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HomeMy WebLinkAbout09-2129AMMON LYNN HOCHSTETLER PLAINTIFF, v. BILLIE JANE HOCHSTETLER DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY!, PENNSYLVANIA CIVII. DIVISION NO. 0 ~'' ~- ~ ~-~ NOTICE TO DEFEND AND CLAIM RIGHTS ', To the Respondent: Billie Jane Hochstetler l ~{ crM You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after th s complaint and notice are served, by entering a written appearance personally or by ttorney and filing in writing with the court your defenses or objections to the claims set rth against you. You are warned that if you fail to do so the case may proceed withou you and a judgment may be entered against you by the Court without further no ice for any money claimed in the complaint or for any claim or relief requested by the PI inti#f. You may lose money or property or other rights important to you, including cu ody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown ~f the marriage, you may request marriage counseling. A list of marriage counselors s available in the Office of the Prothonotary at YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. F YOU DO NOT HAVE A LAWYER, TELEPHONE THE OFFICE SET FORTH BELO THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA ER IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABL TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEG L SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. '~ LAWYERS REFERRAL SERVICE COUNTY BAR ASSOCIATION IN YOUR COUNTY Lavryer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 AMMON LYNN HOCHSTETLER ) IN THE COURT OF C~MMON PLEAS PLAINTIFF, ) CUMBERLAND CO , PENNSYLVANIA v. ) CIVIL DIVISION BILLIE JANE HOCHSTETLER ) NO. ® ot.-~ ~ ~ C N' 1 ~'"crn. DEFENDANT ) ~!i COMPLAINT IN DIVORCE COMES, the Plaintiff, Ammon Lynn Hochstetler, by FILING PRO S~E, who files this Complaint in I}ivorce a statement of which is as follow: !, 1. The Plaintiff is Ammon Lynn Hochstetler, an adult individual currently residing at 311 Old Stone House Road, Boiling Springs PA 17007. Plaintiff has resided at this address for at least six months. 2. The Defendant is Billie Jane Hochstetler an adult individual currently residing at 311 Old Stone House Road, Boiling Springs PA 17007. 3. The Plaintiff has been a bona fide resident of the Commonw th of Pennsylvania for at least six (6) months previous to the filing of this Complaint. ~ 4. The Plaintiff and Respondent were married on date: Novemb~r 16, 1991 in the County of Gatesville, Coryell County, Texas. 5. There are minor child(ren) born of this marriage and wife is t now pregnant. The name of the child is: ICaitlynn Rae Hochstetler, Born: O~tober 20, 1996, Provisions for custody, child support and visitation are con ed in the Marital Separation Agreement attached which shall be incorporated ' this complaint. 6. There have been no prior actions of divorce or for annulment tween the parties. 7. Neither party is a member of any branch of military. T1_ 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. Plaintiff has been advise that counseling is available and that ~'laintiff may have the right to request that the Court require the parties to participate in 11. The Plaintiff, Ammon Lynn Hochstetler, respectfully request$ that this Court grant this Divorce pursuant to Section 3301 (c) of the Divorce Code and that a Decree of Divorce be entered. ~~i 12. After ninety (90) days have elapsed from the date of filing of khis Complaint Plaintiff and Defendant intend to file an affidavit consenting to a divorce. I verify that the statements made in the Complainrt are true and corre~t. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A Sectio~ 4904, relating to unsworn falsification to authorities. I! COMMONWEALTH OF PENNSYLVANIA County of Cumberland Respectfully submitted, ' ,-- Signature of Plaintiff Name: Ammon Lynn Hoc etler Dated: 2 0 0 9 . AFFIDAVIT li, I )ss. Before me, the subscriber; a Notary Public in and for said Commc County, personally appeared Ammon Lynn Hochstetler, who, being law, deposes and says that the facts contained within the foregoing CoY and correct to the best of his knowledge, information, and belief, make this Affidavit. i~~ Name: Ammon Lynn ath and Cumberland sworn according to rt in Divorce are true t he is authorized to -2- Sworn to and subscribed before me this day of ~ 2009 NO ARY P LIC v~?ti~t~?~~A;r,~.?f! ^i- r c\1tYSYi.VAN1A Nodal SCI Jermifer N. QroYe, Notary Public S+~ver Spring Twp., QKrrbederrd ~ My C,omrrli~ion Elites Jar. 28, ?A12 Member, Pennsylvania Association of Plotarles -3- Flr ~~ ~ ~~~ , 2Q49 APR -6 AM Ia~ 32 ~C~~ ~~..~1~ l~~ ~' ~ ~ ~'~ ~~ ~ d~ ~ I~PF ~k AMMON LYNN HOCHSTETLER ) IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND C PENNSYLVANIA ~I v. ) CIVIL DIVISION ~ BILLIE JANE HOCHSTETLER j NO. ~~ ' ~- ~ a- y II ~ N ~ ~ DEFENDANT ) ' MILITARY AFFIDAVIT ~, I, Billie Jsne Hochstetler, Defendant, being sworn, certify that the ~ollowing information is true: {Mark all that apply] ~! I am not on active duty in the armed services of the United I understand that I am swearing or affirming under oath to the tru ess of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. I, DATED: ~ ~ ~/ Signature of DEfend: Name: Billie Jane Address: 311 Old S1 Telephone Number: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On die ~ day of ,~, _, 2009, before me, a Notary Public Billie Jane Hochstetler, known to me to be the person whose name is sul document and acknowledged that she executed the foregoing for the purpose IN WITNESS WHEREOF, I have hereunto set my hard and seal. COMMO_NW~ALTH OF PENNSYLVANIA Notarial Seal Jerv~ifer N. Qrnre, Notary Public ~" SP-in9 TwP•. Grr'nberland ~Y My ~- Dart. 28.2012 Member, PertnsylvaMa ASaGelattan of Notarks -1- Pe'~~Y aPP Bribed to the within Herein contained. ~~.~w~Iy1yr{~~j{y~, iY+ y SV, Y ~~r ~~ ~~~~ `y` Amn+oN fy,~ ~c~ef Plaintiff v. : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Civil Action- Law No. CIVIL TERM a,~Il-~ ~~ ~~~ 09 ~~~a ~ Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Aoc. ~ ~ , 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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:,'-~~/"~, d`~Q~~' ` ~/ ~/~ ~(!~9 J~~. ~-~ ~'~~ i2~ ~E1 ,~. Cu~~~~~ ~ _ . _ ',~i, t' AMMON LYNN HOCHSTETLER PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~, ) CIVII., DIVISION BILLIE JANE HOCHSTETLER ) NO. Cb ~ • o~I o~ DEFENDANT ) AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on /S~,O/' ,~/ (p , 2009. (date:). 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~L1L-~l'~ ..~-0 g , 2009. Defendant -1- ,. FlLEu--P~;~=~C~~ QF Tf-IF ~~ ~~ i ~-~'~ ~:~;~~;Y Zang ~~~ -s ~~ ~z: ~~ curs ~,,;;-,~ ,, AMMON LYNN HOCHSTETLER PLAINTIFF, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BILLIE JANE HOCHSTETLER ) NO. Q ~ -,~/~ DEFENDANT ) 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~"~' _ ? ` 0 ! , 2009. Plaintiff -2- FILFu_a~~~;C~ p 2QD9 J'.~~ -~ P~ E2~ ~~ AMMON LYNN HOCHSTETLER PLAINTIFF, v. BILLIE JANE HOCHSTETLER DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVII., DIVISION NO. O~-~I o~ r WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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 ai~idavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: '7- ~~ p 9 , 2009. ~~~~ Defendant -2- r: f ' ,. _ I 2009 J~3 -B P~ 12~ 7-~4t i,'7i ~r~ tl Li.. AMMON LYNN HOCHSTETLER PLAINTIFF, v. BILLIE JANE HOCHSTETLER DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. Q9"' ~I ~ l ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE PLEASE take notice that I, Billie Jane Hochstetler, Defendant, was provided with a Copy of the Notice to Defend and Claim Rights, Affidavit of Separation and Complaint for Divorce and do accept service of same. I further enter my appearance in this action for all purposed. DATED: ~ ~v ~ Q ~Y De en ant Address:311 Old Stone House Road Boiling Springs PA 17007 Telephone: 717-422-5188 -1- F{LE~J~~t?i=~ ~U~ CU~~r~ ~~~;-~,~ ~r '+ {; S IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. ~'~~`~ CIVII. TERM 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the .Divorce Code. 2. Date and manner of service of the Complaint: Filed `~~ ~ • 0 f , 2009, -, was served on the Defendant ,6 ~~~o~ . ~~~...:.~/~, c~ u~ signed on ~ (,~ `~ ~ , 2009. 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: by the Plaintiff on ,TG?Gy ~ , 2009; by the Defendant on S~.t 7 , 2009. The Affidavits were filed on 2009 for both parties. 4. Related claims pending: None 5. (b) Date Plaintiii:'s Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: , 2009. Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: - _ , 2009. Respectfully submitted, Date: ~'fLf,,j~.. ~~_~-,,,~ ~~ ~; r c;, ~,',, ~~ttv9 ~ ; : ,? i ~; r , rte ~ ~-. ,