HomeMy WebLinkAbout05-2012
DENISE D. HOCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
WILLIAM K. HOCH,
Defendant
NO.05~,;oI;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 t e
following pages, you must take prompt action. You are warned that if you fail to do so, th case
may proceed without you and a decree of divorce or annulment may be entered against yo by the
court. A judgment may also be entered against you for any other claim or relief requested .
these papers by the plaintiff. You may lose money or property or other rights important to ou,
including custody or visitation of your children. When the ground for the divorce is indi 'ties
or irretrievable breakdown of the marriage, you may request marriage counseling. A list 0
marriage counselors is available in the Office of the Prothonotary at Cumberland County
Courthouse, Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPE TV,
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 NO
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELO
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE 0
FEE.
CUMBERLAND COUNTY
BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: 717-249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common PIeas of Cumberland County is required by law to comp1 with
the Americans with Disabilities Act of 1990. For information about accessible facilities d
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any aring or
business before the court. You must attend the scheduled conference or hearing.
DENISE D. HOCH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
05 ~ .;z.pl.J-
NO. Civil Term
WILLIAM K. HOCH,
Defendant
IN DIVORCE
COMPLAINT
AND NOW COMES the above-named PIaintiff, by her attorney, Susan 1. Hartm ,
Esquire, and makes the following Complaint in Divorce:
I. Plaintiff, DENISE D. HOCH, is an adult individual eurrentIy residing at 2 2
Pine Road, Newville, PA, 17241, Cumberland County, Pennsylvania 17013.
2. Defendant, WILLIAM K. HOCH, is an aduIt individual currently residing 2255
Pine Road, Newville, PA, 17241, Cumberland County, Pennsylvania 17013.
3. Both Plaintiff and Defendant have been bona fide residents in the Commo ealth
of Pennsylvania for at least six months immediateIy previous to the filing of this Complai t.
4. The Plaintiff and Defendant were married on August 2, 1980 in Walnut B
Cumberland County, P A.
5. A prior action in divorce alleging irretrievable breakdown was filed in Jun , 1999,
in Cumberland County, Pennsylvania, docketed to 99-3014 Civil Term. It was purged fro the
list due to inactivity.
6. PIaintiff avers the marriage between the parties is irretrievably broken.
7. PIaintiff has been advised that counseling is available and that Plaintiff m y have
the right to request that the court require the parties to participate in counseling.
8.
America.
Defendant herein is not a member of the armed forces of the United State of
WHEREFORE, Plaintiff prays this HonorabIe Court enter a decree dissolving the
marriage between the parties.
Respectfully Submitted,
-<<J c;
usan J. Hartman quO e
Attorney for Plaintiff
Duncan & Hartman, P.C.
1 Irvine Row
Carlisle, PA 17013
(717)249-7780
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904, relating to
unsworn falsification to authorities.
~)~BtJ~
DENISE D. HOCH
--
Date: 4 - ~ -a~
DENISE D. HOCH
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
WILLIAM K. HOCH,
Defendant
NO.
Civil Term
: IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you on the state ents
will be admitted.
AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
I. The parties to this action separated in June 1999 and have continued to live se te
and apart for a period of a least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, I
fee or expenses if! do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are trne and correct. I understan
false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to
falsification to authorities.
Date: 4 - 7f - 06
B
PlaintifflDefcflBant
DENISE D. HOCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
WILLIAM K. HOCH,
Defendant
: NO.
Civil Term
IN DIVORCE
AFFIDAVIT
DENISE D. HOCH, Plaintiff, being duly sworn according to law, deposes and says
I. I have been advised of the availability of marriage counseling and unders d that
I may request that the Court require my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the D mestic
Relations Office, which list is available to me upon request.
3. Being so advised, I (ge1DO NOT) request that the Court require that my souse
and I participate in counseling prior to a divorce decree being handed down by the Court.
4. I realize that if the divorce is brought under section 330l(c) of the Divorc
then counseling must be completed within ninety days after the fiIing of the compIaint. I
divorce is brought under section 330l(d) of the Divorce Code, then counseling must be
eompleted within one hundred and twenty days after the filing of the complaint.
I understand that false statements herein are made subject to the penalties off 18
Pa.C.S.4904 relating to unsworn falsification to authorities.
.[;
DENISE D. HOCH
~
DENISE D. HOCH,
Plaintiff
IN 'THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
WILLIAM K. HOCH,
Defendant
NO.'
. Civil Term
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
To the Within Named Defendant:
You have been named as the Defendant in a divorce proceeding filed in the Court f
Common Pleas of Cumberland County. This notice is to advise you that in accordance w' h
section 3301(c) of the Divorce Code, you may request that the Court require you and your spouse
to attend marriage counseling prior to a divorce decree being handed down by the Court. list
of professional marriage counselors is available at the Domestic Relation Office, 13 Nort
Hanover Street, CarIisle, Pennsylvania. You are advised that this list is kept as a conveni
you and you are not bound to choose a counselor from the list. All necessary arrangeme
the cost off counseling sessions are to be born by you and your spouse.
If you desire to pursue counseIing you must make your request for counseling wi n
twenty (20) days ofthe date on which you receive this notice. Failure to do so will cons tute a
waiver of your right to request counseling.
Prothonotary
~
~
\):>
o
~
...c:..
o
~
-.
V'\
o
~
----
~
<:::::>
,
VI
o
~
~
-~
,-
-:>
""
C}
n
c:.;
'"
c:;:.
c::;.
C:..n
;t.:.-
-u
::-..;c,
\.0
-"',
~-,:"
~.~~
f.,,?
f',)
~-
o
-n
--i
H~F
ITi
"")
~
I
()
--T,
~'~-~
('("j
DENISE D. HOCH,
PIaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
WILLIAM K. HOCH
Defendant
NO. 2005-2012
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. Grounds for divorce: irretrievable breakdown under Section 3301 I (d)(1 ) of the
Divorce Code.
2. Date and manner of service of the complaint: U.S. Mail, certified, return receipt
requested, mailed May 4,2005, receipt dated May 6, 2005. See attached affidavit of service.
3. B.(1) Date of Execution of the plaintiff;s affidavit required by Section 3301(d) of
the Divorce Code: December 1,2005.
(2) Date of Service of the plaintiff's affidavit upon the defendant: June 3, 2005.
4. Related claims pending: none
5. Indicate date and manner ofserviee of the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under Section 3301 (d)( 1 )(1) of the Divorce
Code: See attached waiver of notice of intention
usan J. Hart
I Irvine Row
Carlisle, P A 17
717-249-7780
/
,.
:;:~~ ()
c_:; -n
,:.:;-"
,-
:':-""
:~;~
..,.~"
.""'..
(....:; -"";:
(..)
DENISE D. HOCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
WILLIAM K. HOCH,
Defendant
NO.C>5-~OI;lCivil Term
IN DIVORCE
COUNTER-AFFIDAVIT UNDER ~ 3301 (d)
OF THE DIVORCE CODE
I. Cheek either (a) or (b): ,~),t,]-\
..Ica) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree beeause (Check (1), (ii), or both):
(1) The parties to this action have not lived separate and apart for a period of at
Ieast two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
/ (a) I do not wish to make any claims for economic relief. 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. !AI (+1 ..
(b) I wish to claim economic relief which may include alimony, division or property,
lawyer's feed or expenses or other important rights.
I understand that in addition to checking (b) above, I must also fiIe all of my economic
claims with the prothonotarY in writing and serve them on the other party. IfI fail to do so before
the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may
be entered without further notice to me, and I shall be unable thereafter to file any economic
claims.
I verifY that the statements made in this counter-affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. !i 4904,
reIating to unsworn falsification to authorities.
Date:
])e c / )006
w~ {[~
Plfuatiff/Defendant
---- ---
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC
RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
o
c
,....,
c~~;,
<.:.~..;:.)
(~-,
o
.,
:~-..-;
r~l
<--
~;::
"J:-
Z~::
L,)
c.,.:'
--_.._._-~..<...~.._---_._-_..
,
DENISE D. HOCH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
WILLIAM K. HOCH
Defendant
NO. 2005-20] 2
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Susan J. Hartman, Esquire, being duly sworn according to law, do swear that I served a
Complaint in Divorce on the Defendant, William K. Hoch, by mailing a true copy to the
Defendant, postage prepaid, certified mail, return receipt requested, on May 4, 2005, to the
following address:
William K. Hoch
2255 Pine Road
Newville, PA 17241
Sworn to and subscribed
before me this 3,d day of
January, 2006.
.ct C4~
No ublic
NOTARIAL SEAL
Kathy L. Mummert, Notary Public
Borough of Carlisle, Cumberland Co., PA
My Commission Expir~s Aug. 11, 2007
EAL
Notary Public
berland Co., PA
\
-
. . .
. ..
L~ .:_' ... ......... ....
; ~;;i;.,~;~;.;;~;,,':;~;:f~4~:ultl~4f~.;: ~.">\
HEllY!L\1f:' flf'17~U'.. : ..". "', "',. "., "cc._.. ....'
~ ,._----';;::.--"..:..:-~- .....::::.--~~~::....~:...~ _.~--,----_.
'"
postage $ .0.60 .' ..-, :-::'j.:-7_',:'
-IT.3l)'-----;-. . 001, .
8 Certll\ed Fee . ~':'. ,)J;.'-l'/J!$n_ark
CJ Return Reclepl Fee n:l5'",.? - ,/ _ ~'<
a (Endorsement Required) /-' '. j /:'....'1\>
CJ Res lrlcted Delivery Fee "13":,50 r-,../' I ' . ,.,0t::r>,\~' ~:,
r'l (Endorfiemen\ Requ\red) I i, .Jt. (~
=r 1---- ", .d511l~1200 I
n.J T()te.\rostage&.Fees~~\ \1:.~ "1?Jt ~~,j__
~ SentTo '~r ~~,-,,,~~/,,~~~,.~<:_,,-:I'" l
~ Sfreef.'APf~O:;-...~.!_J__I~e-_~_..:- -~:.~.~..,~ ",;;~~_~~,u.'-;;'7/'--.u..n
o,pO Box No. 0101 5 5 i?~..0_~...g2,,~:'.-..-.n..n....
cilY;-S;aie;ziP+4n-"N~-;::;'~;'''-'' e ? A J7.;l </ (
SENDER: COMPLETE THIS SECTION
. .
. .
. Complete items 1 , 2, and 3. Also complete
item 4 if Restricted Delivery is desired;
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space pennrts.
AX Si~nat t&..'
.. 0 Agent
Addressee
B. eceived by (Printed Name C. Date of Delivery
',... ~-C "Vr:-
D. Is delivBl)' address different from Item 1? 0 Yes
If YES, enter delivery address below: 0 No
1. Article-Addressed to:
W:l\\"-VV"\ ~oc:."-1
~ CI 55'?, VIe Roa.cl
NeI..<..Jl/; II~\ '?A l"ldyl
ffflliVflr to ~I.-I'f ,.
,.u,.lessee Onli
3; Service Type
)s("Certffied Mail 0 Express Mall
o ~egistered 0 Return Receipt for Merchandise
o Insured Mall 0 C.O.D.
4. Restricted Delivery? (Extra Fee) )(ves
2. Article Number
(Transfer from service label)
PS Form 3811 , August 2001
7002 2410 0007 8509 6209
Domestic Return Receipt
102595-02-M-154D
('" rO ()
., c:,')
C c:::J -n
,:;..:,
(. .,'
..'
""-,'
j ~....:'
"..
,~
+
+
+
+
+
+
+
+
+
+
+
+
+
+
,
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+. '.- --,
~++++++++++++~:+++++++
++. +:'Ii
+
"
+
+
"
+
+
+
+
+
"
+
"
+
+
"
+
+
+
+
+
"
+
+
+
+
+
"
+
"
+
+
+
+
+
+
+
+
+
"
+
+
+
+
.
<+
+
+
+++++++++.+++++++++++.++
+;+;+.+:+:
++++++.;f.+.++++++
++.+++++++++++
:+. 'O':+. +.
+++++++:+
+
+
"
+
+
+
+
+
+
+
+
+
+
+
+
+
"
+
+
+
+
+
+
+
+
+
+
+
"
+
+
+
+
+
+
+
+
+
"
+
+
+
"
+
"
"
+
+
+
+
+
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
DENISE D. HOCH
Plaint if f
No.
2005 -2012
VERSUS
WILLIAM K. HOCH
Defendant
DECREE IN
DIVORCE
AND NOW,
1tL..,^- ~
, ~L, IT IS ORDERED AND
Iz.-r
DECREED THAT
Denise D. Hoch
, PLAINTIFF,
AND
William K. 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
QUA ;i
PROTHONOTARY
+
+. +. +. +.:+: +. + +. +. +. ++
+++'l' +:+:++++++ +++++'+'+++
+. ++ + +. ++ + 'f +. 'f+ +. +. +. +' + +
++
J.
"
+
"
+
+
+
"
"
"
+
+
+
+
+
+
.
+
+
.
"
+
"
+
"
+
+
"
+
+
"
+
+
+
+
.
+
+
"
+
+
"
+
"
+
+
+
+
+
+
+
,~ '/
/I,.J J' f",;;J",;"7/ ,:'7;1::")'"'
f;;.;:?'7? ''?If'';Ji/tf M. I r~ '
V_~1/)f. {L--' /~ r 'jI
.; ...
, .
Jv7 LI,/
,'lt1'U'/
./-------