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Home My WebLink About02-4792 ROBERT F. WAGNER, III, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW ; NO. 2002. 'f"f.l..CIVIL : IN DIVORCE CHARLENE R. WAGNER, 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, 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 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HAVE AN ATTORNEY 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 2 Liberty Avenue Carlisle, PA 17013 Telephone (7'17) 249-3166 ROBERT F. WAGNER, III, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW CHARLENE R. WAGNER, Defendant : NO. 2002 - '17 ~ CIVIL : IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C\ AND 3301(D\ OF THE DIVORCE CODE 1, Plaintiff is Robert F, Wagner, III, an adult individual who resides at 1855 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania 17241, 2, Defendant is Charlene R Wagner, an adult individual who currently resides at P,O Box 32, Cumberland County, Plainfield, Pennsylvania 17081, 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on October 9, 1993 Dauphin County, Pennsylvania 5, The marriage is irretrievably broken, 6, The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in counseling, 7, Plaintiff requests the court to enter a decree of divorce, WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER BY~~ Robert L, O'Brien, Esquire Attorney for Plaintiff 10, # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa, C,S, S 4904, relating to unsworn falsification to authorities, 7Ii Robert F, Date: J/;~/oL ROBERT F. WAGNER, III, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW CHARLENE R. WAGNER, Defendant : NO. 2002. : IN DIVORCE CIVIL ACCEPTANCE OF SERVICE AND NOW, this f(j)-0 day of :)(fJember, 2002, I, Charlene R Wagner, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa, RC,P, 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. fj;~ R. WtJpuA- Charlene R Wagner rlo\Domestic\Wagner'wagner .com ~(\ ~ - J w (\', 0 ...(, - C><) ~ 'V ~ ~ (" . \ C. ~' (') c <'~ ul'-;: O)d t~ f-~ F-~ ~:; - ;:/'-. i~ ~,:,: -.;;- ~ Cl fv o ~-, -1 I (') -n ;] lP-l ~ (~~ ; - :~H . c> ~-)ITI :;! :::.0 -< ~ ,) ::.J,;: ;..;) 'J <n ROBERT F, WAGNER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 2002 - 4792 CIVIL TERM CHARLENE R. WAGNER, Defendant CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1, A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on October 1, 2002, 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint 3, I consent to the entry of a final decree in divorce without notice, 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 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, 6, I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling, I do not request that the court require counseling, 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, Date: /, -, /' '"" -- (. J / rlolDomesticlWagner\consent.aff c-' (o. ROBERT F. WAGNER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 2002 - 4792 CIVIL TERM CHARLENE R. WAGNER, Defendant CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1, A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on October 1, 2002, 2, Defendant acknowledges receipt and accepts service of the Complaint on October 4,2002 3 The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint 4, I consent to the entry of a final decree in divorce without notice, 5, 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 6, 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 7, I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling, I do not request that the court require counseling 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, Date: 1- U -Od- t)lCt~ne1 wa~{lOIAL,,-- ROBERT F. WAGNER, III, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ; NO. 2002 - tl7'1J-cIVIL : IN DIVORCE CHARLENE R. WAGNER, Defendant ACCEPTANCE OF SERVICE AND NOW, this Ljt!J. day of October, 2002, I, Charlene R. Wagner, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa, R.C,P, 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. th!i~ ftU~ Charlene R. Wagner I I I II II rloIDomestic\Wagnerlwagner.com Ii II !I I I ROBERT F. WAGNER, III, Ii 11 Plaintiff I I vs. CHARLENE R. WAGNER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 -4792 CIVIL TERM : 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. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: U.S. Mail on October 4, 2002, 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on January 6, 2003; and Defendant on January 6, 2003. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: NONE. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce Code: None served as the parties signed the Waiver of Notice. (Defendant on January 6, 2003, and Plaintiff on January 6, 2003.). Respectfully submitted, ", ~D() ~ ~'^~ Robert L. O'Brien, Esquire " >...' C (~o r 7' ~~,pyp ~~~) /~?;:::' ~f!7:9>P ~4~ 2v.ht:./ ~.p ~J?"'/-~P '/,,~7 [:/'/lC-/ ; ,