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HomeMy WebLinkAbout06-6398 VIOLA V. HODGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. be: - (;3 r ( : ACTION IN DIVORCE Civil Term PAUL R. HODGE, Defendant 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 VIOLA V. HODGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. () {, - & 3 'i t Civil Term vs. PAUL R. HODGE, : ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Viola V. Hodge, a competent adult individual, who has resided at 147 W. North St., Carlisle, Cumberland County, Pennsylvania, 17013, since 1981. 2. Defendant is Paul R. Hodge, a competent adult individual, who has resided at 147 W. North St., Carlisle, Cumberland County, Pennsylvania, 17013, since 1981. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 10, 1995 in Hagerstown, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither PIl}-intiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. ~4904 relating to unsworn falsification to authorities. t;;;;"~~I?~~ Viola V. Hodge, Plaintiff Respectfully submitted, Date: 1#" e Adams, Esquire .D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~~~ ~~ \.-- -t--- ~ c::; 'lA c::.. o c: .._~ ' I ~ ~ r-.,.;) = C:':"':J d""" (") -n ::::i f'h 'T1 r-" ~~2 ;7:~ C) ~ I N -0 ()l c;n Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. olo -lo3~ g- Civil Term VIOLA V. HODGE, vs. PAUL R. HODGE, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this November 24,2006, I, Jane Adams, Esquire, hereby certify that on November 7,2006, a certified true copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT was served, via certified mail, return receipt requested, addressed to: Paul Hodge 147 W. North St. Carlisle, Pa. 17013 DEFENDANT . Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. . Print your name8nd address on the reverse so that we can retum the card to you. . Attach this card to the back of the mal/piece, or on the front if space permits. 1. ArtlcleAddressed to: ':''\nT..J '10 lS 7' 1117 -q ~1CY'1.;:-1 ~.~ 8~~LIS~~ ~, 17013 2. ArtIcle Number (1hInefer from IIMceIlfbel) PS Form 3811, February 2004 70D4 1350 0003 7147 0888 ,_J'bm&Stic Return Receipt 102S115-02-M-1540 Adams, Esquire I No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF r-' c::? ,~ cf' .-. ,p,:_'~ '3: tv ....J -0 ~ (.;:J .. .- .:;:- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VIOLA V. HODGE, vs. No. 06 - 6398 Civil Term PAUL R. HODGE, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~-~-c01 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 63301(d) OF THE DIVORCE CODE 1. I consent to 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: c::l- '1-.0'7 2 g ~ ~ -- ~:D ...., ~q;. 1""'1 co !~ ~5; CN ~"': ~c -0 g3l ~Q :E ~~ s;g N ~ ~ .. N VIOLA V. HODGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 06 - 6398 Civil Term PAUL R. HODGE, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 7T~ f- Jt76? WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 6330l(c) AND 6330l(d) OF THE DIVORCE CODE I. I consent to entry of a fmal 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: ;Q-pfi-. 7;oJ-pp::r g~~H~ Paul R. Hodge, Defendant ~ 2 ~, ~5? ~c; :.:::: :J:>:o ~o rC ~ ~ ~ ~ -n ~:n G1;ii\ ~I iG g .. ~ - ~ N Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VIOLA V. HODGE, vs. No. 06 - 6398 Civil Term PAUL R. HODGE, ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under &3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Served via certified mail, restricted delivery, return receipt requested, on: November 7, 2006. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: February 9, 2007 By Defendant: February 9, 2007 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: February 13,2007 Date Plaintiffs Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: February 13,2007 Date: :;;/ &./ /0 '1 1 e Adams, Esquire . . No. 79465 ~ S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff 2 s: -Vcrl rnrl' L,-.~:; 6~I ._L ...1.', r:C' ~;~~ ;-:; =2 r-.) = = --' .." f"11 CO N ~ ~:n "\Jtn ~Jt:I -!:')L Co ::;:i .,-, ---1'1 (;0 ~'-m 9 ~ ~ -v ~. -- N .' o ,. ,. ,. if.if. if.if. if. if. if. if. ;+; ;+;;f, ;+; ;+;;+;if.;f, if.if.if.if.if.if.if.;f,if.if.if. if.if.if.~ ~if.if.;+; ;+; if. if. IN THE COURT OF COMMON P AS OFCUMBERLANDCOUNTY STATE OF PENNA. Viola V. Hodge, Plaintiff No. 06 No. VERSUS Paul R. Hodge, Defendant DECREE IN DIVORCE AND NOW, ......-r'1 t1A.- e/1 Viola V. Hodge /~ , -2007 , IT IS OR DECREED THAT , PLAIN IFF, Paul R. Hodge I DEFEt I DANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDE YET BEEN ENTERED; HAS NOT None. ~ ~~if.if.if.if.if.~if.if.if. if. ~ ~~~ ~ ~~~~~~~~if. ~if.~~~ if.if. ~if.~ if.~~~ ~~~~~~~..~~ ~~~~if.~~ ,. ~ ~ ,. ~ if. if. if. if. if. if. if. if. if. if. if. if. if. ,. ~ ~ if. if. ~ ~ ;!' ~ ~ '" J. . ~ 1: ~ ~V( cO. lJ ..f' ~ ~,~ ~ 4; -rJ (fl- 1-[" , . '