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HomeMy WebLinkAbout87-0067IN THE court Of COMMON PLEAS Of CUMBERLAND COUNTY DIANE M. HOOVER, Plaintiff N () ..........6...7. .............. .C...I...V.I.L., 19 87 Versus ..................... .q~_S._.__L~..r,. 9Y...HO_.O..V.E._r,.., .................. ............................................ Defe_nd_ant ................ DECREE IN 19..8.7..., it is ordered and decreed that .. .~:. ~°.gy.e.r. ......................... plaintiff, and James Leroy Hoover ...... defendant, ~.,~ ~re divorced from the bonds of mmrimony. 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 ~'~ By e C r : ......... ProthOnotary'_" IN THE COUR~ OF CO:~ION PLEAS OF DIANE M. HOOVER, C~IBERLAND COUNt', PENNSYLVANIA Plaintiff · v. NO, 67 CIVIL 1987 " JAMES LEROY HOOVER, Defendan~ .. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record~ together with the following info.rmation, to the court for entry of & divorce decree: 1. Ground for divorce: irretrievable breakdoma under Section (201(c)) ~X~) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: January 14, 1987 by Certified Mail fe~urn receip'~ requested and 'attached as Exhibit "A" 3. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by Section 201(c) of the Divorce Code: by the plaintiff ~.~. ~,-~ . by defendant (b) (1) Date of execution of the plaintiff's affidavit required by Section 201(d) of the Divorce Code: ; (2) date of service of the plaintiff% affidavit upon the defendant: &. Related claims pend/mg: Nona DIANE M. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. ~ CIVIL 1987 : JAMES LEROY HOOVER, : Defendant : IN DIVORCE NOTICE 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, High and Hanover Street, Carlisle. 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. Court Administrator, Third Floor Cumberland County Court House Carlisle, PA 17013 (717) 249-1133 Attorney for Plaintiff DIANE M. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : : JAMES LEROY HOOVER, : Defendant : IN DIVORCE COMPLAINT 1. Plaintiff is DIANE M. HOOVER, who currently resides at R.D. 99, Box 83-A, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is JAMES LEROY HOOVER, who currently resides at R.D. 99, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been a bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. Plaintiff has lived in Pennsylvania all of her natural life, being 29 years. 4. The Plaintiff and Defendant were married on October 5, 1975 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in SAID~S&GU~DO counseling. Having been so advised Plaintiff does not desire 26 W. High Street Carlisle, Pa. the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to ~nter a decree in divorce. Respectfully/~bmitted, Edward E. Guido, Esq. Attorney for Plaintiff SAIDIS & GUIDO 26 W. High Street Carlisle, Pa. COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Before me, the undersigned authority, personally appeared DIANE M. HOOVER who, being duly sworn according to law, deposes and says that the averments contained in the foregoing Complaint of which she has personal knowledge are true and correct and those averments based on information received from others she believes to be true and correct. Diane M. Hoover Sworn and subscribed to before me this \-~day ~ C~m~s~' ~ DIANE M. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. CIVIL 1987 V. : JAMES LEROY HOOVER, : Defendant : IN DIVORCE AFFIDAVIT I, DIANE M. HOOVER, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's 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 counselling 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. Section 4904 relating to unsworn falsification to authorities. Diane M. Hoover Sworn and subscribed to before me this \J~day of ~iC~<3~.~_~.~ , 1987. EXHIBIT "A" DIANE M. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 67 CIVIL 1987 : JAMES LEROY HOOVER, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT (1) A Complaint in divorce under Section 201(c) of the Divorce Code was filed on January 12, 1987. (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (3) I consent to the entry of a final decree of divorce. (4) 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. 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. · ' Diane Mi Hoover Sworn and subscribed to before me this ~ day Carlisle, Cumber!and Co., Pa. My Commission Expires Feb. 20, ;98,9 DIANE M. HOOVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 67 CIVIL 1987 : JAMES LEROY HOOVER, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT TO DIVORCE (1) A Complaint in divorce under Section 201(c) of the Divorce Code was filed on January 12, 1987. (2) Defendant acknowledges that service of the Complaint was made by certified mail on January 14, 1987. (3) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (4) 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. (5) I consent to the entry of a final decree of divorce. (6) I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. (7) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. Being so advised, I do not request that the Court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the Court. 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. James Ler~ Hobver Sworn and subscribed to k~fore me this ~/~ day/~-l.