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HomeMy WebLinkAbout04-1221IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania17050 197-52-3718 CIVIL ACTION - LAW TERM CASE NO. (3 ~11 -I ,~,.-~. I IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court for divorce. If you wish to defend against the claims set forth on the other side of this page, 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 this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or 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 the CUMBERLAND County Courthouse, in Mechanicsburg, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 197-52-3718 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM COMPLAINT UNDER SECTION 330t(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michele Hoffman who resides at; 5 Sunset Circle; Mechanicsburg, Pennsylvania 17050. 2. Defendant is Jason Randolph Hoffman who resides at: 5 Sunset Cimle; Mechanicsburg, Pennsylvania 17050. 3. ~ Plaintiff and/or [] Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on February 25, 1999 at East Berlin, Adams County, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the previsions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments. 6. There has been no pdor action of divorce or for annulment between the parties. Complaint for Divorce; Page 7.The marriage is irretrievably broken. 8. After 90 days have elapsed from the date of filing of this Complaint, Plainl~ff intends to file an affidavit consenting to a divorce, Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the dght to request that the Court require the parties to participate in marriage counseling, 10. There are no children born to or adopted by the parties to this marriage and none are expected. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and Defendant. I vedfy that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unsworn falsific_ati..,o~:) authorities. Date: c~- i ele~rl~an, Pro Per IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsbu~g, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania17050 197-52-3718 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM COUNSELING NOTICE RULE 1920.45(a)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301 (al(6) Indignities Section 3301 (c) Irretrievable breakdown Mutual Consent Section 3301 (d) Irretrievable breakdown Two/Three year separation A list of qualified professions is available for inspection in the Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone(. ) IN THE COURT OF COMMON PLEAS OF THE OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania17050 197-52-3718 JUDICIAL DISTRICT CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM AFFIDAVIT OF NON-MILITARY SERVICE Michele Hoffman, being duly sworn according to Law, deposes and says that Plaintiff knows by Plaintiff's own personal knowledge and therefore avers that the defendant, Jason Randolph Hoffman, is 29 years of age and that Defendant is not in the military service of the United States or its allies, or olherwise within lhe provision of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments and that the defendant is employed by Holy Spidt Hospital. Sworn to and subscribed before me this the ~ day of Michele Hoffman, Plaintiff Notarial Seal Kenr~eth L. Schlegel, Notary Public Hampden Twp., Cumberland County My Commission Expires Apr. 4, 2005 IN THE COURT OF COMMON PLEAS OF THE __ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania17050 197-52-3718 CIVIL ACTION - LAW CASE NO. Oq-Ic~g~, I IN DIVORCE AFFIDAVIT AS TO SIGNATURE Michele Hoffman, being duly sworn according to law, deposes and says that Michele Hoffman is the Plaintiff in the above-captioned divorce action; that Michele Hoffman is familiar with the signature of the Defendant; and that the signature on the Acceptance of Service attached hereto as Exhibit "A" is the signature of the Defendant, Jason Randolph Hoffman. Sworn to and subscribed before me this the ~ day of Michele Hoffman, Plaintiff Notarial Seal Kenneth L. Schlegei, Notary Public Hampden Twp., Cumberland County My Commission Expires Apr, 4, 2005 M~mbar. penns,~'~ez~a Association of Notaries IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania17050 197-52-3718 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM ACCEPTANCE OF SERVICE I, Jason Randolph Hoffman, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divorce filed in the above-captioned matter. Date IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMI:~ERLAND Michele Hoffman, Plaintiff 5 Sunset Cimle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Cimle Mechanicsburg, Pennsylvania17050 197-52-3718 § CIVIL ACTION - LAW § § CASE NO. § IN DIVORCE TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) ol~ the Divorce Code was filed on the .~.~ day of ~o,~C.l~ . , ~O<3~./ _. 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301(c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. I understand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 7. 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. Section 4904 relating to unswom falsification to authorities. Dated: ~- ~" U/~ ~//~/~/./.~j j~J~ ~ '7' Michele Hofh-~, Plain'tiff' IN THE COURT OF COMMON PLEAS OF THE OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Cimle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 197-52-3718 __ JUDICIAL DISTRICT CIVIL ACTION - LAW CASE NO. DIVORCE TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the ~L day of /V~c.~4 , ,~0o~ _. 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301(c) of the Divorce Code, and I understand said Complaint. I waive any pleading pedods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. I understand that I may lose rights concerning alimony, division of property, lawyefs fees or expenses if I do not claim them before a diivorce is granted. 7. I verify that the statements made in this affidavit are ~'ue and correct. I understand that false statements herein are made subject 1:o the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated:.. Ja~n Randolph Hoffman, Defendant IN THE COURT OF COMMON PLEAS OF THE __ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 197-52-3718 CIVIL ACTION - LAW GI'V','/ TERM ~ASE NO, ~ IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divome without notice. 2. I undemtand 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 t 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 THE FOREGOING AFFIDAVIT 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. ^TE 7- IN THE COURT OF COMMON PLEAS OF THE _~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Michele Hoffman, Plaintiff 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania 17050 197-52-3718 ClIVIL ACTION - LAW CASE NO. (~ q- l a,~ l IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. I undemtand 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 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSF=' STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:____'7 IN THE COURT OF COMMON PLEAS OF THE ___ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUIVlBERLAND Michele Hoffman, Plaintiff § 5 Sunset Circle § Mechanicsburg, Pennsylvania 17050 § 170-62-1800 Jason Randolph Hoffman, Defendant 5 Sunset Circle Mechanicsburg, Pennsylvania17050 197-52-3718 CIVIL ACTION - LAW ~ASE NO. IN DIVORCE TERM PRAECIPE TO TRANSMIT RECORD To the Pmthonotary: Transmit thc record, together with thc following information, thc Cour~ for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of Complaint: the _,5' dayof tC'e~cuacy 2004 by Acceptance of Service ' 3. Complete either paragraph (a) or (b) (a) Date of execution of the Affidavit of Consant required by Section 3301(c) of the Divorce Code; By Plaintiff Michele Hoffman; by Defendant Jason Randolph ttoffman. (b)(1) Date of execution of the affidavit requi~:d by Section §3301(d) of the Divorce Code: (b)(2)Date of filing and service of the lamlaffs affidavit upon the respondent: 4. Related claims pending: 5. (Complete either (a) (b).) (a) date and manner of service of the notice of intention to file to transmit record, a copy ofwhichis attached: ~,-1~"(3q by ka~v~ ntel[,~ecv. Co) (1) Date Plaintiffs waiver of notice in §3301(c) Diw>ree was filed with the prothonotary: (b) (2) Date Defendant's waiver of notice in §3301(c) Divoree was filed with the prothonotary: 6. Attached hereto are: (a) ^ copy of the docket entries, certified by counsel ( or by clerk of courts - civil) to be a tree and correct copy of the original docket entries; Co) The original proposed divome decree (including a copy of the pre-nuptial agreement, which is requested to be incorporated by reference in said decree); (c) The completed form required by the commonwealth of Pennsylvania, Department of Health, Bureau of Vital Statistics; (d) The completed affidavit of non-military service muder the Soldiers and Sailors Civil Relief Act of 1940, 50 U.S.C.A. App. Sec. 520, if required bymle 1920.46. Mic e~e Hoffman, Pe~e~ IN THE COURT OF COlVlrvIoN PLEAS OF CUMBERLAND COUNTY STATE Of .~~~ PENNA. MT{-~IRLR P~JN~'I'F~ VERSUS NO. _n4 - ll'~l AND NOW, DECREED THAT DECREE lin DIVORCE MICHELE HOFFMAN AND JASON RANDOLPH HOFFMAN --~% 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 WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED;