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Home My WebLink About01-2270 KIM HOOVER-LONG, . Plaintiff · IN THE COURT OF COMMON PLEAS ! CUM]3ERLAND COUNTY, PENNSYLVANIA · V. TIMOTHY S. LONG, i Defendant · CIVIL ACTION- LAW · · DIVORCE 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 fights important to you. 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 at the 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 ANNUL~NT IS GRANTED, YOU MAY LOSE TI-~ RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA~ A LAWYER OR CANNOT AFFO~ ONE, ~ TO OR TELEPHONE TI-~ OFFICE SET FORTH BELOW TO FIND OUT WHE~ YOU CAN GET LEGAL I-~LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 240-6200 Le hah demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siquientes, usted tiene veinte (20) dias de plazo al partir de lag fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abagado y archival en la corte en forma excrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si ustted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perrier dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABAGADO INMEDIATAMENTE. SI NO TIENE ABAGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCURENT~ ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 240-6200 KlM HOOVER-LONG, . · IN THE COURT OF COMMON PLEAS Plaintiff' . · CUMBERLAND COUNTY, PENNSYLVANIA · · v. : NO. 01.~,270 ~ 7~.~..,~ · · TIMOTHY S. LONG, : CIVIL ACTION- LAW Defendant ' DIVORCE OF TIlE DIVORCE CODE 1. Plaintiff is Kim Hoover-Long, who has resided at 611 Herrin Lane, Enola, Cumberland County, Pennsylvania, 17025, since approximately January 20, 2001. 2. Defendant is Timothy S. Long, who has resided at 214 Spring Lane, Enola, Cumberland County, Pennsylvania, 17025, since approximately July of 2000. 3. 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 August 19, 1999. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. The Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. There is one minor child born of the marriage to wit Jordan T. Long, born October 13, 1995. 10. The Plaintiff' avers that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce. Res' ectfully submitted, By: _ EMILY LONi HOFFMAN, ESQUIRE Sup. Ct. I.D. # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108-1475 (717)233-1112 Attorney for Plaintiff' AFFIDAVIT Kim Hoover-Long, being duly sworn according to law, deposes and says that the facts contained in the foregoing Complaint in Divorce are tree and correct to the best of her knowledge, information and belief. Kim Hoover-Long ~ . Date: qtt, to ! o ~ KIM HOOVER-LONG, · IN THE COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 01-2270 CIVIL TERM TIMOTHY S. LONG · CIVIL ACTION- LAW 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. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on or about April 19, 2001 by signing an Acceptance of Service. 3. (a) Date of execution of the Plaintiffs Affidavit of Consent: August 21, 2001; Defendant's Affidavit of Consent: August 22, 2001. 4. Related claims pending: No claims were raised. 5. Date of filing of Plaintiff's Waiver of Notice: September 7, 2001. Date of filing of Defendant's Waiver of Notice: September 7, 2001. Respectfully submitted, HOFFMAN LONG LLP Richard W. Long, Esqmre Sup. Ct. ID # 79152 P.O. Box 11475 Harrisburg, PA 17108-1475 (717) 233-1112 {',~_~,~/rv' 7. ',~00 i Attorney for Plaintiff Date' '1 CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the attached document was served on the person below by First Class United States Mail sent on September 7, 2001' Timothy S. Long 214 Spring Lane Enola, Pa. 17025 Respectfully submitted, HOFFMAN LONG LLP Richard W. Long, Esqtdre Sup. Ct. ID # 79152 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108-1475 (717)233-1112 Date' ~'""f~~ ~ ,,~3)j Attorney for Plaintiff KIM HOOVER-LONG, ' IN THE COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA · · V. · TIMOTHY S. LONG, i · CIVIL ACTION- LAW Defendant . · DIVORCE ACCEPTANCE OF SERVICE I, Timothy S. Long, affirm that I accept service of the divorce complaint in the above action on April 19, 2001. KIM HOOVER-LONG, · IN THE COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 01 -2270 CIVIL TERM · TIMOTHY S. LONG, ' CIVIL ACTION- LAW Defendant ' DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(e) of the Divorce Code was filed on April 18, 2001. 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 herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification m authorities. TIMOTH,i/S. L~JNG ~.~. KIM HOOVER-LONG, · IN THE COURT OF COMMON PLEAS Plaimiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 01 -2270 CIVILTERM TIMOTHY S. LONG, · CIVIL ACTION - LAW Defendant · DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (e) of the Divorce Code was filed on April 18, 2001. 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification to authorities. KIM HOOVER-LC~ KIM HOOVER-LONG, · IN THE COURT OF COMMON PLEAS Plaimiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 01-2270 CIVIL TERM TIMOTHY S. LONG, · CIVIL ACTION- LAW Defendant · 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. 2. I understand that I may lose fights 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 unswom falsification to authorities ra .oovuu-, o 0 85510 I KIM HOOVER-LONG, · IN THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA v. ' NO. 01-2270 CIVILTERM TIMOTHY S. LONG, ' CIVIL ACTION- LAW Defendant · DIVORCE WAIVER OF NOTICE OF INTENTION TO RE UEST 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights 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 unswom falsification to authorities ' Date' g'-'Z.Z.- e~ - TIMOTHY S. LOJ~IG <~ -~ 8.5.510 I iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. KIM HOOVER-LONG ---- Plaintiff No. 01-2270 CIVIL TERM VERSUS CIVIL ACTION - LAW TI_________MOTHY S. LONG D I V 0 R C E Defendant DEC tEE iN DIVORCE AND NOW ~---- ,2_0_0_L_, IT IS ORDERED AND DECREED That KIM HOOVER-LONG , PLAINTIFF, AND_ TIMOTHY S. LONG , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. ThE COURT RETAINS JURISDiCTiON OF ThE FOLLOWING CLAimS WHiCh haVE BEEN RAISED OF RECORD iN This ACTION FOr WhiCh A FINAL ORDER HAS NOT YET BEEN ENTERED; ATTEST. J. PROThONoTARY