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Home My WebLink About03-0149 SAMANTHA ROHRER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO: 03- 1 49 CIVIL TERM JASON E, ROHRER, : CIVIL ACTION - LAW Defendant. : 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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, Cumberland County Courthouse, Carlisle, 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 TIllS 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, P A 17013 (717) 249-3166 SAMANTHA ROHRER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO: OJ -/49 Cio'L ~€A-"1. 3iso~ JAMES E, ROHRER, : CIVIL ACTION - LAW : IN DIVORCE Defendant. COMPI,AlNT IN DIVORCE AND NOW, comes the Plaintiff, Samantha Rohrer, by and through her attorneys, Mancke, Wagner, Tully & Spreha, and files the following Complaint in Divorce: 1. The Plaintiff, Samantha Rohrer, is an adult individual currently residing at 1502 Hemlock Avenue, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Jason E. Rohrer, is an adult individual currently residing at 34 S. Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on April 14, 1999, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that she has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based are: A. That the marriage is irretrievably broken pursuant to ~3301(c) of the Divorce Code; and B. That as of August 13,2004, the parties will have lived separate and apart for a period of at least two (2) continuous years pursuant to ~3301(d) of the Divorce Code. -2- WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, r, Tully & Spreha ''') ---- /' . :~.hari:rWagner, Esquire ",I:U'- #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorneys for Plaintiff Date: //3/C!..3 I I -3- VERIFICATION I verify that the statements made in the foregoing document 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. x ( .~~~~. (Lc V\ r( ~ 1)-dl-02r DATE: ):)D'o. 1!-~~ o ..' ~ --l CI) ~ ~ 0 ~~~ Y- ! \.i.-: _.- _.. -.i/ -<. r '~) ... € CASE NO: 2003-00149 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERIFF'S RETURN - NOT FOUND ROHRER SAMANTHA VS ROHRER JASON E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being inquiry for the within named defendant, DEFENDANT duly Sworn according to law, says, that he made a diligent search and ROHRER JASON E COMPLAINT - DIVORCE unable to locate Him in his bailiwick. He therefore returns the but was the within named DEFENDANT , NOT FOUND , as to , ROHRER JASON E PAPER EXPIRED. UNABLE TO SERVE ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 8.28 5.00 10.00 .00 41.28 R. Thomas Kline Sheriff of Cumberland County MANCKE WAGNER TULLY SPREHA 03/12/2003 Sworn and subscribed to before me day of J1lt~ this sAMANTHA ROHRER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PlaintiH: : NO: 03-149 CIVIL TERM v. : CIVIL ACTION - LAW JASON E. ROHRER, : IN DIVORCE Defendant. PRAECIPE TO THE PROTHONOTARY: Please reinstate the Complaint against the Defendant in the above-captioned matter. Respectfully submitted, er, Tully & Spreha . chard Wagner, Esquire 1.0. #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorneys for Plaintiff Date: ..jjtAJ/03 f I (') c <- ""Oc=; rnni 2:r:? i5j'S: ::2": ;r~ r~' ? " ~C'; ...,c_ -;.;. ~1 -< o w :11: ::r.:s ;:0 N (XI o -n :..-:j f+i;1J 'T.ill :~;? ::C) p':-jl ~'?B ;':~rn ::=:'1 ?o -< :~ ...Ji... ~ (fl SHERIFF'S RETURN - REGULAR CASE NO: 2003-00149 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROHRER SAMANTHA VS ROHRER JASON E JASON VIORAL / Sheriff or Deputy Sheriff of Cumberland County/Pennsylvania, who being duly sworn according to law, says/ the within COMPLAINT - DIVORCE/ AMEN was served upon ROHRER JASON E the DEFENDANT / at 1834:00 HOURS/ on the 4th day of April / 2003 at 34 S MIDDLESEX ROAD CARLISLE/ PA by handing to JASON ROHRER a true and attested copy of COMPLAINT - DIVORCE, AMEN together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31.45 .-r~":""':'~,"~1/"~~ R. Thomas Kline 04/07/2003 MANCKE WAGNER TULLY SPREHA Sworn and Subscribed to before tl- me this In ~ day of Dt~ ~U0-..3 A. D . ("l vfA- t1 ~ A~ ~~othonotary ,'-r-' By: ~ ty Sheriff SAMANTHA ROHRER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. NOTICE TO 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 Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAV.1T UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. The parties to this action separated August 13, 2002, and have continued to live separate and apart for a period of at least two (2) continuous 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 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 P C.S. Section 4904 relating to unsworn falsification to author ti s. fgJir Rohrer DATE: Cj-3-f)Lf '. SAMANTHA ROHRER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i) or (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): ( ) (a) 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 in the Notice of Intention to Request a Decree in Divorce, a Decree in Divorce may be entered without further notice to me and I should be unable thereafter to file any economic claims. 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. Section 4904 relating to unsworn falsification to authorities. Jason E. Rohrer DATE: SAMANTHA ROHRER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO: 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that the PLAIN'l'IFF in the above matter, having been granted a final Decree in Divorce on the JLti:: day of j{)u.(/nJ-/A.../ , 2001f, hereby i.ntends to resume and hereafter use the previous name of SAMANTHF. ZAENGLE and gives this written notice avowing her intention i.n accordance with the provisions of the Act of April 2, 1980, P.I.., 23 P.S. Section 702 (effective July 1, 1980). ~'-'\ (~ "{lJ\\Ll \\k~4 rlC~rCr Samantha Rohrer TO BE KNOWN AS: ,..--, If. c=t \... -, 'J ()ClJ\ Q V \ LD\ 'jAQ/1--,(:"t(--t Samantha Zaengle ,~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cl.A~ ~\~01. SS. ON THE ,~~Y'd day of ~ ' 20"3 before me, a Notary Public, personally a~ear Samantha Zaengle, 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. IN WITNESS WHEREOF, I have hereunto set my hand and seal. NOTARIAL SEAL CHERYL D. SMITH, Notary Public Mt. Holly Springs Borough, Cumberland Co, My Commission Expires Feb. 18, 2006 ~lJ dn,l;;;' Nota.ry Publ1.c 1- ............ ~ \) ~ \ w - ~ ~ ~ () o it! ~ 7- ~ ::.~ ::-.~ ---:-~ ..' i __.; ...~ ~~~ ('- }~F; L - .J -< (') ~; ;i';"~ ':::<n 1'0) <:::) ~ CJ't c... ",.. Z I W o 11 :e-n ii1r= ~9 --19 _L. -H I.':;~o om --I p ~~ -0 :J.:.: r;:> .c- c.n SAMANTHA ROHRER, IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLV IA Plaintiff, v. NO. 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TO: Mr. Jason E. Rohrer 478 N. Mountain Road Newville, PA 17241 YOU HAVE BEEN SUED IN an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 53301 (d) affidavit. Therefore, on or after ,At:""",,,},,, J 1,7,tk>"1 , the Plaintiff can request the court to enter a final decree i divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter affidavit by the above date, the court can enter a final decr e in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the abov date or the court may grant the divorce and you will lose for ver the right to ask for economic relief. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HE A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONO OF THE COURT IS ATTACHED TO THIS NOTICE. Y COURT ADMINISTRATOR 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 . ~-'- SAMANTHA ROHRER, IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLV IA Plaintiff, v. NO. 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in t is Affidavit, you must file a Counter-Affidavit within twenty (2 ) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated August 13, 2002 and have continued to live separate and apart for a period of at least two (2) continuous years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimo y, division of property, lawyer's fees or expenses if I do not c aim them before a divorce is granted. I verify that the statements made in this Affidavit are t ue and correct. I understand that false statements herein are m e subject to the penalties of 18 P C.S. Section 4904 relating t un,wocn fal,ifioation to authoc tiO~ ~~~ ntha Rohrer DATE: 9-30(/ SAMANTHA ROHRER, IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLV IA Plaintiff, v. NO. 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. Check either ~a) (a) or (b): I do not oppose the entry of a divorce decree. () (b) I oppose the entry of a divorce decree because (Check (i) or (ii), or both): () (i) The parties to this action have not lived sepa ate and apart for a period of at least two years. () (ii) The marriage is not irretrievably broken. 2. Check either (~a) (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, lawye 's fees or expenses if I do not claim them before divorce is granted. ( ) (b) I wish to claim economic relief which may inclu e alimony, division of property, lawyer's fees or expenses or other important rights. , ... . I understand that in addition to checking (B) above, I ust also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do 0 before the date set forth in the Notice of Intention to Requ st a Decree in Divorce, a Decree in Divorce may be entered wi thou further notice to me and I should be unable thereafter to fi e any economic claims. I verify that the statements made in this Counter-Affid it are true and correct. I understand that false statements he in are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: ?-;:?c:;J-cJt!/ , " , " :-' ~n ,.\ 0-) ~--- ,;.1 -------- , SAMANTHA ROHRER, IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLV IA Plaintiff, v. NO. 03-149 CIVIL TERM CIVIL ACTION - LAW JASON E. ROHRER, IN DIVORCE Defendant. NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in t is Affidavit, you must file a Counter-Affidavit within twenty (2 ) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. The parties to this action separated August 13, 2002, and have continued to live separate and apart for a period of at least two (2) continuous years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimo division of property, lawyer's fees or expenses if I do not cl im them before a divorce is granted. I verify that the statements made in this Affidavit are t and correct. I understand that false statements herein are ma subject to the penalties of 18 P C.S. Section 4904 relating t unsworn falsification to author ties. ue e &1<< Rohrer MTE: 9~q SHERIFF'S RETURN - REGULAR CASE NO: 2003-00149. . COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROHRER SAMANTHA VS ROHRER JASON E JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE, AMEN was served upon ROHRER JASON E t e DEFENDANT , at 1834:00 HOURS, on the 4th day of April , 2003 - - at 34 S MIDDLESEX ROAD CARLISLE, PA by handing to JASON ROHRER a true and attested copy of COMPLAINT - DIVORCE, AMEN together with . and at the same time directing His attention to the contents th I=reof, - Sheriff's Costs: So Answers: Docketing 18.00 C ?,; . Service 3,45 ...#" ,.t..~-::'~ ,.-;;$" ,.." ,;---:-' Affidavit ,00 4 ,....~~:.;~.",:,'<,' < Surcharge 10,00 R, Thomas Kline .00 31.45 04/07/2003 MANCKE WAGNER TULLY SPREHA Sworn and Subscribed to before By: ~ a-L me this day of 7jty Sheriff A,D, I / V Prothonotary r SHERIFF'S RETURN - NOT CASE NO: 2003-00149_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FOUND . ROHRER SAMANTHA VS ROHRER JASON E R. Thomas Kline ,Sheriff or Deputy Sheriff, who eing kC'~,~\c?J duly sworn according to law, says, that he made a diligent sear hand inquiry for the within named defendant, DEFENDANT ROHRER JASON E unable to locate Him in his bailiwick, He therefore returns t e COMPLAINT - DIVORCE b twas , NOT FOUND , as to the within named DEFENDANT , ROHRER JASON E PAPER EXPIRED: UNABLE TO SERVE ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff1s Costs: Docketing Service Not Found Surcharge / ./ So answ~./-r) /:->// // ~~~. R. Thomas Kline Sheriff of Cumberland County 18.00 8.28 5.00 10,00 .00 41.28 MANCKE WAGNER TULLY SPREHA 03/12/2003 Sworn and subscribed to before me this day of /I,D, Prothonotary SAMANTHA ROHRER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V A Plaintiff, v, : NO: 2003-149 - CIVIL TERM : CIVIL ACTION - LAW JASON E. ROHRER, : IN DIVORCE Defendant. PRAECIPE TO TRANSMIT THE 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) , 330 I (d) of the Divo ce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: April 4, 2003, by Sheriff's service. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) 0 the Divorce Code: By Plaintiff: By Defendant: (b) (I) Date of Execution of the Plaintiff's Affidavit required Section 330 I ( ) of the Divorce Code: September 3, 2004 (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 09117 4 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Tnm mit the Record, and attach a copy of said Notice under Section 3301(d) (I)(i) of e Divorce Code: I III II04 by first class mail, postage pre-paid. (b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: ,p,1~er, E~. Attorney for Plaintiff :t; ~+; ~:f.:f. +.;f.:+: :+::ti:+::ti'f.;!i:+:;+;;!i +' 'f'" 'f +.:+::+: +.:+: 'f. +.;+::+: :+:;f :+: + + "':+:+ "" '" +;.., ~ +.;+. +.:f. +. +. . IN THE COURT OF COMMON PLEA +. 'f +. +. +. '+' +. +. +'f, + . . + . . . . . . . . . . . . . . . + . . . . . . . . . . . . . . SAMANTHA ROHRER VERSUS JASON E, ROHRER . . . . . . . . . . . . . . . . ...,.----- AND NOW, DECREED THAT . . . . . . . . . . . . . . . . . . . AND OF CUMBERLAND COUNTY STATE OF PENNA, No. 2003-149 CIVIL DECREE IN DIVORCE -D~1 t L\ SAMANTHA ROHRER :~"", IT IS ORDERED AND , PLAINTIFF, JASON E, ROHRER , DEFENDANT ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... NONE / ,/, ;/ ". By THE COURT: \ / / I' ATTESa .,,~~ " "-'--- ) PROTHONOT RY :+:+.+.'+''f'+'+'f+++.+'+'+.'+''l'++.+,+, '1'+++.++++ + +' 'l' + +. + ++.++++'+''1'+''+'1'+ . . . . . . . + . . . . + . + . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . . . . . . . . + . . . + + . . + . + . . . . + . + . . . . . . + . . +. '+' + + +. ++. J. . ~ f. ?'1'",u '71Jd1t, ;,a IT. ,,' ~ Jt'" 1 ~ &/al p{l ;,~. tt' eJ .. .. ~., .. ' ~ .--