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Home My WebLink About02-3944IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY Fifty - Ninth Judicial District NO: 01- 5529 RECORDED: 08/27/01 BOOK: PAGE: KIND: DIV 0 DEBT: $ 0.00 SURCHARGE: 10.00 PRO: 40.50 JCP FEE: 5.00 SAT DATE: 07/24/02 <PLAINTIFF> 1 HOFFMAN STEVEN T <DEFENDANT> 1 HOFFMAN DEBORAH J AUGUST 27, 2001 Plaintiff's Complaint in Divorce filed by LEE E. OESTERLING, ESQ. SAME'DATE: Certified copy of Complaint with endorsement thereon to plead to same, issued for service upon the defendant. Verification filed: FEBRUARY 12, 2002 Plaintiff's and Defendant's Affidavits of Consent filed. JULY 17, 2002 - Motion to Transfer Divorce Complaint to Cum~Derland County filed by Lee E. Oesterling, Esquire on behalf of Plaintiff. Entire file sent to Judge for Order. JULY 24, 2002 - ORDER - AND NOW, on this 17th day of July 2002, IT IS ORDERED AND DECREED that the aforementioned Complaint for Divorce, docket number 2001-5529 and all documentation related thereto, shall be transferred to Cumberland County, Pennsylvania, pursuant to and in conformity with the enclosed Motion to Transfer. BY THE COURT /s/ John H. Foradora, Specially Presiding. SAME DATE - Cop~es sent to the Court of Common Pleas of Cumberland County, Lee E. Oesterling, Esquire for Plaintiff and Deborah J. Hoffman, Defendant. *True and Correct Copy from the cords of Cameron Co. 7/24/02 TRANSFERRED TO CUMBERLAND COUNTY. IN THE COURT OF COMMON PLEAS OF THE 59Tu JUDICIAL DISTRICT CAMERON COUNTY PENNSYLVANIA STEVEN T. HOFFMAN : Plaintiff, : DEBORAH J. HOFFMAN : Defendant : Docket No. 2001-5529 Civil Action - Divorce ORDER AND NOW, on this f~r~72d day of ~ ,2002 it is ORDERED DECREED that the aforementioned Complaint for Divorce, docket number 2001-5529 and all documentation related thereto, shall be transferred to Cumberland County, Pennsylvania pursuant to and in conformity with the enclosed Motion to Transfer. True and Correct Copy ~?~v~!fied from the :, ,,~:,o H~ of Cameron Co. IN THE COURT OF COMMON PLEAS OF THE 59Tu JUDICIAL STEVEN T. HOFFMAN Plaintiff, DEBORAH J. HOFFMAN Defendant Docket No. 2001-5529 Civil Action - Divorce DISTRICT CAMERON COUNTY PENNSYLVANIA MOTION TO TRANSFER DIVORCE COMPLAINT 1. Plaintiff to this action is Steven T. Hoffman, who currently resides in Cumberland County, Pennsylvania. 2. Defendant to this action is Deborah J. Hoffman, who is curre~ltly a resident of Cumberland County, Pennsylvania. 3. Plaintiff filed a Complaint for divorce with Court of Common Pleas, of Cameron County at docket number 2001-5529 requesting a Divorce under No-Fault Grounds of Section 3301 (c) of the Divorce Code and with the belief that the parties would be able to mutually resolve disputes and materia, l. ly participate in the proceedings. 4. Due to their non-resident status, the parties are unable to file a Marital Settlement Agreement and Qualified Military Retirement Order thereby frustrating the intent of the parties to mutually resolve all issues surrounding marital assets and obligations. 5. Plaintiff seeks to address these issues in The Court of Common Pleas of The Ninth Judicial District, Cumberland County as the appropriate and more convenient forum to resolve the issues surrounding dissolution of the marriage. WHEREFORE, Plaintiffprays that this Honorable Court transfer the complaint for divorce and all supporting documentation to Cumberland County, Pennsylvania. Dated: 5-31-02 Res,pect .d, Lee E. Oesterling, Esquire, #71320 Attorney for Plaintiff 42 East Main Street true aha G~ Copy Mech~ic~b~g, PA 170~5~0e0 from the ~ c:~:ds of Cameron Co. ~ :iDa, IN THE COURT OF COMMON PLEAS OF THE 59TM JUDICIAL DISTRICT CAMERON COUNTY PENNSYLVANIA STEVEN T. HOFFMAN : Plaintiff, : DEBORAH J. HOFFMAN Defendant Docket No. 2001-5529 Civil Action - Divorce ORDER AND NOW, on this day of ,2002 it is ORDERED AND DECREED that the aforementioned Complaint for Divorce, docket number 2001-5529 and all documentation related thereto, shall be transferred to Cumberland County, Pennsylvania pursuant to and in conformity with the enclosed Motion to Transfer. BY THE COURT Correct Copy horn the of cameron Co. Law Offices ofHazlett & Oesterling 20 South Market Street Mechanicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS OF THE 59th JUDICIAL DISTRICT CAMERON COUNTY, PENNSYLVANIA STEVEN T. HOFFNIAN Plaintiff, DEBORAH J. HOFFMAN Defendant Civil Action - Divorce NOTICE TO DEFEND AND CLAIM OF 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 fights important to you, including custody or visitation of your children. 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. Office of The Prothonotary East 5* Street Emporium, Pennsylvania 15834 Telephone: (814) 486-3349 .~ of Cameron Co. , ,~, Pro~honotarY NOTICE OF AVAILABILITY OF COUNSELING THE DIVORCE CODE OF PENNSYLVANIA REQUIRES THAT YOU BE NO1 LP'IED OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE IS SOUGHT UNDER ANY OF THE FOLLOWING GROUNDS: 23 Pa.C.S. § 3301(a)(6) 23 Pa.C.S. § 3301(c) 23 Pa.C.S. § 3301(d) - Indignities - Irretrievable Breakdown; Mutual Consent - Irretrievable Breakdown; Two.year separation where the court determines that there is a reasohable prospect of reconciliation A list of mamage counselors is available in the Office of the Prothonotary, Cameron County Courthouse, East 5t~ Street, Emporium, Pennsylvania 15834. Telephone: (814) 486-3349. Lee E. Oesterl~nng, I.D.'~713~0 Attorney for Plaintiff 20 South Market Street Mechanicsburg, PA 17055 (717)790-0490 ~ ~ ~: k,,c rmct uopy ..... mm the ~:,'~'ds of Cameron Co. Law Offices of Hazlett & Oesterling 20 South Market Street Mechanicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS OF THE 59th JUDICIAL DISTRICT CAMERON COUNTY, PENNSYLVANIA STEVEN T. ltOFFMAN : Plaintiff, .~No. 2001 : Civil Action - Divorce DEBORAH J. ttOFFMAN : Defendant : COMPLAINT UNDER SECTION .7 3301(C) OF TI:gE~ DIVORCE CODE ~' ~ Plaintiffis Steven T. Hoffman, an adult individual, ~i juris, with a current mailing address of 111 South George Street, City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, 17055. 2. Defendant is Deborah J. Hoffman, an adult individual, sui juris, who currently resides At 406 South High Street, City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this complaint. 4. The parties were married on the 26~h day of April, 1969, County of Cumberland, Commonwealth of Pennsylvania. 5. Neither Plaintiffnor Defendant is in the military or naval service of the United States or ~,~,~, aha Correct Copy , ;"~i,;d from the ,:,;r~s of Cameron Co. its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 hnd its amendments. 6. There have been no prior actions for divorce or annulment instituted by either of the pa~es m this or any other jurisdiction. 7. For purposes of § 3301(d) of the Divorce Code, the pa~ies have been living separate and apart since on or about January 19, 2001. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff intends to file an affidavit of consent after the expiration of 90 days ~rom the'~lhte of filing and service of the Complaint. Plaintiffbelieves and therefore avers that defendant m~y also t~-]& such an affidavit. COUNT I REQUEST FOR A NO-FA UL T DIVORCE UNDER 3~ 3301 (c) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. The marriage of the parties is irretrievably broken. WltEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to § 3301(c)~ Code. ~ / LdE. Oest~, I.D~ ~ 71 ~i6 / Aaomey for Plaintiff / 20 Sou~ M~ket S~eet / Mec~icsb~g, PA 17055 / (717)790-~, ano Correct Copy ~ '~ :r~k~ from the ,.t- vds of Cameron Co. I verify that upon personal knowledge or information and belief 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 unswom falsification to authorities. Date: /? o( IN THE COURT OF COMMON PLEAS OF THE FIFFY-NINTH JUDICIAL DISTRICT CAMERON COUNTY, PENNSYLVANIA STEVEN T. HOFFMAN Plaintiff, DEBORAH J. HOFFMAN Defendant No. 2001-5529 Civil Term Civil Action - Divorce on AFFIDAVIT OF CONSENT ~ 1. A complaint in divorce under Section 3301 (c) of the Divorce Code w s e August 27. 2001 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety (90) days have elapsed from the date of fling and service of the Complaint. 3. I consent to the entry of a final decree of divorce a.fter 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. I~2BORAH J. HQI~FMAN,/Defendant True and Correct Copy '~i~ed from the 45 of Cameron Co. IN THE COURT OF COMMON PLEAS OF THE FIFTY-NINTH JUDICIAL DISTRICT CAMERON COUNTY, PENNSYLVANIA STEVEN T. HOIfFMAN Plaintiff, DEBORAH J. HOF~MAN Defendant No. 2001-5529 Civil Term Civil Action - Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was d on August 27. 2001 2. The marriage of plaintiff and defendant is irretrievably broken, and n ty ( elapsed from the date of filing and service of the Complaint. day~ have-~2 i-z 3. I consent to the entry of a f'mal decree of divorce after service of notice of intention entry of the decree. to request 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 unswom falsification to authorities. Date: ] STEVEN T. HOFFMAI¢, Plaintiff ~:~d from the ,-,,'~s of Cameron Co. Law Offices of Lee E. Oesterlmg, LLC 42 East Main Street Mechanicsburg, PA 17055 (717) 790-5400 IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA STEVEN T. HOFFMAN Plaintiff, DEBORAH J. HOFFMAN Defendant No. Civil Action - Diw>rce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE iDIVORCE CODE 1. I consent to the 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: STEVEN T. HOFFFMAI~, lqaintiff Law Offices of Lee E. Oesterling, LLC 42 East Main Street Mechanicsburg, PA 17055 (717) 790-5400 IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA STEVEN T. HOFFMAN Plaintiff, Civil Action - Divorce DEBORAH J. HOFFMAN Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the 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 ifI 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. Section 4904 relating to unswom falsification to authorities. Date: D~B~)-~AISI J. HOFF~, 15e~en~o~ -