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Home My WebLink About04-4991 TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. Ot./ .ljqq/ GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW 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. 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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, PA 17013 (717) 249-3166 vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO . () '1- If 9 9/ Cu..:..t.. I u.- TERESA L. OCHS, Plaintiff GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN DIVORCE COMPLAINT IN DIVORCE NOW COMES Plaintiff, TERESA L. OCHS, by her attorneys, Purcell, Krug & Haller, and avers as follows: COUNT I DIVORCE PURSUANT TO SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is TERESA L. OCHS, an adult individual who currently resides at 6208 Raleigh Street, Apartment 619, Orlando, Florida 32835. 2. Defendant is GARY L. OCHS, JR., an adult individual whose last known address is 320 Fifth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant has been a bona fide resident 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 May 19, 2001. 5. There have been no prior actions in divorce or annulment between the parties. 6. The marriage is irretrievably broken. I, Teresa L. Gehs VERIFICATION , Plaintiff in the within action, hereby verify that the facts contained in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. e.s. Section 4904, relating to unsworn falsification to authorities. ~ ~,,-l!I. ~M DATE: WI/tr1 '0 <.-:l S2 _:T I ,- (,,) C:. I"l . ~~~~ C) ~:=.) ::.) ~ u '2l ()--.. oj ':0 ---- d --=r:: J ~ '- ~ - '-:r- ~ -6 TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Nichole M. Staley O'Gorman, Esquire, Attorney for the Plaintiff, Teresa L. Ochs, in the above action, hereby swear and affirm that on the 4~ day of October, 2004, I sent, by certified mail, return receipt requested, restricted delivery, a Complaint in Divorce to the Defendant, Gerry L. Ochs, Jr. The Return Receipt Card signed by the Defendant on October 5, 2004, is attached hereto as Exhibit nAn. Sworn and sUbscri~ to before me this day of~, 2004. C~ttL~ -J. ~ra~o_{ Nota ubllc COMMONWEALTH OF PENNSYLVANIA Notarial Seal Angela S. Shaffer. Notary Pub/ic City Of Hamsburg, Dauphin Coonty My CommlSSlOI1 Expires Jan. 12, 2008 Member. Pennsylvania ASSOciatIon Of Notaries EXHIBIT "A" ;'X~>":;$t I~_~ . () C "'tJ t~ti !-","\rT1 :::~ ~J) --~7 [" (? ) ~ <;COl -"0 j;. ~~ =< '"'" = = .r- o n -< ". ::1: C5 N .j:.- TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSEN'J: 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on October 4, 2004. 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 unsworn falsification to authorities. Date: '2-/1 Y~f- , I TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW 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. 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. 54904 relating to unsworn falsification to authorities. Date: ;?/f'{!o~ I / f" TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 4, 2004. 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. 54904 relating to unsworn falsification to authorities. Date: MIs/oS . thU1Cl ~ . {JcLJ TERESA L CHSr Plaintiff " -',' TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW 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 =inal 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. 84904 relating to unsworn falsification to authorities. Date: :J/IS!(1S ctv CHS, Plaintiff .". ," () -- TERESA L. OCHS, Plaintiff IN THE COU2T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 4, 2004. 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. S4904 relating to unsworn falsification to authorities. Date: MIs/oS d.Lu.~~ TERESA L ,;.)., ~'," "."\ TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN JIVORCE 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 ~inal 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. s4904 relating to unsworn falsification to authorities. Date: ~ liS)C1'J I ~(lv CHS, Plaintiff .' TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 4, 2004. 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 unsworn falsification to authorities. Date: '2../1 Y~5- , f -------- - TERESA L. OCHS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-4991 GERRY L. OCHS, JR., Defendant CIVIL ACTION - LAW ACTION IN ~IVORCE 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 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: ;?- /I<.{ !o ~ I / '- - Nichole M. Staley O'Gorman, Esquire 1.0. 78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstalev@pkh.com vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-4991 TERESA L, OCHS, Plaintiff GERRY L. OCHS, JR., Defendant : CIVIL ACTION.. LAW : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 (x) 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint was served on Defendant on October 5, 2004 by Certified Mail, return receipt requested. - 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: by Defendant: January 8, 2005 January 6, 2005 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None. 5. (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 of Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with Prothonotary: February 24, 2005 Date of Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: February 25, 2005 " 'j '\ LV \ll~".1 ! f Date:J/ A~(OI) i Nichole M. Sta ey O'Go II.D,79866 . 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 CERTIFICATE OF SERVICE I, MICHELE PRITCHARD, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that service of the foregoing Praecipe to Transmit Record was made upon the following via First-Class Mail, Postage Prepaid on February 28, 2005: Gerry L. Ochs, Jr. 320 Fifth Street New Cumberland, PA 17070 -1l}tY-~) Michele Pritchard ~ ,.. . . . . . . . . . . . . . , . . . . . . . . , . . . . . , . . . . . . . . . . . . . , . . , . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . . , . . . , ;Ii :+: :f.;F.:f. ;f.~;F.;ti :+i;F.'" ;+; Of. 1ti:f.;t;:f. ;ti +. ,.. :+: ;+;;F.,., i1i;F.,.,;t;;ti;ti;F. :+;,.,;+::t; :Ii :f.'+'1f.;t; ;ti;t;:tili:f.:ti:+:;+; . . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TERESA L. OCHS PENNA. STATE OF No. 04-4991 VERSUS GERRY 1. OCHS, JR. DECREE IN DIVORCE AND NOW, /nil- "'^ J>~ . ,,20 oS , IT IS ORDERED AND TERESA 1. OCHS DECREED THAT AND GERRY 1. OCHS, JR. ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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; IVo AI t:- By THE cou~ At ,~ ., Of. '" ~. . ., :+';F.:+: "':f. Of iIi "'Of. . . . . PROTHONOTARY . ,. :+;:+;;+:;I: . . . . , . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . , . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'f.'+''''+' ~ ''-4z.0 VV' sJ r~ ~Vf-, ~ ~. ~ vv' -<.(7;7Ptr;;) ~ ' ')'0 <7[: / ,0 30 .$ E vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-4991 TERESA l. OCHS, Plaintiff GERRY l. OCHS, JR., Defendant : CIVil ACTION - LAW : ACTION IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the L day of (Yyl[C'A ,2005, hereby elects to resume the prior surname of TERESA L COSTEllO, and gives this written notice pursuant to the provisions of 54 P.S. 3 704. Date: 1/3 \ 1 OS , ~).'ic ~0) TERESA l., CHS ~Ul~~ Cotk~ ERESA/. OSTEllO STATE OF FLORIDA A :SS. COUNTYOFU~ -Q : On the 3 ( day of ~~ ' 2005, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. .......", JOSHUA ~'''Pf f*""~' """'" ON 1-toib'';''1 MY COMMISSION # DO 302904 W,e.'<!l EXPIRES, MafCh 24. 2008 "'J..r!f.~~ BondedThruNotaryPubUcLklde~ritem 4:;.. \-:> ~ ~f\~ . - -J ~ ~ r- ~~J --- -. (;;' .- ." -