HomeMy WebLinkAbout10-0549
SCOTT L. HOOVER,
Plaintiff
V.
AMY S. HOOVER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 10-54q CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
N
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,
including custody or visitation of your 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS'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 SOUTH BEDFORD
CARLISLE, PA 17013
(717) 249-3166 OR (800)990-9108
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&U ULAKIS
Kara W. Haggerty, Esquire
Attornev I.D. #: 86914
2 West High Street
Carlisle, PA 17013
(717) 249-0900
SCOTT L. HOOVER,
Plaintiff
V.
AMY S. HOOVER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. /p _ y4/q CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
1. Plaintiff is Scott L. Hoover, who currently resides at P.O. Box 185, Newburg,
Cumberland County, Pennsylvania 17240.
2. Defendant is Amy S. Hoover, who currently resides at 1301 Mary Avenue,
Shippensburg, Pennsylvania 17257.
3. The 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. The Plaintiff and Defendant were married on October 21, 1995, at Shippensburg,
Pennsylvania.
COUNT I - DIVORCE
5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by
reference as though set forth in full.
6. There has been a prior action for divorce filed between the parties at Cumberland
County Docket Number 01-5762; however, no further action was ever taken on that divorce
pleading.
Divorce is sought pursuant to the provisions of the Divorce Code, ? 3301(c) and
3301(d), in that:
a. The marriage is irretrievably broken.
b. Plaintiff and Defendant have lived separate and apart since November 7,
2000, and continue to do so.
Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the court require the Parties to participate in such counseling.
9. The Plaintiff in this action is not a member of the Armed forces.
WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce.
Respectfully submitted,
DATE () 1 2-5 /0
ABom & KUTULAKis, L.L.P.
Kara W. Haggerty, EsqM84
Supreme Court ID No2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff
VERIFICATION
I, SCOTT L. HOOVER, verify that the statements made in this Divorce Complaint are true
and correct to the best of my knowledge, information, and belief. 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 110 2 t i .ter-r.c.
SCOTT L. HOOVER