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HomeMy WebLinkAbout10-2023Rebecca A. DeHoff, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Darren L. DeHoff, Defendant :NO. A9 - 2C a3 CIVIL TERM 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, 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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. N Cumberland County Bar Association .. "' 32 South Bedford Street H ? Carlisle, Pennsylvania 17013 717 249 3166 , ) ( - AMERICANS WITH DISABILITIES ACT OF 199 0 ;n 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. Rebecca A. DeHoff IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Darren L. DeHoff , Defendant : NO. CIVIL TERM DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION COUNT The plaintiff, Rebecca A. DeHoff, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and equitable distribution: COUNT ONE DIVORCE UNDER 23 Pa.C.S. §43301(a)(6), 3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Rebecca A. DeHoff, who currently resides in Cumberland County, PA. Respectfully, Plaintiff requests her address remain confidential at this time. A Protection From Abuse action, York County No. 2008-FC-001047-12, between Plaintiff and Defendant remains in effect. 2. Defendant is Darren L. DeHoff , who currently resides at either 1072 East Canal Street, Dover, York County, PA 17315 or 3760 East Canal Street, Dover, PA, York County, PA 17315 since approximately September 17, 2009 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 21, 2003 in Camp Hill, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since approximately June 2, 2008 6. Defendant has been physically abusive towards Plaintiff resulting in the above referenced Protection From Abuse order. 7. There have been no prior actions for divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. 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 counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 10. Plaintiff repeats and realleges paragraphs one through nine as though fully set forth here in. 11. Plaintiff and Defendant have acquired property during their marriage which needs to be divided upon divorce. WHEREFORE, Plaintiff requests the court to enter an order dividing the property equitably between the parties and such relief as the court deems just. DATE Zc72-3/ Respectfully Submitted, Christ er Walker Certified Legal Intern MEGA RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date--3 a3 10 Plaintiff 0. 1. ?? Rebecca A. DeHoff Tr Rebecca A. DeHoff IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - DIVORCE Darren L. DeHoff , Defendant : NO. INVENTORY OF PLAINTIFF Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory are true and correct, to the best of her knowledge, information, and belief. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. CL QLLd--?- Plaintiff ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) 1. Real Property (X) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 12. Inheritances ) 13. Patents, copyrights, inventories, royalties ) 14. Personal property outside the home ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ) 16. Employment termination benefits - severance pay, worker's compensation claim/award ) 17. Profit sharing plans ) 18. Pension plans (indicate employee contribution and date plan vests) ) 19. Retirement plans, Individual Retirement Accounts ) 20. Disability payments ) 21. Litigation claims (matured and unmatured) ) 22. MilitaryN.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ) 26. Other MARITAL PROPERTY Plaintiffs lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names Of Number Of Property All Owners 2. 1996 Dodge Grand Caravan Rebecca DeHoff, Darren DeHoff PROPERTY TRANSFERRED Item Description Date Of Number of Property Transfer Consideration LIABILITIES Item Description Names Of Number of Property All Creditors Person To Whom Transferred Names Of All Dehtnrs 2 NONMARITAL PROPERTY Item Description Number of Property Reason For Exclusion Owner from Marital Property Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. Rebecca A. DeHoff Plaintiff V. Darren L. DeHoff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. /O -6?Od.3CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Rebecca A. DeHoff, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ya Z/. Resp ly submi , hristop r Walker Certified Legal Intern MEG ESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 r a r' l _ W=° D s=_? rn , - ' 1 0 Rebecca A. DeHoff, IN THE COURT OF COMMON FLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA C vs. NO. 10-2023 rnm r-q C-) r -u Darren L. DeHoff, CIVIL ACTION - IN DIVORCE © rn . Defendant c:; -- C? AFFIDAVIT OF CONSIENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was 'filed on March 23, 2010, 2. The marriage of Plaintiff and Defendant is itretrievably broken and ninety (90) 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 unswo n falsification. to authorities. Date Darren L. DeHo Ff, Defendant Rebecca A. DeHoff. , IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVAI` S: NO, 10-2023 -?v3c? o` ? ---t -z vs. = - Darren L. DeHoff, CIVIL ACTION - IN DIVORCE Defendant IPA e; C-) 'o ? X c? WAIVER OF NOTICE OF ANTEl MQN TO REQUEST --{ -- ENM OF A DIVORCE DECREE UNDER 83301(c) OF THE DIVORCE.CQDE 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 herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date 242 Darren L. DeHof , Defendant Rebecca A. DeHoff, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 10-2023 Darren L. DeHoff, CIVIL ACTION - IN DIVORCE ~ Defendant i -v ' ~ -< ~ r- ~- AFFIDAVIT OF CONSENT _ ~ ~~ :. q ~ ~ _.. ~ ~ ~ 1. A Complaint in Divorce under § 3301(c} of the Divorce Code was filed on March 23, 2010. 2. The mamage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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 falsification to authorities. Date g oZ Rebecca A. DeHoff, Plaint ff c T Rebecca A. DeHoff, Plaintiff vs. Darren L. DeHoff, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-2023 CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. --e -~ 7~ ~ ~ '~ ° r - ]~-~ .. ~~ a ~ -,, 2. I understand that I may lose rights concerning alimony, division of property, lawyer' 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 herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswo falsification to authorities. Date ~ ~~ Rebecca A. DeHoff, Plaints Rebecca A. DeHoff, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA V : NO. 10-2023 CIVIL TERM rn 1'x.7 C3 - . =M ' s C 3 ; Darren L. Deohff, cp - : CIVIL ACTION - LAW Defendant : IN DIVORCE s? ... D Y, PRAECIPE TO TRANSMIT RECORD t_i, To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under § (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: Service was complete on March 31, 2010 by certified mail restricted delivery, return receipt requested. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintiff 8/19/2012 ; by defendant 11/24/2010 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: N 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: 09/04/2012 Date defendant's Waiver of Notice was filed with the Prothonotary: 12/10/2010 Attorney for Plainti f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Rebecca A. DeHoff v. Darren L. DeHoff NO. 10-2023 DIVORCE DECREE AND NOW, ~G~-~ ~- ~ ` a'~/ ~- , it is ordered and decreed that Rebecca A. DeHoff ,plaintiff, and Darren L. DeHoff ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order far 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.") By the , A:., Attest: J. Prothonotary ~_ o ~~~ C ~ ~ ~' ~~~ ,° v'•s~'~%t..