, to live separate and
apart from the other, at such place or places as he or she may, from time to time,
choose or deem fit. Each party shall be free from interference, authority or contact
by the other, as fully as if he or she were single and unmarried, except as may be
necessary to carry out the provisions of this Agreement. Neither party shall molest
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the other or attempt to endeavor to molest the other, nor compel the other to
cohabit with the other, or in any way harass or malign the other, nor in any way
interfere with the peaceful existence, separate and apart from the other.
Should a Decree, Judgment, or Order of separation or divorce be obtained by
either of the parties in this or any other state, country or jurisdiction, each of the
parties hereby consents and agrees that this Agreement and all of its covenants
shall not be affected in any way by any such separation or divorce; and that
nothing in any such Decree, Judgment, Order or further modification or revision
thereof shall alter, amend or vary any term of this Agreement, whether or not either
or both of the parties shall remarry, it being understood by and between the parties
hereto, that this Agreement shall survive and shall not be merged into any Decree,
Judgment, or Order of divorce or separation. It is specifically agreed however,
that a copy of this Agreement or the substance of the provisions thereof, may be
incorporated by reference into any Order of divorce, Judgment, or Decree. This
incorporation, however, shall not be regarded as a merger, it being the specific
intent of the parties to permit this Agreement to survive any Judgment and be
forever binding and conclusive upon the parties.
2. EFFECTIVE DATE
The effective date of this Agreement shall be the "date of execution" or
"execution date", defined as the date upon which it is executed by the parties if
they have each executed the Agreement on the same date. Otherwise, the "date of
execution" or "execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement.
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3. MUTUAL RELEASES
Husband and Wife do hereby mutually remise, release, quit-claim or forever
discharge the other and estate of such other, for all time to come, and for all
purposes whatsoever, from any and all rights, title and interest, or claims in or
against the estate of such other, or whatever nature and wherever situate, which he
or she now has or at any time hereafter may have against such other, the estate of
such other or any part thereof, whether arising out of any former acts, contracts,
engagements, or liabilities of such other or by way of dower or curtesy, of claims
in the nature of dower or curtesy, or widow's or widower's rights, family
exemption or similar allowance or under the intestate laws; or the right to take
against the spouse's will; or the right to treat a lifetime conveyance by the other as
testamentary or all other rights or a surviving spouse to participate in a deceased
spouse's estate, whether arising under the United States, or any other country; or
any rights which either party may now have or at any time hereafter have for the
past, present, or future support or maintenance, alimony, alimony pendente lite,
counsel fees, costs or expenses, whether arising as a result of the marital relation or
otherwise, except all rights and agreements and obligations of whatsoever nature
arising or which may arise under this Agreement or for the breach of any provision
thereof.
It is the intention of Husband and Wife to give to each other, by the
execution of this Agreement, a full, complete and general release with respect to
any and all property of any kind or nature, real, personal, or mixed, which the other
now owns or may hereafter acquire, except, and only except, all rights and
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agreements and obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
4. DISTRIBUTION DATE
The transfer of property, funds and/or documents provided for herein shall
only take place on the "distribution date" which shall be defined as the date of
execution of the Divorce Decree, unless otherwise specified herein.
5. MUTUAL CONSENT/ADVICE OF COUNSEL
Husband and Wife acknowledge and understand the terms and conditions of
this Agreement, and Wife is represented by Diane M. Dils, Esquire and Husband is
unrepresented. Each party acknowledges that he or she has received or has been
given an opportunity to receive independent advice from counsel of his or her
selection and was fully informed as to his or her legal rights and obligations.
Husband and Wife acknowledge that they fully understand the facts as to
their legal rights and obligations under this Agreement. Husband and Wife
acknowledge and accept that this Agreement is, under the circumstances, fair and
equitable and that it is being entered into freely and voluntarily, and that the
execution of this Agreement is not the result of any collusion or improper or illegal
agreement or agreements.
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6. FINANCIAL DISCLOSURE
The parties confirm that each has relied on the substantial accuracy of the
financial disclosure of the other as an inducement to the execution of this
Agreement.
Notwithstanding the foregoing, the rights of either party to pursue a claim
for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any
interest owed by the other party in an asset of any nature at any time prior to the
date of execution of this Agreement that was not disclosed to the other party or his
or her counsel prior to the date of the within Agreement is expressly reserved. In
the event that either party, at any time hereafter, discovers such an undisclosed
asset, the parties shall have the right to petition the Court of Common Pleas of
Dauphin County to make equitable distribution of said asset.
The non-disclosing party shall be responsible for payment of counsel fees,
costs, or expenses incurred by the other party in seeking equitable distribution of
said asset.
7. MARITAL DEBT
Husband and Wife hereby acknowledge that there is currently a loan
outstanding at PSECU in joint names. Husband hereby agrees to be solely
responsible and hereby indemnifies Wife in connection with said loan payments.
Husband hereby agrees that he shall refinance, or do whatever is necessary, to
remove Teresa's name from said PSECU loan. Husband hereby acknowledges that
the same shall occur within sixty (60) days of the date of this Property Settlement
Agreement.
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8. REAL ESTATE
Husband and Wife acknowledge that Wife purchased the real estate located
842 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043, prior
to the parties marriage. Husband hereby agrees to waive all of his right, title and
interest in said real estate upon Wife refinancing all debt in connection with the
real estate into her name alone and upon payment to Husband in the amount of Ten
Thousand ($10,000.00) and 00/100 Dollars.
At the time of the execution of the Property Settlement Agreement, the
parties acknowledge that Wife is in the process of refinancing and it is anticipated
that said refinancing and payment to Husband shall occur within sixty (60) days of
the date hereof.
Husband hereby agrees to vacate the real estate located at 842 Hummel
Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 upon execution of
this Property Settlement Agreement. Husband further agrees to execute any and all
documents necessary for the refinancing to occur removing his name from all debt
in connection with the real estate.
9. PERSONAL PROPERTY
Except as set forth hereto, Husband and Wife have agreed that their personal
property has been divided to the parties' mutual satisfaction and neither party will
make any claims to the property possessed by the other, except:
NONE
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10. WAIVER OF RIGHTS
The parties hereto fully understand their rights under and pursuant to the
Divorce Code, Act of 1980, No. 1980-26, as amended February 12, 1998,
particularly the provisions for alimony pendente lite, spousal support, equitable
distribution of marital property, attorneys fees, and expenses. Both parties agree
that this Agreement shall conclusively provide for the distribution of property
under the said law and the parties hereby waive, release and forever relinquish any
further rights they may respectively have against the other for alimony, alimony
pendente lite, spousal support, equitable distribution of marital property, attorneys
fees, and expenses.
11. WAIVER OR MODIFICATION TO BE IN WRITING
A modification or waiver of any of the terms of this Agreement shall be
effective only if in writing, signed by both parties, and executed with the same
formality as this Agreement. No waiver of any breach hereof or default hereunder
shall be deemed a waiver of any subsequent default of the same or similar nature.
12.MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and
all steps and execute, acknowledge and deliver to the other party, any and all future
instruments and/or documents that the other party may reasonably require for that
purpose of giving full force and effect to the provisions of the Agreement.
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13.AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall inure to the benefit of the parties
hereto and their respective legatees, devises, heirs, executors, administrators,
successors, and assigns in the interest of the parties.
14. PENSION
Husband and Wife hereby acknowledge that they waive all of their right,
title and interest in any and all 401(k), IRA's, Pension or Retirement Accounts
which may have accumulated between the date of marriage and the date of the
execution of this Property Settlement Agreement.
15.BREACH
If either party breaches any provision of this Agreement, the other party
shall have the rights, at his or her election, to sue in law or in equity to enforce any
rights and remedies which the party may have, and the party breaching this
Agreement shall be responsible for payment of attorneys fees and all costs incurred
by the other in enforcing his or her rights under this Agreement.
16. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania.
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17. HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs/provisions and
sub-paragraphs hereof, are inserted solely for convenience of reference and shall
not constitute a part of this Agreement nor shall they affect its meaning,
construction or effect.
18.DIVORCE
The parties hereto acknowledge that their marriage is irretrievably broken.
The parties further agree to execute the necessary Affidavits of Consent and
Waiver of Counseling, and Waiver of Notice of Intent to Request Entry of Divorce
Decree upon request so that the divorce may become finalized. The parties further
agree and acknowledge that this Property Settlement Agreement shall be
incorporated into said Decree in Divorce; however, shall not merge therewith.
19. IRREVOCABILITY
It is understood and agreed to by and between the respective parties thereto
that the property division - distribution affected by the herein agreement is
IRREVOCABLE and that such division - distribution shall not be affected by any
change of circumstances of the respective parties OR by other statutory or judicial
alternatives which may be available to the respective parties under prior, current,
or future laws of the Commonwealth of Pennsylvania or any other jurisdiction.
Except as provided herein, the parties hereby waive any respective rights to
financial support and/or alimony and/or pension or future expectancies each may
respectively have under prior, current, or future laws or case decisions.
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IN WITNESS WHEREOF, the parties hereto have set their hands and seals
the day and year first above written.
NOTARIAL SEAL
FCARR!'.E JEAN SINGER, NOTARY PUBLIC
PAXTON TkAiR, DAUPHIN COUNTY
fY COIfAISSION EXPIRES SEPT. 7, 2010
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TE SA V. HOFFM'?X
(SEAL)
ROBERT D. HOFFMAN
II
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On this, the ?(8)41 day of 1 , 2008, before me, a Notary Public, the
undersigned officer, personally appeared TERESA V. HOFFMAN, known to me
or satisfactorily proven to be the person whose name is subscribed to the within
instrument, and acknowledged that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
My Commission Expires: -)'b? t,
NOTARIAL SEAL
COMMONWEALTH OF PENNSYLVANIA CARRIE JEAN SINGER, NOTARY PUBLIC
FIAXTC)^I IVIP., DAUPHIN COUNTY
COUNTY OF DAUPHIN MY Uo??I??1=a:::?I PXPi;DES SEPT. 7, 2010
On this, the \ day of -'s -,? 2008, before me, a Notary Public, the
undersigned officer, personally appeared ROBERT D. HOFFMAN, known to me
or satisfactorily proven to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have
to set my hand and official seal.
My commission expires:
j? NOTARIAL SEAL 2
Initials l CARRIE JEAN SINf,ER, NOTARY PUBLG
LOIAIER PAXTON TWP., DAUPHIN COUNTY
OY QMMIrSIC?d EXPIRES SEPT. 7, 2010
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TERESA V. HOFFMAN
Plaintiff
VS.
ROBERT D. HOFFMAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-2144
CIVIL ACTION - LAW
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 served
upon the Defendant, Robert D. Hoffman at his address of 842 Hummel Avenue,
Lemoyne, Pennsylvania 17043, by First Class United States Certified Mail No.
7007 2560 0000 0344 5641 by depositing the same at the post office at Harrisburg,
Pennsylvania, addressed to the Defendant, Robert D. Hoffman at 842 Hummel
Avenue, Lemoyne, PA 17043.
Attached hereto is the return receipt card executed by the Defendant, Robert
D. Hoffman, dated April 14, 2008, evidencing receipt of said Complaint in Divorce
under Section 3301(c) of the Divorce Code.
Respectf 4 submitted,
Diane M. Dils, Esquire
1400 North Second Street
First Floor, Front
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Attachment
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D. Is delivery address ditn3nt from item t? r 0' Yes
If YES, enter delivery address below; 0 No
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Item 4 if ResMcted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
• Attach this card to the back of the mailpiec*
or on the front if space permits.
1. Article Addressed to:
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TERESA V. HOFFMAN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 08-2144 CIVIL TERM
ROBERT D. HOFFMAN, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 3, 2008.
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
statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification
to authorities.
Date:
ROBERT D. HOFFMAN, Defendant
Q
cxy
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TERESA V. HOFFMAN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 08-2144 CIVIL TERM
ROBERT D. HOFFMAN, CIVIL ACTION - LAW
Defendant IN.DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 3, 2008.
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
statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification
to authorities.
Date:
TERESA V. HOFFMAN, intiff
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TERESA V. HOFFMAN
Plaintiff
VS.
ROBERT D. HOFFMAN
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-2144
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 April 14, 2008.
3. [Complete either Paragraph (a) or (b).]
(a) Date of execution of Affidavit of Consent required by Section 3301(c)
of the Divorce Code by Plaintiff, signed July 18, 2008, by Defendant,
July 18, 2008.
(b) Date of execution of Plaintiff's affidavit required by Section 3301 (d)
of the Divorce Code: NIA; 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: NIA;
5. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff:
Simultaneously herewith and by Defendant: Simultaneously herewith.
6. Related Claims Pending: None
Diane M. Dils, Vsquire
1400 North Second Street
First Floor, Front
Harrisburg, PA 17102
(717) 232-9724
Attorney for (x) Plaintiff
( ) Defendant
Date: August 5, 2008
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IN THE COURT OF COMMON PLEAS
TERESA V. HOFFMAN
OF CUMBERLAND COUNTY
STATE OF PENNA.
Plaintiff
VERSUS
ROBERT D. HOFFMAN
Defendant
N O. 08-2144 Civil Term
DECREE IN
DIVORCE
AND NOW, q 12 ZOO , IT IS ORDERED AND
DECREED THAT TERESA V. HOFFMAN , PLAINTIFF,
AND ROBERT D. HOFFMAN 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;
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BY THE COURT:
PROTHONOTARY
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TERESA V. HOFFMAN,
Plaintiff
VS.
ROBERT D. HOFFMAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-2144
CIVIL ACTION - LAW
DIVORCE
ORDER OF COURT
AND NOW, this , ?_ , day of August, 2008, upon presentation and
consideration of the within Property Settlement Agreement dated July 18, 2008, it
is hereby Ordered that said Property Settlement Agreement is attached hereto and
made a part of this Order of Court:
BY THE COURT:
J.
Distribution:
Diane M. Dils, Esquire, 1400 North Second St., Harrisburg, PA 17102
Robert D. Hoffman, P.O. Box 126142, Harrisburg, PA 17112 -
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