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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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DEBRA A. ROLLINGS,
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Plaintiff
No. 00 - 4740
CIVIL TERM
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VERSUS
RICHARD W. ROLLINGS,
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Defendant
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DECREE IN
DIVORCE
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AND NOW,
NtJV..e.~ 15
c:r ,.~314.~'
2000
, IT IS ORDERED AND
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DEBRA A. ROLLINGS
, PLAINTIFF,
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DECREED THAT
..
AND
RICHARD W. ROLLINGS
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISE:D OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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NONE
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ATTEST:
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DEBRA A. ROLLINGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00 - 4740
CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
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. Grounds for divorce: irretrievable breakdown under
~3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: service
by certified United States mail, return receipt requested,
restricted delivery, on July 7, 2000, as set forth in Affidavit
of Service filed herein.
3. Date of execution of the Affidavit of Consent required
by ~3301(c) of the Divorce Code: by Plaintiff: November 6,
2000; by Defendant: October 31, 2000.
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 a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice was filed with the
Prothonotary: November~, 2000.
LAW OFFICES
MARLIN R. McCALEB I
(c) Date Defendant's Waiver of Notice was filed with the
LAW OFFICES
MARLIN R McCALEB
.
Prothonotary: November /3_, 2000.
Date: November /-1, 2000
-2-
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Marlin R. McCaleb, Esquire
Attorney for Plaintiff
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DEBRA A. ROLLINGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00 - t(1tfO CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - 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.
If the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request that the court require you and your spouse to attend marriage
counseling prior to a divorce decree being handed down by the court. A list of marriage
counselors is available in the Office of the Prothonotary at Cumberland County Court
House, Carlisle. You are advised that this list is kept as a convenience to you and you are
not bound to choose a counselor from the list. All necessary arrangements and the cost of
counseling sessions are to be borne by you and your spouse.
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 WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
~~
LAW OFFICES
MARLIN R. McCALEB
Marlin R. McCaleb
Attorney for Plaintiff
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DEBRA A. ROLLINGS,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 00 - '17?1OCIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR 330l(d)
OF THE DIVORCE CODE
1. Plaintiff is DEBRA A. ROLLINGS, who currently resides at 403 Cherokee Drive,
Mechanicsburg (Hampden Township), Cumberland County, Peunsylvania 17050, since June
17,2000.
2. Defendant is RICHARD W. ROLLINGS, who currently resides at 5009 Muirfield
Place, Mechanicsburg (Hampden Township), Cumberland County, Peunsylvania 17050,
since May 20, 1992.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
4. Plaintiff and Defendant were married on June 20, 1998, in Hampden Towhship,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that Plaintiff may have
LAW OFFICES
MARLIN R. McCALEB
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the right to request that the court require the parties to participate in counseling.
8. Plaintiff requests your Honorable Court to enter a decree of divorce.
I verify that the statements made in this Complaint are tme and correct. 1 understand
that false statements herein are made subject to the penalties of 18 Pa. C.s., Section 4904,
relating to unsworn falsification to authorities.
.~
A. Rollings, Plainti
Date: ~ 2000
.~
Marlin R. McCaleb
Attorney LD. No. 06353
219 East Main Street
P.O. Box 230
Mechanicsburg, Pennsylvania 17055
(717) 691-7770
FAX: (717) 691-7772
Attorney for Plaintiff
LAW OFFICES
MARLIN FL McCALEB
-3-
DEBRA A. ROLLINGS,
Plaintiff
VS.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 00 - <17'10 CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF MARRIAGE COUNSELING
Debra A. Rollings, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I
participate in counseling.
2. I understand that the court maintains a list of marriage counselors in
the Office of the Prothonotary, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my
spouse and I participate in counselling prior to a divorce decree being handed
down by the court.
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.
LAW OFFICES
MARLIN R. McCALEB
Date:~, 2000
Jl 0 NO a -f.u....~
bra A. Rollings, aintiff
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,
DEBRA A. ROLLINGS,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00 - 4740
CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF SERVICE
MARLIN R. McCALEB, Esquire, certifies and says: that he is
the attorney for Debra A. Rollings, the Plaintiff in the
above-captioned action; that on behalf of said Plaintiff, he
did file Plaintiff's Complaint in Divorce in the Office of the
Prothonotary of Cumberland County, Pennsylvania, on July 3,
2000; that pursuant to Rule No. 1930.4{c) of the Pennsylvania
Rules of civil Procedure, he did serve said Complaint upon
Richard W. Rollings, the Defendant herein, by depositing a true
and attested copy of said Complaint, properly endorsed with
Notice to Defend and Claim Rights, in the mail in the post
office at Mechanicsburg, Cumberland County, Pennsylvania, on
July 5, 2000, properly addressed to the said Defendant at his
place of residence at 5009 Muirfield Place, Mechanicsburg, PA
17055, with proper postage attached, certified United States
mail (Receipt No. P 977 270 316, return receipt requested,
restricted delivery); that thereafter he did receive said
return receipt card bearing the signature of Richard W.
LAW OFFICES
MARLIN R. McCALEB
Rollings, Defendant herein, and indicating receipt of said copy
of the Complaint on July 7, 2000; that the said certified mail
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receipt and return receipt card are attached hereto and made a
part hereof, marked Exhibit "A".
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.
Date: July 18, 2000
~.d/
Marlin R. McCaleb
LAW OFFICES
MARLIN R. McCALEB
-2-
LAW OFFICES
MARLIN R. McCALEB
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iTO: P "177270 316
: Richard W. Rollings
i 5009 Mui rfi e 1 d Pl ace
! Mechani cSQurg. PA 17055
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i SENDER:
REFERENCE:
,
: PS FORM 3800 s' PTEMBER 1995
,
Postage
RETURN
RECEIPT
SERVICE
Certified Fee
AeturnReoeiplFee
ReslricledDelivery
Total Postage and Fees
US Postal Service
Receipt for
Certified Mail
i No Insurance Coverage PnMded
i Do not use lor Inl8maltanaI Mall
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Richard W. Rollings
5009 Muirfield Place
Mechanicsburg, PA 17055
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P "177 270316
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EXHIBIT "A"
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DEBRA A. ROLLINGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00 - 4740 CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on July 3, 2000.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date
of filing the Complaint.
3. I consent to the entry of a final 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 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: NINU'"bJlI ("
, 2000
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De ra A. Rolling , Plaintiff
LAW OFFICES
MARLIN R_ McCALEB
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DEBRA A. ROLLINGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00 - 4740 CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
63301 (cl 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 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. Section ~4904,
relating to unsworn falsification to authorities.
Date: IJoVq,mk /.; , 2000
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De ra A. Rollings plaintiff
LAW OFFICES
MARLIN R. McCALEB
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DEBRA A. ROLLINGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00 - 4740 CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on July 3, 2000, and served on me by
certified mail on July 7, 2000.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date
of filing the Complaint.
3. I consent to the entry of a final decree of divorce
after service of notice of intention to request entry of the
decree.
4. I am not a member of the armed forces, nor in active
military service, of the United States of America or the
Commonwealth of Pennsylvania or any other state or country.
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 -J/-oo
, 2000
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Richard W. Rollings,
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Defendant
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DEBRA A. ROLLINGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00 - 4740 CIVIL TERM
RICHARD W. ROLLINGS,
Defendant
CIVIL ACTION - IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
53301 (0) 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 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 lunderstand that false statements herein
are made subject to uhe penalties of 18 Pa. C.S. Section ~4904,
relating to unsworn falsification to authorities.
Date:
/0.,/-00
, 2000
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Defendant
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DEBRA A. ROLLINGS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-4740 CIVIL TERM
:
RICHARD W. ROLLINGS, :
Defendant : IN DIVORCE
NOTICE OF INTENT TO RETAKE PRIOR NAME
Notice is hereby given that DEBRA A. ROLLINGS, the
Plaintiff in the above matter, having been granted the Final
Decree in Divorce on the 15th day of November, 2000, hereby
elects to retake and use her previous name of DEBRA A. BARRY
and gives this written notice avowing her intention in
accordance with the provisions of the Act of December 16, 1982,
54 Pa.C.S., Section 704, as amended.
,hln.q -RrJ1AH1~
Debr~ A. Rollings I
To B~own As:
)""1. ~ /'
Debr A. Barry ~
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
On the 1!/~tday of at/t!!MJ<er ,2000, before me, a
Notary Publ~personally appeared DEBRA A. ROLLINGS, to be
known as DEBRA A. BARRY, known to me to be the person whose
name is subscribed to the within document and acknowledged that
she executed the foregoing for the purpose therein contained.
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IN WITNESS
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Notarial Seal
, Marlin A. McCaleb, Notary Public
! Mechanicsburg Bore, Cumb'i"~,,::"d Gounty
I My Commission Expirf'!:; D&\'; 1,\., 2002
'ti13mber, Pennsylvania ,t\.S;:-C'(;;;~li.~~Gtaries
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Ma~;!n ~i "lit 'l:G'li, .-.jotary Public
Mec<-"- ,~:,,\: 'ir, GL:O, Cumberland County
My". , , ':;''-nit.~s Dec. 14,2002
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LAW OFFIEES",' . ",' ,
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