HomeMy WebLinkAbout02-5079
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CHRISTOPHER M. RODITES,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 2002- S079
CIVIL TERM
CHRISTINA M. RODITES,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
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, Pennsylvania 17013
Telephone (717) 249-3166
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CHRISTOPHER M. RODITES,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 2002- S07r
CIVIL ACTION-LAW
IN DIVORCE
CIVIL TERM
CHRISTINA M. RODITES,
Defendant
COMPLAINT UNDER SECTIONS 3301(C)
AND 3301/D) OF THE DIVORCE CODE
1. Plaintiff is Christopher M. Rodites. an adult individual who currently resides at
310 Peach Glen Road, Gardners, Cumberland County, Pennsylvania
2. Defendant is Christina M. Rodites, an adult individual who currently resides at
36 Subdivision Road, Newville, Cumberland County, Pennsylvania
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 July 14, 2000. in Cumberland
County, Pennsylvania
5. There have been no prior actions of divorce or for annulment between the
parties
6. The marriage is irretrievably broken.
7. 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
8. Plaintiff requests the court to enter a decree of divorce
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WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of
the Plaintiff and against the Defendant
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Respectfully submitted.
O'BRIEN, BARIC & SCHERER
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Michael A Scherer. Esquire
1.0.# 61974
17 West South Street
Carlisle. PA 17013
(717) 249-6873
Attorney for Plaintiff
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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.
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Christopher M. Rodites
Date: /(;- 1$ - Of)
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CHRISTOPHER M. RODITES,
Plaintiff
vs.
CHRISTINA M. RODITES,
Defendant
AND NOW, this ;23
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002 - 5079
CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
day of October, 2002, I, Christina M. Rodites, Defendant
above, hereby accept service of the Complaint filed in the above case pursuant to Pa. RCP
1920.4(d) and acknowledge receipt of a true and attested copy of said Complaint
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CHRISTOPHER M. RODITES,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5079 CIVIL TERM
CHRISTINA M. RODITES,
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 18, 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:
/0~o-?
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Christopher M. Rodites
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CHRISTOPHER M. RODITES,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5079 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
CHRISTINA M. RODITES,
Defendant
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 18, 2002.
2. Defendant acknowledges receipt and accepts service of the Complaint on
October 23, 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: / Ij 15;/1)3
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Chrisfina M. Rodites
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CHRISTOPHER M. RODITES,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5079 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
CHRISTINA M. RODITES,
Defendant
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: Defendant signed an
Acceptance Of Service form on October 23, 2002.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required under Section 3301 (c)
of the divorce code: by the plaintiff November 12. 2003
by the defendant November 15. 2003
(b) (1)
of the divorce code
(2)
Date of execution of the plaintiff's affidavit required by Section 3301 (d)
N/A
Date of service of the plaintiff's affidavit upon the defendant
N/A
4.
Related claims pending
NONE
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file praecipe
to transmit record, a copy of which is attached: N/A
(b) Date plaintiff's waiver of notice in Section 3301(c) divorce was filed
with the Prothonotary: November 19. 2003
Date defendant's waiver of notice in Section 3301 (c) divorce was filed
with the Prothonotary: November 19. 2003
1tJiA~
Mfchael A. Scherer, Esquire
Attorney for Plaintiff, Christopher M. Rodites
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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RODITES,
STATE OF
PENNA.
CHRISTOPHER M.
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Plaintiff
No.
2002-5079
CIVIL
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VERSUS
+
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CHRISTINA M.
RODITES,
.
Defendant
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DECREE IN
DIVORCE
,;:r 10: '13A.,vt ~
d- ell .3
AND NOW,
tJ~ ;;,
IT IS ORDERED AND
DECREED THAT
CHRISTOPHER M.
RODITES
, PLAI NTI FF,
AND
CHRISTINA M.
, DEFENDANT,
RODITES
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOW,ING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
)
B
J.
PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
C~"\<\-<>I>h~ W\, t.cd.&es
Plaintiff
Vs
File No. 2002.- ~ 07"1
IN DIVORCE
Cl.,i\&\';^k M- ?.cdil:~S
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
or ~ after the entry of a Final Decree in Divorce dated
hereby elects to resume the prior surname of C r..", ~.<d.
written not}ce avowing his /@intention pursu
Date: ~/'/h/()r
1I}a..,,/1oo3 ,
.
C~~/)/~~::/L
Signature of ame being res med
COMMONWE,M-TH OF PENNSYL VANIA )
COUNTY OF~~.D )
On the -It!!!- day of AlI~u~ , 200.2, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
fil~
rothonotary or Notary Public
NOTARIAl SEAL
PROlHONOTARY, NOTARY PUBLIC
CUMIlERlAHO COUNTY COURT HOUSE
",., COMMISSION EXPIRES JANUARY 2, 2006
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