HomeMy WebLinkAbout03-0013F:\FILES\DATAFiLE\Gendoc cur/9888-2 com 1/ajt
Created 12/17/02 12:15:06 PM
Revised 12/17/02 I2:30 17 PM
9888.2
KETHA M. RANCK,
Plaintiff
V.
PAUL R. RANCK,
Defendant
1N THE COURT OF COMMON PLEASE
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- /.3 ~-zk;d ~z~
CWIL 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 at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pa. 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
desire to pursue counseling, you must make your request for counseling within twenty (20) days of
the date on which you receive this notice. Failure to do so will constitute a waiver of your right to
request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
KETHA M. RANCK,
Plaintiff
PAUL R. RANCK,
Defendant
IN THE COURT OF COMMON PLEASE
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-
CIVIL ACTION-LAW
: IN DIVORCE
COMPLAINT
17013.
2.
PA 17013.
3.
Plaintiff is Ketha M. Ranck, who currently resides at 126 Beech Street, Carlisle, PA
Defendant is Paul R. Ranck, who currently resides at 349 Fourth Avenue, Carlisle,
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 Plaintiffand Defendant were married on May 27, 1992, in Cumberland County,
Pennsylvania.
5.
6.
7.
There have been no prior actions of divorce or for annulment between the parties.
The marriage is irretrievably broken.
Plaintiff has been advised that counseling is available and that Plaintiff may have the
fight to request that the court require the parties to participate in counseling.
8. Plaintiffrequests the Court to enter a decree of divorce.
Date: /2./~//0 2..-
MARTSON DEARDORFF WILLIAMS & OTTO
Thomas J. Wi/[liKens, Esquire
I. D. No. 175~
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by my counsel in
the preparation of the lawsuit. The language of the document is that of counsel and not my own.
I have read the Complaint and to the extent that the document is based upon information which I
have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content of the document is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
Ketha ~. Ranck~
~(ETHA M. RANCK,
Plaintiff
V.
PAUL R. RANCK, :
Defendant :
:
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 03-13 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
PRAECIPE
To the Prothonotary:
DATE:
Please enter my appearance in the above-captioned matter
on behalf of the Defendant.~tr off
At tiff
cc: Thomas J. Williams, Esquire
F:\FILES\DATAFILE\Gendoc.cur\9888-2.affl/cny
Created: 1/15/03 8:39:15 AM
Revised: l/15/03 8:49:12 AM
9888.2
KETHA M. RANCK,
Plaintiff
V.
PAUL R. RANCK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
NO. 03-13
CIVIL ACTION-LAW
:
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
· SS.
COUNTY OF CUMBERLAND )
I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Paul R.
Ranck at 349 Fourth Avenue, Carlisle, PA 17013 on January 3, 2003, by certified mail, restricted
delivery, return receipt requested.
Attached is the Post Office return receipt signed "Paul Ranck" and dated January 6, 2003·
Thomas J. Willie, Esquire
Sworn to and subscribed
before me this 15th day of January, 2003.
'~Notary Public
NOTARIAL SEAL I
TRICIA D. E~KENROAD, Notary Public
Carlisle P,,m Cumberland County
_My. Comn ~,..~ion Ex~ires Oct. 23. 2004
· 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 we 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:
C. Date
YES, enter delivery address below:
1 3; Service Type
Certified Mail [] Express Mail
[] Registered [] Return Receipt for Merchandise
[] Insured Mail [] C.O.D.
4. Restricted Deliver? (Extra Fee) J~yes
2. Al
PS F
102595-02-M-0835
I1-1
1::3
Postage
Certified Fee
~ Return Receipt Fee
ru (Endorsement Required)
r"l Restricted Deliver~ Fee
I--1 (Endorsement Required)
I""t Total Postage & Fees