HomeMy WebLinkAbout03-1844
LISA MARIE ROSENBERGER
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ()3./?<f<+ ~ TLv-
DAVID A. ROSENBERGER
Defendant
CIVIL 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 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, 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.
CURTIS R. LONG, PROTHONOTARY
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
(717) 240-6195
LISA MARIE ROSENBERGER
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03. Jfl..ft..j ~ I~
DAVID A. ROSENBERGER
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(C) OR 3301(D)
OF THE DIVORCE CODE
AND NOW, comes the above-named Plaintiff, Lisa Marie
Rosenberger, by her attorneys, Mark A. Mateya, Esquire, of
counsel for Knupp, Kodak & Imblum, P.C., and seeks to obtain a
Decree in Divorce from the above-named Defendant upon the grounds
hereinafter more fully set forth:
1. Plaintiff is LISA MARIE ROSENBERGER, an adult
individual who currently resides at 70 Conrad Road, Carlisle,
Cumberland County, Pennsylvania 17103.
2. Defendant is DAVID A. ROSENBERGER, an adult individual
who currently resides at 8 Paradise Drive, Carlisle, Cumberland
County, Pennsylvania 17103.
3. Plaintiff and Defendant have been bona fide residents
of the Commonwealth for at least six (6) months immediately
previous to the filing of this Complaint.
1997, in Winchester, Virginia.
4. The Plaintiff and Defendant were married on March 29,
5. There have been no prior actions of divorce or for
annulment of marriage between the Parties in this or any other
jurisdiction.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a Decree of
Divorce.
Respectfully submitted,
BY:U~, U
Mark A. Mat~;~-l\
Attorney I.D. No. 78931
Of Counsel
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Dated:
LI (l\ ( D')
Attorney for Plaintiff
I, LISA MARIE ROSENBERGER, verify that the facts set forth
in the foregoing Complaint are true and correct to the best of my
knowledge, information, and belief. I understand that false
statements herein are subject to the penalties of 18 Pa.C.S. ~
4904, relating to unsworn falsification to authorities.
DATED: tJ/f'--/ r 0:7
r ~
....... ""-
~ ~
"Q
"'
o
~
Ji
~
""-
~
C)-
d
n
,-.--
,
- "
C~
\...J
LISA MARIE ROSENBERGER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this 8th
day of ~ 2003, comes Mark A. Mateya,
Esquire, Attorney for Plaintiff, who, being duly sworn according to
law, deposes and says that:
1. A Complaint under Section 3301 (c) and 3301 (d) of the
Divorce Code was filed on April 22, 2003.
2. On April 23, 2003, a certified copy of the Complaint was
sent to the Defendant via certified mail, restricted delivery,
return receipt requested pursuant to Pa. R.C.P. 1920.4.
3. On April 23, 2003, a certified copy of the Complaint was
set to the Defendant via first class mail, postage prepaid. A copy
of the Certificate of Mailing is attached hereto as Exhibit 'AI and
is incorporated herein by reference.
"'-~..
4. On or about May 5, 2003, undersigned counsel for
Plaintiff received the return receipt card signed by the Defendant
on April 24, 2003. Said receipt is attached hereto as Exhibit "B"
and is incorporated herein by reference.
KNUPP, KODAK & IMBLUM, P.C.
~Q, ~~'
BY:
Mark A. Mateya Esquire
Attorney I.D. No. 78931
Attorney for Plaintiff
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108
(717) 238-7151
~;.
...,~
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
I
Received From:
1n1lJ(1( A. IYJAIl
'1 ./J. ~~ O-'T .:>~
HA~15"BU~&, ~. J'1/0J
One piece of ordinary mail addressed to:
j)AIJA"D A t?osu~u."~
i 'At.A7nSE J)~ l V E
CA 1tJ...15LE PA. 1'1 J 0.3
,.
PS Fonn 3817. January 2001
.._..:.>
1U;"'1~
f i;
~~~il
.',;
~ ~ ~...!
~~~
c::'
-+ ll- tt";"), h:(
\
c:-
tf.
~~:-:l
"
..
r-"I
~
IT"
IlJ
Ul
~ Retum Receipt Fee
~ (Endorsement Required)
Cl Restricted Delivery Fee
Cl (Endorsement Required)
Total Postage & Fees
; I' .
SENDER: COMPLETE THIS SECTION
. 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 mail piece,
or on the front if space permits.
1. Article Addressed to:
1>A V ID A. ~ 0.5(JJ13E~bE~
Ig PAR.ADlSE"DR ,vS
C.A-ItLI5LE") PA. /7/05
Postmark
Here
\
II
a" ..... .. .
D. Is delivery address different from item 1?
If YES, enter delivery address below:
3. Se!)lice Type
[i" Certified Mail
D Registered
D Insured Mail
D Agent
D Addressee
Dyes
D No
D Express Mail
D Return Receipt for Merchandise
DC.a.D.
4. Restricted Delivery? (Extra Fee)
2. Article Number (Copy from service label) 'J{) '1/
7001 "f.~o 0001 JAD!5 t?t-,
PS Form 3811, July 1999 Domestic Return Receipt
~es
102595-99-M-1789
T
\
..
(") ('"':~,
C
:;;...- .
-0 ~~:-
J-ri I ..,.~~
-~..
.,,/
CJ;22 I ""',
2"<:-
I \ c
:.::::
~c
I f c "",
>c:
:?:: 'jl c
:~ _:~~
( -,' """"
r
L
'-1(1
fn(1
-7.
6~~
-< .
~C
Pc
ZC-
>c
z
--;
-<
I
i
)
l
. -
{.....,
_n
, .:"
- - )
'"
,J
"'1
~a
-<
LISA MARIE ROSENBERGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDA VII OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April
22,2003
2. The marriage of Plaintiff and Defendant is irretrie:vably 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 this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn
faisification to authorities.
DATED: Of] - 1M -()L!
~Jfl:.mf~"d4ll~
Lisa Marie Ro enberger ,
Plaintiff
-
"""
o
c:
~r
I'
""
c::;.)
~
b"
o
-q
:.....j
..L..,...,
f'11p:
'.\:"Inl
~t)O
OL
::r:!~;~
<~??5
(3fT'l
~
;:z
~-
C')
I
<.D
;~?
S-:>
QJ
LISA MARIE ROSENBERGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-1844 CIVIL TERM
DA VlD A. ROSENBERGER,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A 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. S 4904 relating to unsworn
falsification to authorities.
DATE() '7-13 --0,/
rI. ;.../f);m j;r. PlI<-ttU(1
~: Rosenberger
Plaintiff
""'
.'-"
""
c:::;>
"'''
...-
E:
G')
I
U')
o
.,
~:1
_L...,.,~
rn r~~
-[lfTl
:UCi
0-1,
--iC
~=~2~
'~,-~rn
e>
,-\
i5:;
,,<
"
::i:
~
crJ
LISA MARIE ROSENBERGER
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,PENNSYL VANIA
v.
: NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER
Defendant
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Lisa Marie Rosenberger, Plaintiff, by and through her attorney, Mark A. Mateya, Esquire,
moves This Honorable Court appoint a master with respect to the following claims:
(X) Divorce
() Annulment
() Alimony
() Alimony Pendente Lite
() Distribution of Property
() Support
() Counsel Fees
() Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims for which the appointment of a master is required;
(2) Defendant, David A. Rosenberger, is unrepresented by an attorney in this action.
(3) The statutory grounds for divorce are 23 Pa.C.S. section 3301(d),
(4) The action is contested with respect to the following claims: divorce.
(5) The action involves complex issues offact.
(6) The hearing is expected to take one day.
(7) Plaintiff, Lisa Marie Rosenberger, filed a complaint in divorce on April 22, 2003. For a
period of twenty (20) months, the parties have negotiated in an attempt to amicably resolve the
I
.
claims at issue. Said negotiations have proven unsuccessful.
WHEREFORE, Plaintiff, Lisa Marie Rosenberger, respectfully requests that This
Honorable Court appoint a master with respect to his claim for divorce.
Respectfully submitted,
~.t~~
P.O. Box 127
Boiling Springs, P A 17007
(717) 241-6500
(717) 241-3099 Fax
Date:
o b..(os
Attorney for Plaintiff
2
VERIFICATION
I, Lisa Marie Rosenberger, verify that the facts set forth in the foregoing Motion for
Appointment of Master are true and correct to the best of my knowledge, information, and
belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. S
4094, relating to unsworn falsification to authorities.
DATED: 09-1 h -()~
4
0 ....., ~
=
c:: =
;;;:: c.n
-o...'.~ <:- ~:n
.J..
mr~! c:
z", :z: :stn
tj'd I
~j )~.. g~
~:,;: w
~L)
:r>C' -0 6:!.l
2;..-1 :x -?()
j;,-J ..<:-m
C .r:- 8
~ Cl ~
U1 -<
-
.' .'V.;f"
/'~ .
LISA MARIE ROSENBERGER
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY ,PENNSYLVANIA
v.
: NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER APPOINTMENT MASTER
AND NOW, this pay of 05, p jJ.rt.dtt~u,ESq.iS
appointed master with respect to e following claims:
1. Granting of Divorce Decree
'v'IN'tfA1ASNN3d
UNn~" '-'1",-,'"1' ''''''vvno
f '! ' , . ,'" '~1", ,-.f; ,
' ~ \,.' -". " ",.', ,r "'. r
Zt :6 I1V 9- Imr saal
Al:JV10NOH100d 3Hl. .:10
D.:!:IQ-Q31l:J
LISA MARIE ROSENBERGER
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYL VANIA
v.
NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER
Defendant
CIVIL ACTION - LAW
IN DIVORCE
INVENTORY
1. List of all assets which specifies:
A. The parties have equitably divided their marital assets.
B. The non-marital assets, their value, the date of the valuation, and any liens or
encumbrances thereon.
None
2. The name and address of each expert whom the party intends to call at trial as a witness.
None
3. The name, address and a short summary of the testimony of each person, other than a
party, whom the party intends to call at trial as a witness.
None
4. A list of all exhibits which the party expects to offer in evidence, each containing an
identifYing mark.
None
5, The party's gross income from all sources, each payroll deduction and the party's net
income, including the party's most recent state and federal income tax returns and pay
stubs.
None
---
6. If a party intends to offer any testimony as to his or her expenses, a current expense
statement in the form required by the practice and procedure governing an action in
support.
7. The value of a pension or retirement benefit, the marital portion thereof, and the facts and
documentation upon which the party relies to support the valuation.
8. Ifthere is a claim for counsel fees, the amount offees to be charged, the basis for the
charge and a detailed itemization of the services rendered.
9. The description and value of any items of tangible personal property, the method of
evaluating each item, and the evidence, including documentation, to be offered in support
of the valuation.
10. A list of marital debts, including the amount of each debt as of the date of separation, the
date on which the debt was initially incurred, the initial amount ofthe debt and its
purpose, the amounts and dates of payments made since the date of separation, and the
evidence that will be offered in support of the claim.
11. A proposed resolution of the economic issues:
None.
ASSETS OF THE PARTIES
1. Real Property - The parties have equitable distributed the marital assets.
2. Motor Vehicles - The parties have equitably distributed the marital assets.
3, Stocks, bonds, securities and options.
Plaintiff - None
Defendant - Unknown
4. Certificates of Deposit
Plaintiff - None
5. Checking Accounts, cash
Plaintiff -
$800.00
6. Savings Accounts, money market and savings certificates
Plaintiff - None
7. Contents of safe deposit box
Plaintiff does not have a safety deposit box
8. Trusts
Plaintiff is not the recipient or owner of any Trusts.
9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
Plaintiff - None
10. Annuities
Plaintiff - None
11. Gifts
Plaintiff - None
12. Inheritances
Plaintiff - None
13. Patents, copyrights, inventions, royalties
Plaintiff - None
14. Personal property outside the home
Plaintiff - None
15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company).
Plaintiff - None
16, Employment termination benefits - severance pay, worker's compensation claim/award
Plaintiff - None
17. Profit sharing plans
Plaintiff - None
18. Pension plans (indicate employee contribution and date plan vests)
Plaintiff ..
19. Retirement plans, individual retirement accounts
Plaintiff - None
20. Disability payments
Plaintiff - None
21. Litigation claims (matured and unmatured)
Plaintiff - None
22. MilitaryN.A, Benefits
Plaintiff is not eligible for any MilitaryN A Benefits
23. Education benefits
No benefits are eligible or have been received by the Plaintiff or Defendant.
24. Debts due, including loans, mortgages held
Plaintiff - shall assume all liability for and pay and indemnifY the Defendant against any
of her individual debts.
Defendant - Shall assume all liability for and pay and indemnifY the Plaintiff against any
of his individual debts.
25. Household furnishings and personalty (include as a total category and attach itemized list
if distribution of such assets is in dispute)
Plaintiff - None
26. Other
MARITAL PROPERTY
List all marital property in which either or both spouses have a legal or equitable interest
individually or with any other person as of the date this action was commenced:
Descriotion of Prooertv
None
Name of all Owners
NON-MARITAL PROPERTY
List all property in which a spouse has a legal or equitable interest which is claimed to be
excluded from marital property:
Descriotion of Prooertv
Reason for Exclusion
None
Descriotion of Prooertv
None
PROPERTY TRANSFERRED
Date of Transfer
Consideration
Person to
Whom
Transferred
LIABILITIES
Descriotion of Prooertv
None
Names of all Creditors
Names of all Debtors
, .
CERTIFICATE OF SERVICE
I, hereby certify that I have served a copy of the foregoing Motion for Appointment of
Master on the following person(s) by facsimile and by depositing a true and correct copy of the
same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland
County, Pennsylvania addressed to:
David A Rosenberger
8 Paradise Drive
Carlisle P A 17103
Dated:
& h-Jos
J /
~.l.;~
P,O. Box 127
Boiling Springs, P A 17007
(717) 241-6500
....>
=
~
<-
~
I
W
2.
;-:.
""C:"fO
fl' .~.,
~ji~Y~
th,,":"
~t.)
~.F
~c:
z
:i
~
:t..,...
rn f"
-Q'f'I
t3b
::;;..,.
1"j~!..1
",,0
(:Sf'n
-'",
';1-;"3
:..:c
...,
:S
.r::
o
<.f'
IT
LISA MARIE ROSENBERGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER,
Defendant
: CIVIL ACTION .. LAW
: IN DIVORCE
COUNTER-AFFIDAVIT UNDER &3301 (d)
OF THE DIVORCE CODE
~.JQ 1. Check either (a) or (b):
, ~@ do not oppose the entry of a divorce decree.
(b) 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 irretrievable broken.
2. Check either (a) or (b):
~~I do not wish to make any claims for economic relief. I understand that I may lose
right~erning alimony, division of property, lawyer's fees or expenses if! 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 ther<eafter to file any economic
claims.
I verify that the statements made in this courter-affidavit are true and correct. I
understand that false statements herein are made subject t les 0 18 P .S, ~ 4904,
relating to unsworn falsification to authorities.
Date:~
David A. Rosenb
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 should not file this counter-affidavit.
0 ...., ~
=
c: =
s::. c.ro
"uc..-. ".. ~::D
q.JCLi c:
"",_".1. C') ~~
ZC
(f),L" 0
,~<.,,'
~C~ ".. ~~
)0.---
~g :3:
CO Q
~ U1 ~
-< w .<
.-
"
LISA MARIE ROSENBERGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLANII COUNTY, PENNSYL VANIA
v.
: NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER & 330U c) or 3301 (d) 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! 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 immediate:ly 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.
DATE~~JrJ~~5'
a:,~ b1?a-2';' ? dJ"'71
~:{osenberger
Plaintiff
~,
o
<g:
-0(;:-:
,-n\;.
-:"-:;-"
21.."
(/) 00"".'
-<c'
;;:
'~~
z
~
,...,
~
~
C>
~
;; \%
~-r\
9-~
9.
?Q
'<
".
:Jf.
C?
(J\
c:..:>
LISA MARIE ROSENBERGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-1844 CIVIL TERM
DAVID A. ROSENBERGER,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
IF YOU WISH TO DENY ANY OF THE STATEME:NTS SET FORTH IN THIS
AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS
AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS
WILL BE ADMITTED.
AFFIDAVIT UNDER SECTION 3:JOHdl
OF THE DIVORCE CODE
1. The parties to this action separated on April 15, 2001, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievable broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
Date: ~TJJ ~~ r:2f'r:>S"'
ct,,;mw'p ?,,,/,,,~
Lisa Marie Flosenberge '
Plaintiff
~
, , "
o
S
-;S;.
-ocr.:
q~fJ~
:Zc.,
~~;:
ec
~c:
-c:
J>c
~
~ ~
5\
~ ~fii
c; ~~
~ 9-~
0) ~
.. ~
c..n :Q
c.>
, .
LISA MARIE ROSENBERGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 03 - 1844 CIVIL
DAVID A. ROSENBERGER,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
/2 'ft.,
day of
L ?~~f--
in the proceedings,
2005, no economic claims having been raised
and there being no issue with respect to grounds for divorce,
the Plaintiff having filed an affidavit under Section 3301(d)
averring a separation in excess of two years, and Defendant
filing a counter-affidavit in which he states that he does not
oppose the entry of a decree nor does he wish to make any
claims for economic relief, the appointment of the Master is
vacated.
BY THE COURT,
cc: ~rk A. Mateya
Attorney for Plaintiff
Geor
>
~=)l
!l~ ,VCY
,c\ \J
()
Vlf"VlY'f,lS:I"',li,J.3d
A.tNnC:: ;~c"'lnJ
SO :z ~ld Z I 5f]V SOUl
},tJV lONOHlOcd 3H.L :10
38:~~o--0311~
, "^"..
"'"'''' ,'"
Lisa Marie Rosenberger,
Plaintiff
IN THE I...vURT OF CCMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.03-1844
CIVIL
~ 2003
vs.
David A. Rosenberger,
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce C~cree:
1. Grounds for divorce: irretrievable breakdown under Section 3301 (c)
3301 (d)(l) of the Divorce Code. (Strike out inapplicable section)
2. Date and manner of service of the ccmplaint: Bv Certified Mail.
Restricted Delivery on April 23, 2003. See Affidavit of Serivce.
3. Ccmplete either Paragraph A. or B.
A. Date of execution of the affidavit of consent required by Section
3301 (c) of the Divorce Code: by the plaintiff
by the defendant
B. (1) Date of execution of the plaintiff's affidavit required by
Section 3301 (d) of the Divorce Code:
August 10, 2005
(2) Date of service of the plaintiff's affidavit upon the defendant:
Allgll"t 1 0 r 200'i
4. Related claims pending:
5. Indicate date and manner of service of the notice of intention to file
praecipe to transmit record, and attach a copy of said notice under Section
3301 (d)(l)(i) of the Divorce Code
1""'-,,'
G
CJ.
(/')
C;~':
o
."1
,...,
~1i~1
-
f'J
\.C
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
+:+.:+ '+ +
.'
.
.
.
.
.
.
.
.
.
;f.:f.+++
..
...
.
..
. ..
:+ :""f. +:+:+
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
++++++++++++++++++++++++++++++++++~
++:+:++++++++++++
. ..
++ ++ ++ '+' '+ ++ ++ + + +'+:+:Ii. ++ ++ +. ++
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
Lisa Marie Rosenberger
VERSUS
David A.
Rosenberger
AND NOW,
DECREED THAT
PENNA.
No.
03-1844
DECREE IN
DIVORCE
:'.. p+.
\L;""
2005
, IT IS ORDERED AND
Lisa Marie Rosenberger
, PLAINTIFF,
AND David A.
ROljenberger
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
YET BEEN ENTERED:
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
.
.
.
++:+:+.'I'++++'I'+'+'
-,
OJ
By THE COURT:
,{
I
(~l
J
ATTESV
.. / ..
. , .
Ui/ L-" X
"'/
L./
PROTHONOTARY
+++++'+'+++++
. ..
J.
~
..#p .J? ~ ~J< 5Cl1/',~
~r 9~;~'~ 5C?'?/-6
'. ,
.. .", ...... . ..,
. # l