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Home My WebLink About02-0131 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH A. HOEDEMAKER, Plaintiff VS. JOHN HOEDEMAKER, III, Defendant CIVIL ACTION---LAW NO. 200'~- l,~ ! CIVIL TERM 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. 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH A. HOEDEMAKER Plaintiff VS. JOHN HOEDEMAKER, III Defendant CIVIL ACTION--LAW NO. 2001, t21 c~vm TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE Plaintiff is Elizabeth A. Hoedemaker, who currently resides at 926 Hamilton Street, Carlisle, Cumberland County, Pennsylvania. Defendant is John Hoedemaker, III, who currently resides at 63 Regency South, Carlisle, Cumberland County, Pennsylvania. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. The Plaintiffand Defendant were married on November 30, 1968, at Little Fails, New Jersey. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaimiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree in divorce. ~ Steven J. Fishman, ID#16269 ~ 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717) 249-6333 I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. §4904, relating to unswom falsification to authorities. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH A. HOEDEMAKER, Plaintiff VS. JOHN HOEDEMAKER, III, Defendant :: CIVIL ACTION :: NO. 200~- :: IN DIVORCE LAW CIVIL TERM ACCEPTANCE OF SERVICE AND NOW, this 2-/~'-day of December, 2001, I John Hoedemaker, III, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. JOh I4ogbEMX R, m ELIZABETH A. HOEDEMAKER, : Plaintiff : : V. : : JOHN HOEDEMAKER, III, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02- 13 } CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on ~J~2ntm_rt~ 10 ,200L ~~_C~2. Defendant acknowledged receipt and accepted service of the Complaint on ,2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. ELIZABETH A. HOEDEMAKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : 07-- 1 3 I CIVIL TERM : JOHN HOEDEMAKER, III, : Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on KJ O33~&r~ lO ,2002. 2. Defendant acknowledges receipt and accepts service of the Complaint on ~ff~¢e~be~ ~[ ,2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: pr;t / JOfl~q ItOEDEMAKER, III ELIZABETH A. HOEDEMAKER, Plaintiff VS. JOHN HOEDEMAKER, III, Defendant : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-131 : 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 2. Date and manner of service of the Complaint: acceptance of service signed by Defendant December 21, 2001, filed in the Office of the Prothonotary on January 10, 2002. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on April 10, 2002; and Defendant on April 10, 2002. 4. Related claims pending: .None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not applicable. Steven J. Fishman, Esquire, ID#16269 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717) 249-6333 RL!ZABETH A. HOED}~:ER VERSUS IN THE COURT Of COMMON PLEAS OFCUMBERLAND COUNTY STATE Of ~~~. PENNA. NO. 2002-131 CIVIL DECREE iN DIVORCE AND NOW,__ DECREED THAT ELIZABETH A. HO~Dt~E~ER 2002 AND JOHN HO~D~AKER, III IT IS ORDERED AND , PLAINTIFF, , 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; None