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HomeMy WebLinkAbout02-0205Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. BOCH, Plaintiff VS · KAREN A. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - J~ CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIOHTS 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 against you and a decree in 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 with 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 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 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, PENNSYLVANIA 17013 (717) 249-3166 BY Andrew C. Sheely, E~u' PA. I.D. No. 62469 ¥ 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market S%reet P.O. BOX 95 Meohanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS · KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - ~0~ CIVIL TERM IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Terry S. Hoch, an adult individual who currently resides at 525 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Karen A. Hoch, an adult individual who resides at 1177 Summerwood Drive, Harrisburg, Dauphin County, pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 5, 1998 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the united States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. This action is not collusive. 10. The parties separated on or about July 31, 2001. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: January 14, 2002 flv, Andrew C. Sheely, ~squfre Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. /~J Date: January 14, 2002 ~ Ter~.~ Hoc~ ' - Andrew C. Sheely, Esquire 127 S. Market Stree% P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS. KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 -~d5/ CIVIL TERM IN DIVORCE .,%F F I D______~AV'~ T Terry S. Hoch, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating~ unsworn falsification to authorities. January 14, 2002 Andrew Co Sheely, Esquire 127 S. Market S%reet P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS. KAREN A. HOCH, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : 02 - 205 CIVIL TERM : : IN DIVORCE _ACC~.P~ANCE OF SERVICI~, I, Karen A. Hoch, Of 1177 Summerwood Drive, Harrisburg, Pennsylvania, 17111, hereby State that I am the defendant in the above captioned matter and that am accepting service of the divorce complaint in the above-captioned matter. I further state that I received a true and correct copy of the divorce complaint on January 24, 2002. Karen A. Hoch Date: January 24, 2002 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsbur~, PA 1~055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS · KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 205 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 15, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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.A. Section 4904 relating to unsworn falsification to the authorities. I IT~--- S. H6cln ' Andrew Co Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsbur~, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS. KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 205 CIVIL TERM 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. 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 decree 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.A. Section 4904' relating to unsworn falsification to the authorities-/DATE: April , 2002T~~h'~ ~/~/~ Andrew C. Sheely, Esquire 127 S. Marke% Stree% P.O. Box 95 Mechanicsburg, PA 15055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS · KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 205 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 15, 2002. I acknowledge that I received a copy of the divorce complaint on January 24, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: April ~) , 2002 Karen A. Hoch Andrew C. Sheely, Esquire 127 S. Marke% Street P.O. Box 95 Mechanicsbur~, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS. KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 205 CIVIL TERM 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. 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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. Ka~e~. Hoch Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) TERRY S. HOCH, VS · KAREN A. HOCH, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 205 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certified Mail, on January 24, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on April 25, 2002 and by Defendant on April 30, 2002. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: None. 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: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary May 6, 2002. Date Defendant's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary May 6, 2002. Attorney for Plaintiff C'-) ,c:z:) IN THE COURT OF COMMON PLEAS OFCUMBeRLANDCOUNTY STATE OF TERRY S. HOCH, PLAINTIFF VERSOS KAREN A. HOCH, DEFENDANT PENNA. NO. o2- 205 AND NOW, DECREED THAT AND DECree IN DIVORCE TERRY S. HOCH , PLAINTIFF, KAREN A. HOCH ,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. ATTEST: PROTHONOTARY