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HomeMy WebLinkAbout10-2302 20 10 A R -6 Pit I : 23 JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@Qmail.com HONEY C. HOCKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. MATTHEW L. HOCKLEY, Defendant No. 0.4734912 Civil Term ACTION 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 #. -T/ A? &AW /# ??Y a t/el 0?i3 Ph 11 JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@Qmail.com HONEY C. HOCKLEY, Plaintiff vs. MATTHEW L. HOCKLEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Term : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Honey C. Hockley, a competent adult individual, who resides at 245 Meals Drive, Carlisle, Cumberland County, Pa., 17015. 2. Defendant is Matthew L. Hockley, a competent adult individual, who resides at 17 E. Pine St., Mount Holly Springs, Cumberland County, Pa. 17865. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 3, 2006 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together, namely, David Matthew Hockely, born April 25, 2007. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 4ppl C?46a Honey C. Ho kley, Plaintiff Respectfully submitted, I verify that the statements made in this Complaint 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. oe,a 9l?l0 3U.No ams, Esquire 1. 79465 1 South St. C Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF F1LE?-'?• ?rr 2010 Ai' -b Gii !- 24 JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com Cti?Y't , rl 4 rl a HONEY C. HOCKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. MATTHEW L. HOCKLEY, Defendant : No. 0 "a3Ga Civil Term : ACTION IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on November 2, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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: Ab 44. / L' Honey C. Hock y, Plaintiff HONEY C. HOCKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. lG" aka Civil Term MATTHEW L. HOCKLEY, ACTION IN DIVORCE - Defendant G NOTICE TO RESUME PRIOR SURNAME _ =n - 'T _ r To the Prothonotary: c > Notice is hereby given that the Plaintiff in the above matter: X prior to the entry of a Final Decree in divorce. OR _ after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of PUNT avowing her intention pursuant to the provisions of 54 P.S. §704. Date: "' t\ &" 4vmh Honey C. Ho kley Prior Name Honey C. Pu t Signature of Name being resumed. COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBE LAND ) On this, the day of 2010 before me, the undersigned officer, personally appeared HONEY C. HOCKLEY/HONEY C. PUNT personally known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and ffal se `Not ry Public My commission expires: ft- s5-51 p??(- ay00,(13 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Stephanie Ann McQuiston, Notary Public Middlesex Twp., Cumberland County My Commission Expires December 09, 2012 , EI_L.? ??C 11 e P l , 12 FE 14'3 ??N?`?l_?'?I~31 HONEY C. HOCKLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10 - 2302 Civil Term MATTHEW L. HOCKLEY, : CIVIL ACTION - LAW Defendant : DIVORCE ACKNOWLEDGMENT OF SERVICE I, Matthew L. Hockley, Defendant, acknowledge that I received a copy of the Notice to Defendant and Divorce Complaint in the above-captioned matter on or about April 15, 2010. Date: Hockley, Defendant t ,. t t O ? AS?? ? HONEY C. HOCKLEY, : IN THE COURT OF C LE Plaintiff CUMBERLAND COUNTY{?!}?yf{Lt V ( V. : NO. 10 - 2302 Civil Term MATTHEW L. HOCKLEY, : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on April 6, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 2-/0 ` / 2 "ew L. Hockley, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301Ic1 AND 433011d1 OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice 2. 1 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. 1 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: Z v M L. Hockley, Defendant n C= ra HONEY C. HOCKLEY, : IN THE COURT OF COMMON PLEAS-oQm Plaintiff : CUMBERLAND COUNTY, PENNSYL V. : NO. 10 - 2302 Civil Term MATTHEW L. HOCKLEY, : CIVIL ACTION - LAW = ?; cn Defendant : DIVORCE C:s AFFIDAVIT. OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on April 6, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 3 l 2,- Honey C. Pun f, Plaintiff f/k/a Honey C. Hockley WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND 63301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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: Z, Honey C. Pun Plaintiff f/k/a Honey C. Hockley HONEY C. HOCKLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLV/IIA` ?l?7 ? fTiM: V. : NO. 10 - 2302 Civil Termer MATTHEW L. HOCKLEY, : CIVIL ACTION - LAW C Defendant : DIVORCE PRAEC_IPE TO TRANSMIT RECORD -~ TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce Decree: Code. 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce 2. Date and Manner of the service of the Complaint: via certified mail, return receipt, signed electronically Defendant also signed acknowledgement of service 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: February 10, 2012 By Defendant: March 14, 2012. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: February 10, 2012. 6. Date Plaintiffs Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: Contemporaneously with this Praecipe. Respectfully submitted, Date: Ja Adams, Esquire I. No. 79465 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HONEY C. HOCKLEY V. MATTHEW L. HOCKLEY NO. 10 - 2302 Civil Term DIVORCE DECREE AND NOW, Ya&Wt -?2 ( , o7C l-1. , it is ordered and decreed that HONEY C. HOCKLEY , plaintiff, and MATTHEW L. HOCKLEY bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for 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.") None. By the Court, Atte J Prothonotary 07j ie coy Mtq ll pal 71