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HomeMy WebLinkAbout04-50760. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KERSTIN U. HOCKER, Plaintiff v. STERLING W. HOCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ?-w t NO. v Y - SD 7e- CIVIL ACTION - LAW 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 Barbara Sumple-Sullivan, Esquire Supreme Court 432317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KERSTIN U. HOCKER, Plaintiff V. STERLING W. HOCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO. ON•SU9(. -7., CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is KERSTIN U. HOCKER, an adult individual residing at 201 Glenn Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is STERLING W. HOCKER, an adult individual residing at 201 Glenn Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4, The Plaintiff and Defendant were married on April 21, 1986 in Berlin, Germany. 5. There are two (2) minor children born of this marriage: Vanessa N. Hocker, born February 15, 1990; and Michelle S. Hocker, born September 15, 1999. 6. The parties separated on October 1, 2004. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I-DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry ofa divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. 2 COUNT H EQUITABLE DISTRIBUTION 12. The averments in paragraphs 1 through I 1 of Plaintiffs Complaint are incorporated herein by reference thereto. 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 401(d) of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Kerstin U. Hocker, prays this Honorable Court to enterjudgment: A. Awarding Plaintiffa decree in divorce; B. Equitably distributing the marital property; and C. Awarding other relief as the Court deems just and Dated: /f) / '2004 Barbara Si e-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 3 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KERSTIN U. HOCKER, Plaintiff V. STERLING W. HOCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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 require 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 to unsworn falsification to authorities. Dated: {b I -, OOo y KERSTIN U. ROCKER Barbara Sample-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KERSTIN U. HOCKER, Plaintiff V. STERLING W. ROCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, KERSTIN U. HOCKER, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE/CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C. S.A. Section 4904 relating to unsworn falsification to authorities. Dated: /01_61/ t" KERSTIN U. HOCKER Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KERSTIN U. HOCKER, Plaintiff V. STERLING W. ROCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, KERSTIN U. HOCKER, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCEICUSTODY are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: /01-0/ ?. KERSTIN U. HOCKER 7- ?v ? Ic c C r? e-J 0 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KERSTIN U. HOCKER, IN THE COURT OF COMMON PLEAS Plaintiff V. STERLING W. HOCKER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5076 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7003 0500 0001 6564 5543, Return Receipt Requested, on the above-named Defendant, Sterling W. Hocker, on October 13, 2004 at Defendant's last known address: 201 Glenn Road, Camp Hill, PA 17011. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: October 14, 2004 Barbara Sample-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID 432317 Attorney 1br Plaintiff U.S. Post al Service CERTIF IED MAIL , RE CEIPT (Domestic M ail Only; No Ins urance Coverage Provided) A,„ y y a u-I "a Pastege $ fQ,6Q ? rl O Certified Fee . R 0 q t Fee Realm {i.]?j m Re (Endorsement Required) 888 CO O ResMCted Delivery Fee (Entlorsement Required) $3.? Llry( E3 TMal Postage 8 Fees $ $8.15 4 ,?.c` !: n M -- M1 SVeet, Apt. No.; w PO Box Na. Q-z I r .!? !2 ........ ......... ............... -11 ' / B EXHIBIT "A' CJ n? r ' ?._ o L y C:;` . ?"? ?' _ f - ? _` ?. , ? -?"N'3 ? r: r ' -,, ? ' 1 -, ?, c:, Curtis R. Long Prothonotary office of the i3rotbonotarp Cumberlanb QCuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 041- SA % CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573