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Home My WebLink About03-0907CARRIE U. SOLLENBERGER, Plaintiff JOHN R. SOLLENBERGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. O 3 '~ ~o'p CIVIL TERM · IN LAW - 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 relief requested in these papers by the Plaintiff. You may loose money or property or other rights important to you, including custody or visitation of your children. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is a',ailable in the Office of the Prothonotary, First Floor, Cumberland County Courthouse, 1 Courthouse Square, 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 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 CARRIE U. SOLLENBERGER, Plaintiff Vo JOHN R. SOLLENBERGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO.O3 ~ qo? CIVIL TERM · IN LAW - DIVORCE COMPLAINT IN DIVORCE AND NOW COMES counsel, William L. Gmbb, SOLLENBERGER, as follows: the Plaimiff, CARRIE U. SOLLENBERGER, by her Esquire, and complains of the Defendant, JOHN R. COUNT I COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is CARR/E U. SOLLENBERGER, who currently resides at 2208 Orchard Road, Lower Allen Township, Cumberland County, Pennsylvania. 2. Defendant is JOHN R. SOLLENBERGER, who currently resides at 2208 Orchard Road, Lower Allen Township, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 7, 2001, at Mechanicsburg, Cumberland County, Pennsylvania. o parties. There have been no prior actions of divorce or for annulment between the 6. Neither party is in the Armed Services of the United States or its allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the marriage between the parties. Respectfully submitted, Date: William L. Gmbb, Esquir~''~' I.D. # 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 Attorney for Plaintiff VERIFICATION I, CARRIE U. SOLLENBERGER, verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: Carrie U. Sollenberger, Plai~t~ff, d CERTIFICATE OF SERVICE I, WILLIAM L. GRUBB, Esquire, certify that I have served a copy of the foregoing document on the individual listed below by depositing the same in the United States Mail, Certified, First Class, restricted delivery, postage prepaid, at Camp Hill, Pennsylvania: John R. Sollenberger 2208 Orchard Road Camp Hill, PA 17011 William L. Grubb, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 CARRIE U. SOLLENBERGER, Plaintiff JOHN R. SOLLENBERGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA :NO. Ob'-"c~o'/ CIVIL TERM · IN LAW - DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING CARRIE U. SOLLENBERGER, being duly sworn according to law, deposes and says: 1. 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 counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Carrie U. Sollenberger, Plaintiff CARRIE U. SOLLENBERGER, Plaintiff JOHN R. SOLLENBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03 - 907 CIVIL TERM : IN LAW- DIVORCE PROOF OF SERVICE BY MAIL I hereby certify that a true and correct copy of the Complaint in Divorce filed in the above matter, was served on John R. Sollenberger by first class, certified mail, return receipt requested, deliver to addressee only, at 2208 Orchard Road, Camp Hill, PA 17011, on February 28, 2003. Addressee acknowledged receipt of the same on March 3, 2003, as shown by the return receipt card attached hereto as Exhibit "A". I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. ~ 4904, r~lating to unsworn falsification to authorities. Date: .~. ./~ % ~ ~ 0'~-~"--/~, ~? , William L. Grubb, Esquire I.D. 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 · 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: A. Received b' C. Signature ' address different f~ If YES, enter delivery address 3. Service Type ~ Certified Mall I"1 Express Mail r-I Registered ~- Return Receipt for Memhandiee [] Insured Mail I-I C.O.D. 4. P,e~n~ed De,lely? (Extra Fee) ~ff~ Yes 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 Exhibit "A" CARRIE U. SOLLENBERGER, Plaintiff JOHN R. SOLLENBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03 - 907 CIVIL TERM : 1N LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 28, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: NBER~R, Plaintiff CARRIE U. SOLLENBERGER, Plaintiff V. JOHN R. SOLLENBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03 - 907 CIVIL TERM : IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 28, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety {90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a after service of notice of intention decree. final Decree in Divorce to request entry of the I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: ~ Defendant CARRIE U. SOLLENBERGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 907 CIVIL TERM JOHN R. SOLLENBERGER, Defendant IN LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST DIVORCE DECREE UNDER 3301(c) 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. §4904 relating to unsworn falsification to authorities. Dated: JTN R. SOLLENBERGEi~, Defendant CARRIE U. SOLLENBERGER, Plaimiff V. JOHN R. SOLLENBERGER, De~ndam : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03 - 907 CIVIL TERM : IN LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST DIVORCE DECREE UNDER 3301(c) 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: -CARRIE U. SOLLENBERGER~, Plaintiff CARRIE U. SOLLENBERGER, Plaintiff JOHN R. SOLLENBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03 - 907 C1VIL TERM : IN LAW - DIVORCE 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 §3301(c)of the Divorce Code. Date and manner of service of the complaint: 03/03/2003, US mail, certified, restricted delivery return receipt, postage prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff June 10, 2003, by Defendant June 4, 2003. Related claims pending: NONE Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit the record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice in §3301(c) was filed with the Prothonotary: June 19, 2003. Date defendant's Waiver o£Notice in §3301(c) was filed with the Prothonotary: June 19, 2003. William L. Grubb, Esq. Attorney for the Plaintiff Carrie U. Sollenberger, IN THE COURT OF COMMON Cf CUMBERLAND COUNTY PENNA. NO. 03 - 907 Plaintiff PLEAS VERSUS John R. Sollenberger, Defendant AND NOW, DECREED THAT AND DECREE IN DIVORCE Carrie U. Sollenberger John R. Sollenberger "~'~, IT IS ORDERED AND __, PLAINTIFF, __, 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ~aintiff VS. File No. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce On the ~ day ofJ~ ~2~ , hereby elects to resume the prior surname of '~ ?~ ~ , and gives this written notice pursuant to the provisions of 54 P.S. S 704. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND : on the 2¢% day of Notary Public, personally appear4d th~ be the person whose name is subscribed acknowledged that he/she executed therein contained. gnature of na~e ~ng resumed SS. ,~, before me, a above affiant known to me to to the within document and the foregoing for the purpose seal. Witness Whereof, I have hereunto set my hand and official --------'-- t mmis~jon ~xpires ~pr. ~,