HomeMy WebLinkAbout94-03285
I
. I
~ 1
!
-5 '
-2 i
,
I
1
\
I
)
/
.:\wplllcjNI.....\Kocla,dj.
VI.
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION ~ DIVORCE
94-]J8S.cIVIL TERM
IN DIVORCE
BOBBI JO KOCH,
Plllntlff
.
.
.
.
.
.
NORMAN M. KOCH,
Defendlnt
.
.
NO.IICf
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 fall 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 requasted 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, Carlisle, Pennsylvania, 17013,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS
FEES OR EXPENSES BEFORE A DECREE OF 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, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 240-6200
FLOWER, MORGENTHAL, FLOWER & LINDSAY
AttorneYI or the PZ7lI,n
I '
By: I - .~
Carol . U say, Esquire
10 # 44693
11 E, High St., Carlisle, PA 17013
(717) 243.5513
c:1..,IIIcJII4lv.....\KlQ,.,.
BOBBI JO KOCH,
Plaintiff
va.
IN THE COURT OF COMMON PLEAS OF
CUMBERUND COUNlY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
94. CIVIL TERM
IN DIVORCE
NORMAN M. KOCH,
Defendant
CO.MfI.AtNI
BOBBI JO KOCH, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY,
respectfully represents:
1. The Plaintiff Is BOBBI JO KOCH, who currentiy resides at 35 Winchester Gardens, Carlisle,
Cumberland County, Pennsylvania 17013, since 1993.
2. The Defendant Is NORMAN M, KOCH, who currentiy resides at 267 Uncoln Street,
Carlisle, Cumberland County, Pennsylvania 17013-1822, since 1993.
3. The Plaintiff and Defendant both have been bona fide residents In the Commonwealth of
Pennsylvania for at least six months Immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on April 21, 1990, at Mechanlcsburg,
Cumberland County, Pennsylvania,
5, That there have been no prior actions of divorce or for annulment between the parties In
this or In any other Jurisdiction,
8, The Plaintiff avers that she Is entitied to a divorce on the ground that the marriage Is
Irretrievably broken and Plaintiff Is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code.
2
c:\..,sl~~''''
7, Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate In marriage counseling, and does not
request counseling,
8, Plaintiff requests the Court to enter a decree of divorce.
FLOWER, MOROENTHAL, FLOWER' LINDSAY
Attorney. for the Plaintiff
DATE: June ~ .1jS!.
3
BOBBI JO KOCH,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
NO. 94.3285 CIVIL TERM
IN DIVORCE
Plaintiff
v.
NORMAN M. KOCH,
Defendant
NORMAN M. KOCH. Defendant, being ciul~ sworn according to law, depo6es and says:
1, That a Complaint In Divorce under Section 3301 (c) of the Divorce Code was filed on June
17, 1994.
2, That my marriage with BOeBI JO KOCH. Plaintiff, Is Irretrlavably broken.
3. That I consent to the entry of a Decree In Divorce on the grounds that the marriage Is
Irretrievably broken,
4. That I understand that I may lose rights concerning alimony, division of property,
counseling 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 to the best of my
knowledge. Information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa,C.S. 4904 relating to unsworn falsification to authorities.
· ,/
f;.,1'I/:(l1 1'~' frtr.(
Normsn M, Koch, Defendant
Date: '7'2'1"/'/
InrYI\fI"
(PI:!) 'll'
~). I "." 1
Amiij;q...;",.
a:; ,....
. "I'I.
.. r.
~ " "
,-,
.' ,
m
lt1 1 .
=
In
I 1
~ .,
. j,.;
1;'
~ .......
"
;i':
if':
:~
('-.I
r-.I
... .
d.4