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Home My WebLink About08-4712MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 (717) 909-4060 Attorney for Plaintiff SHARON L. HOOVER, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. OS - 4111 a Civi l -Ferm DANIEL E. HOOVER, 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 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. 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 the 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue; Suite 102 Camp Hill. PA 17011 (717) 909-4060 Attorneys for Plaintiff SHARON L. HOOVER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 6 ?- V 7/- C' P DANIEL E. HOOVER, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Sharon L. Hoover, who has resided at 323 Manchester Road, Camp Hill, Cumberland County, Pennsylvania 17011, since May of 2003. 2. Defendant is Daniel E. Hoover, who has resided at 4458 Mercury Court, Harrisburg, Dauphin County, Pennsylvania 17110, since June 13, 2008. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 20, 2002, in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. Plaintiff avers that there are no children of the parties under the age of eighteen (18). COUNT I - DIVORCE 10. Plaintiff avers that the grounds on which the action is based are as follows: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court enter a decree in divorce. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: _8-q-06 By: MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, Sharon Hoover, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. DATE: 8'q-e 'Son ZHoov?eWr J i1 L 'S Y ..'.. .1 - "y 10 MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 9094060 Attorneys for Plaintiff SHARON L. HOOVER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-4712 CIVIL TERM DANIEL E. HOOVER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Margaret M. Simok, Esquire, do hereby certify that a true and correct copy of the Complaint for Divorce was served upon Daniel E. Hoover, Defendant, by certified mail, return receipt requested, delivery to addressee only, on the 22nd day of August, 2008. The original signed receipt, No. 7005 0390 0005 2244 1989, is attached hereto and made a part hereof. MARIA P. COGNETTI & ASSOCIATES ' Date: 3 -06 By: ble? MARG T M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff G UNITED STAT&M544fA-iSjWka iG ?F% 1.7 • Sender: Please Print your name, address, and ZIP+4 in this box • -#4 y COGNETTI & ASSOCIATES 210 GRANDVIEW AVENUE SUITE 102 CAMP HILL PA 17011 I777IIiI III771771IiIIIII777II177IIIII17III17711711777II11I71 ¦ 2 - 8M 3. Also =nPlefe ¦ Print your name and address on the revers ON so that we can return to card to you. shred b;( rre) ¦ Attach this card to the back of the malipiece, Q O Q ? or on the front if space peal ts. D. Is deNvery dIIII t 1? 1. Article Addressed to: M YES, errlsr fWjwy edoLW q?Y 1?14g' 0 No a Service log Mel ? Bpo a Mail ? ReplslMsd wnsttm Receipt for Merdwwlse ? IT!!r MON O C.O.D. 4. Restricted DeNvery9 (E*v Fee) stiree 2. Article Number _ -- ro-r P6 Fpm 811, February' 2004 Domestic Retum Receipt taeere ee * tilt j-? r ( . MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Supreme Court ID No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Sharon L. Hoover SHARON L. HOOVER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANI A 08-4712 CIVIL TERM :DOCKET NO ~' ~`' v. . ^a -- DANIEL E. HOOVER CTJ :CIVIL ACTION -LAW }-'~~ C~ r' C~ -T1 ''- Defendant IN DIVORCE ~ `~ ~ e~> °" -- "~ ° ~ ~ yam, ~?' ~-~~ 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served by United States Postal Service, certified, restricted delivery, return receipt requested on August 22, 2008. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: By Plaintiff, on October 18, 2010; By Defendant, on October 1, 2010.. 4. Related claims pending: None. 5. Plaintiffs Waiver of Notice in § 3301(c) Divorce is being filed concurrent with this Praecipe to Transmit. 6. Defendant's Waiver of Notice in § 3301(c) Divorce is being filed concurrent with this Praecipe to Transmit. MARIA P. COGNETTI & ASSOCIATES Date: October 20, 2010 By: MARG T M. SIMOK, ESQUIRE Supreme Court ID No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff SHARON L. HOOVER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :DOCKET NO. 08-4712 Civil Term DANIEL E. HOOVER :CIVIL ACTION -LAW `~ ~; ~ , Defendant :DIVORCE _.~:~ ~ ~~ e-, w ~ r~ ~,~. ~ ~ AFFIDAVIT OF CONSENT <=~ -+ i-- ~-- .~- ~ "~ ~r --n ~, --n 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on ~~ ~ ~ ~I ~ August 5 2008 ~ Q , . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of 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 herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: _~ ~ ~ / - ~ ~ SHARON L. HOOVER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v ~ 08-4712 Civil Term ~ :DOCKET NO ~~ ~ . . ~ ~-~ ca ~~ ~ ~ r n r.. DANIEL E. HOOVER :CIVIL ACTION -LAW =~ =~ `` -~ r" Defendant : IN DIVORCE ~' ~ ~~ ~'~ -, o r -._ ~ -~, -~ ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF ~ -v _~, c3 -n c=~ DIVORCE DECREE UNDER § 3301 c) OF THE DIVORCE CODE p~ _-`•' ~~' Y ~ ~~ 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 Decree of Divorce 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. § 4904 relating to unsworn falsification to authorities. Date: ! d `f ' ~ y SHARON L. HOOVER, Plaintiff v. DANIEL E. HOOVER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 08-4712 Civil Term CIVIL ACTION -LAW DIVORCE e-'7 c --~-- 4p a. .~1 ~.::-~ ~~~ ~__ _..- ~.y ~ a r~ c-,, :~= yam, ~ =~ -"~.. ~~ r-~ tv AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on August 5, 2008. r 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of 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 herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: ~G' ~~ ~~ SHARON L. HOOVER -:-~ _,~ ~~ r- ~' n ~~ ~ Q c~~ ~ ~7 :aj ~y SHARON L. HOOVER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA . :DOCKET NO. 08-4712 Civil Term °;Y~ a v r . s~ ~ a~ ~ :CIVIL ACTION -LAW '~ ~~ ~ ; DANIEL E. HOOVER -~ , Defendant : IN DIVORCE ~,~" rv ~,~? WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A t~ ~ ~'' ~' `" :~ ~~ ~. DIVORCE DECREE UNDER § 3301 (c) OF THE DIVORCE CODE Ate. ~ ,,,,~ c, ~~ ~;;. ,~- ~„~ 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 Decree of Divorce 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. § 4904 relating to unsworn falsification to authorities. Date: ~~' ,~ ~( ~_ SHARON L. HOOVER SHARON L. HOOVER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DANIEL E. HOOVER No. 08-4712 CIVIL TERM DIVORCE DECREE AND NOW, ~ c,~C o~e,r ~~ ~,41~ , it is ordered and decreed that SHARON L. HOOVER plaintiff, and DANIEL E. HOOVER ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The Property Settlement Agreement dated October 14, 2010, shall be incorporated and not merged into this Decree. By the Court, Attest: J. rothonotary '~ ~ ~~ it , j . ~v ~1~~ Apr, 13. 2012 1: 31 PM No. 5341 P. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ue? L 1-100 Plaintiff vs. heel 1?dOUe? Defendant FILE NO ^J " L17 Z 7 T A . . 2 , -v Fn -a IN DIVORCE :ts w ? c-, 3 ?- NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the ab1ovve/nottter_, having been granted a Final Decree in Divorce on the day of hereby elects to resume the prior surname of elr2 L and gives this written notice pursuant to the provisions o 4 P.S. 704. DATE: / C t J ilmantre ignature of name being resume COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the day of /4?/L 20 Z!?,-before me, a Notary Public, personally appeared the above affiant known to the 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 'W'hereof,1 have hereunto set my hand and official seal. Notary Public COMM0141WEALM OF PENNSYLVANIA NOD\RIAL SEAL - --- i WCH11"EL R. CARANCI, Nota;-y Public Lemoyne Boro. Cumreiknd County My Commission Expires June 15, 901 4 + I& CD PA PLF'F PAGE 111"RCVDAT 4113QD121:38:41PMRastemDaolghtTlme)"SWEAFAX1016"DNIS:8841ICSID:"DURATION mm?ss:00.34 C* !qq'7-5q&008a I y e* x1'1454