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Home My WebLink About09-6267 LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com TIMOTHY M. HOOT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEPHANIE HOOT, NO. G °Z 7 CIVIL TERM Defendant 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 *udg rent may also be entered against you for any other claim or relief requested in these papers ?y 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 at Cumberland County Courthouse, 1 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 2 11 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com TIMOTHY M. HOOT, Plaintiff V. STEPHANIE HOOT, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. d / - io)- 6 7 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the Plaintiff, Timothy M. Hoot by and through his attorneys, Law Offices of Peter J. Russo, P.C. and avers the following in support of his complaint in divorce: 1. Plaintiff is Timothy M. Hoot, an adult individual who has resided at 1152 Siddonsburg Road, Mechanicsburg, Pennsylvania since approximately 1998. 2. Defendant is Stephanie Hoot, an adult individual who has resided at 1152 Siddonsburg Road, Mechanicsburg, Pennsylvania since approximately 1999. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 2, 1999, in Mifflinburg, Union County, Pennsylvania. 5. Plaintiff and Defendant separated on March 11, 2009. 6. There have been no prior actions of divorce or for annulment between the parties. 3 7. The marriage is irretrievably broken. 8. The parties have participated in counseling for approximately six (6) weeks. COUNT I -- DIVORCE 9. The prior paragraphs of this Complaint are incorporated by reference as though fully set forth herein. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plain-fiTf'-- Peter J. Russo, Esquire ID #72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: 9 L L c' VI 4 TIMOTHY M. HOOT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEPHANIE HOOT, NO. CIVIL TERM Defendant : IN DIVORCE I, Timothy M. Hoot, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: 4 0,w,??? Timm y of 5 OF F1l.EG?-+ FFICE /yam 27#09 SEP ! $ PH 12: 29 33sy ,e - a,36 /1, ,,. Cj,?tu l7OSs. ? o y TIMOTHY M. HOOT, Plaintiff V. STEPHANIE HOOT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-6267 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I accept service of the Complaint in Divorce. I hereby certify that I am authorized to accept service on behalf of the defendant of the Complaint filed in the above-captioned matter. L1 /j Date: September 23, 2009 "Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Supreme Court ID: 32317 (717) 774-1445 Attorney for Defendant i 2009 SE' 28 I'd 13: 2 4 ( 5 .,/1..15'..._ tt_ uir f v?L