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Home My WebLink About07-0717IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff v. No. 2007 - ~`~ C 1 v cC,~~1L''~'1 Janice Rogers, . Defendant : In Divorce a v.m. 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 First Floor, Franklin County Court House, 157 Lincoln Way East, Chambersburg, Pennsylvania. 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff v. No. 2007 - `~~ l..LUi~, ~ L Janice Rogers, . Defendant : In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) or 3301 ~) OF THE DIVORCE CODE NOW comes the Plaintiff and for cause of action against the Defendant says: 1. Plaintiff is Jeremy Rogers, who currently resides in Cumberland County, Pennsylvania with a mailing address of 885 Greenspring Road, Newville, PA 17241 since August 2006. 2. Defendant is Janice Rogers, who currently resides in Bergen County, New Jersey with a mailing address of 10 Schuyler Court, Kearny, New Jersey 07032 since approximately 2003. 3. Plaintiff and defendant have been bona fide residents of 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 September 26, 2001, at Fayetteville, Franklin County, North Carolina. 5. There have been no prior actions of divorce or for annulment of marriage between the parties in this or in any other jurisdiction. 6. The marriage is irretrievably broken and the parties have lived separate and apart for a period of at least two years. ~. Plaintiff has been advised of the availability of counseling and that Plaintiff 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. c Barbara B. Townsend Attorney for Plaintiff I hereby verify that the facts set forth in the foregoing instrument are true and correct to the best of my knowledge, information and belief, and that I make this verification subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to Authority, as authorized by the Judicial Code and Pennsylvania Rules of Civil Procedure. Date: 02- c__~ ~.... ~ C .~.,,~ t ""T"1 W 1 ~, N ~"r'} C~7 ` ~ ri C c., '~, - ;. `_y ~= `_ .. _ - c.~~ -~ .~ _.._ ~J r-_ "' ~- C_.7 o 'Z'~ --j i - -,J ~'Y'~ C a '~ T '1"t ' .+7 r= - - ; :-i~ G~ rJ ~.,~ ;`) ` _ • . _~ _.~ . _ ~ .,~ ' ~Tl ,r', ~J f - ' f ~? .,. "'~ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff Janice Rogers, v. No. 2007 - ! ~ ~ 1. l V ~~ `~ Defendant In Divorce a v.m. NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this aflidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated not later than November 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I understand that the statements made in this aflidavit 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: ~ e IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff v. No. 2007 - 717 Civil Term Janice Rogers, Defendant : In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN SS Barbara B. Townsend, Esquire, being duly sworn according to law, deposes and says that she served a copy of the Notice of Intention to Request Entry of Divorce Decree upon the Defendant by mailing the same to Janice Rogers at her last known address of 10 Schuyler Court, Kearny, New Jersey 07032, by regular mail on March 22, 2007, from the United States Post Office in Chambersburg, Pennsylvania. arbara .Tow send Sworn an~subscribed to before me this ~ day of q rc , 2007 ~ ~ ~~~,~ Notary Public e~t.,, ~s _ f~ ~~ ~ ~ ~ _7 ~-, _ ~ r ~.~ ~ L.*3 ~ P ~ N ,-C .~'" ,TH ~ICIAL pISTgIGT ON p~S OF THE 9 D COUNTY GOUR•r Og GO ~ ~~ Gi3MB'E~'~ IN THE OF pENNS c tion -Law Civil A ; Jeremy r{Ogers, Plaintiff _ 717 Civil Term ~° 2007 v. ivorce a v•m. In D~ o ers, Defendant ' y~GE ~anice R g DAFT OF SER AFFI TATE OF pE~gYLV~~ : SS sand says depose S N to law, davit COUNTY OF ~N~ sworn aGCOrd'ng d Plaintiff s Aff being duly Divorce an uire, of the CiOmplaint in at her last known Townsend' Esq ~anice Ro~e~' mail, restricted Barbara B• e and correct copDivorce Gode tO b certified ostage 33p1~d) of the ersey 07032, Y t attached heret°, P that she s~ tSec on gearny, New 1010, receip bersburg, required Y ler Court, 3400 0017 6225 ffice at C,ham 10 Schuy No. 7099 United States;'°st 4 j address of onl , from the ~I7~*" delivery, addressee $ ~ 2007 , ~ ; prepaid on February ~,'' 1 Pennsylvania. d Towns t ( f -{ c„~--~ 'l ~,~,otary public,,, t _ ,ti~xa~, t,~~~~'dT`i -~~F ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that =ve can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ,, -~ `r'{(~1.~"/C C ,~ ~~~>: X25 i %`~ ~L /-/ 1 CL~2iv/ /~ z rlC. tiJ~ A. gnature X ^ Agent ~, J ^ Addressee eceived by j Prinfed Name C. Date of Delivery D. Is delivery ad y` ~~rent from item 1? ^ Yes If YES, et i e below: ^ No O i L3i ~j\ w N 3. S ice f~0ertified P xpress Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number ~j (Transfer from service label) ! ~~`! ! s")~~ t~~ ~ ~ ~n ,~ r~ ?S ~ ~) PS Form 3811, February 2004 Dorrteatic Return Receipt tozsss-oz-M-isao 0 O r~ ~ Postage $ 1 2 ~ ~.J ~ Certified Fee ~~ '`/'y((/~~ 4 "' Postmark ~ Return Receipt Fee / ,_ ~ (Endorsement Required) Here ~, ~ Restricted Delivery Fee ~~~^^^777 ,'„ ~~'r O (Endorsement Required) ~~ ~11`~) ..4. O ~,, 0 ~ Total Postage & Fees $ y (l ~lt\ ~ Recip/ent's Name U y LS 1~'1 ase Print C/ear! ~~ be completed by mailer] -------------------- --AIL/ /C ~:: ~''C~~(~E,~S , Q- Street, Apt. N~~r PO~x No. ----- -------------- --- ~- G+~L~/LL!!~- - ------°------------ - ------ c~I:-J" ~ City-State, ZlP~ ----------- ------ -- I'~ - -----------~----- f /Z/~ l~ 7Gt3 ~. i . a -_ , ~ ~ ii t"t' . ~ -i d' . ~ ;-~ ~ ~ -.1. f . t ~f f~i ~_~ r ~ } f; "7' i , ~n .. ~~. ---- :I3 f~3 •{ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff Janice Rogers, v. No. 2007 - 717 Civil Term Defendant : In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE To: Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter affidavit to the 3301(d) affidavit. Therefore, on or after April 11, 2007, the other party can request the Court to enter a final decree in divorce. If you do not file with the prothonotary of the Court an Answer with your signature notarized or verified or a counter affdavit by the above date, the Court can enter a final decree in divorce. A counter affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YUU 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 e~.s ~~ i ~ T- -_.a , t=; ~~ _ {-3 _ . ~~ .. C'"? cn ~~ ~a ~-~ 1 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff v. No. 2007 - 717 Civil Term Janice Rogers, Defendant : In Divorce a v.m. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d~ OF THE DIVORCE CODE 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. I oppose the entry of a divorce decree because Check (i), (ii), or both: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ~ I do not wish to make any claims for economic relief. 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. ~b~ I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. r~~ I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ss4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. ~--~ O ~.:., c-_ .._, oY~ ~~ ;_,> ._-- ._ !,'= -~ ~ e ~`;~ s IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff Janice Rogers, v. No. 2007 - 717 Civil Term Defendant : In Di•:orcc a v.m. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit to record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Complaint was mailed to the defendant on February 8, 2007, by certified mail, restricted delivery. Defendant accepted service of the complaint on February 22, 2007. 3. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code: February 2, 2007; (2) Date of filing and service of the plaintiffs affidavit upon the respondent: Plaintiff's affidavit was filed on February 6, 2007. Plaintiff's affidavit was mailed to the defendant by certified mail, restricted delivery. Defendant accepted service of the complaint on February 22, 2007. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Notice of Intention mailed to the defendant by regular mail on March 22, 2007. O Barbara B. T wnsend Attorney for Plaintiff 4~ ~, --.~.1 ~ ""S ~1 - c_i - ~.,,? K..S ~T ,.-.. -t3~:~ . , ~, ~:~ _: ~~- r it ~ , S ' 1.~ G.l • ~~' IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA -CUMBERLAND COUNTY Jeremy Rogers, Civil Action -Law Plaintiff v. No. 2007 - ~ I-l Janice Rogers, Defendant In Divorce a v.m. AFFIDAVIT OF NON-MILITARY SERVICE Plaintiff avers that the Janice Rogers, Defendant, is not now and has not been since the commencement of this action in military service of any branch of the United States or any political subdivision thereof. re I verify that the statements made in this Affidavit of Non-Military Service 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 perjury contained in 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: '~l~" 13- b~ r-~ ~~ ~ ~= -ri ~ ' ~ ' - ~ - ,. ~r,-, .~: I t _ ~ ,y ~ I N THE COURT' OF COMMON PLEAS G}F CUMBERLAND COUNTY ,:¢, . =+~ PENNA. STP.~t E O F ~; ~~~~~, ~~-~ ,, JEREMY ROGERS No. Zoos _ >» VERSUS JANICE ROGERS DECREE IN DIVORCE Z ~ ~OO~, IT IS ORDERED AND AND NOW, DECREED THAT JEREMY ROGERS __, PLAINTIFF, AND JANICE ROGERS ^_, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAfNS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAfSED OF RECORD IN THIS ACTION 1='OR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE BY THE COURT: ~~ ~, ATTEST : ~ '~ ' ~ PROTI-iONOTARY ~~.. -<~'~'' ~~