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Home My WebLink About01-04936 IN THE GOURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. w',= , DANIELLE M. RHOADS, Plaintiff VERSUS NIGEL L. RHOADS, Defendant N O. 2001-4936 CIVIL DECREE IN DIVORCE /'~ AND NOW, °-1 J "~/~~T IS ORDERED AND DECREED THAT AND DANIELLE M. RHOADS NIGEL L. RHOADS ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, 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 C°v~ DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IIV THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4936 CIVIL TERM CIVIL ACTION-LAW IN 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: Ground for divorce: irretrievable breakdown under Section 3301(c) of the divorce code. 2. Date and manner of service of the complaint: Service upon the defendantvia certified mail, restricted delivery on August 24, 2001. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 3301 (c) of the divorce cods: by the plaintiff November 29. 2001 ; by the defendant January 27, 2002 (b) (1) Date ofexecution ofthe plaintiffs affidavit required by Section 3301 (d) of the divorce cods N/A (2) Date of service of the plaintiffs affidavit upon the defendant N/A 4. Related claims pending NONE 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: January 30. 2002 Date defendant's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: January 30. 2002 Mic ael A. Scherer, Esquire Attorney for the Plaintiff, Danielle M. Rhoads ~: ,~ z~~ a -- -, ~ < ~ = ..~ ~ ,' ~ t~v ` c- a ~= ~ ~ _~ .~ DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- ~-lj 3~ CIVIL TERM 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 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 Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, PA 17013 Telephone: (717) 249-3166 I DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001- y~~ CIVIL TERM CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C) AND 3301(D~ OF THE DIVORCE CODE 1. Plaintiff is Danielle M. Rhoads an adult individual who resides in Cumberland County, Pennsylvania. 2. Defendant is Nigel L. Rhoads, an adult individual who currently resides at 23 Betty Nelson Court, Lot #139, Carlisle, Cumberland County, Pennsylvania. 3. 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 Plaintiff and Defendant were married on August 12, 1998, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she 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. ~I WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARK & SCHERER DATE: ~ . Z ~ • ~ I '/%~~ Michael A. Scherer, E quire I.D.# 61974 17 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff, Danielle M. Rhoads mas.dir/domesticldivorce/rhoads.com VERIFICATION The statements in the foregoing Complaint are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. !understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. DATE: ~ I ~ ~ ~ ~ ~~ ~( ~~~~~~~~%~/ Danielle M. Rhoads .~ :, :~ " ; ~ ~: ~~ ~y~r;. ' ,; = _ ~, << - ,. ~= . ==3 A ~ ~ (jT -U DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2001-4936 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on August 22, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: \l ~~~~~~ ~~~'~ (~' l~~Y~%''T0~' Danielle M. Rhoads ~ - c_ _.. -, . - ~ r;^ ~ _: ~~~ _ ~ ~,. C,. -" r- ti (aj ~7 F~ DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4936 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on August 22, 2001. 2. Defendant acknowledges receipt and accepts service of the Complaint on August 24, 2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: ~--~- - ~~ Nigel L. Rhoads C7 c~ i, C ~~ i 4 v c n~ r.~. -~ - T. _~ ~~ ,- ~- , . r"C .. G <'7 ~ DANIELLE M. RHOADS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NIGEL L. RHOADS, Defendant NO. 2001-4936 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card. DATE: January 29, 2002 ^ GZ>mplete~items.l, 2; antl~3. Also complete •iteen 4 if Restricted Delivery is desired. ~e P+ipt your name end address on the reverse . so that we eari.re~urri the card to you. •~. Attach this card to the back of the mailpiece, or on the frdnt if space permits. 1. Article Addressed to: ~I~~.l Le ~dwads ~3 ~~+I~u Nilson Caut~t l,o-I' .~ II 3q . ~rlisl~, F~ 17013 C. Signa[urd X , ^ Agent /wyi(i' / ~~/~17 Addre D. Is delivery ad~(ass different from item 1? ^ Yes If YES, enter delivery address below: ^ No 3. Service Type " (Certified Mail ^ Ezpr~s Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.C.D. 4. Restricted Delivery? (ire Fee) Yes 2, Article Number (Copy from O'BRIEN, BARK & SCHERER BY i~~~~~~~i `~ ~' Mi hael A. Scherer, Esquire Receipt 102595-00-M-0952 c '' ~~~: ~ _ ' ~r u~ - ~; ~.::_ ~~ -- -t~ l ~:; ~ - -.`l; .~ v '%~C' C °° `~ ~ .J +-~ C7 -~-? ... -_ ..., F _ ...... _. ewe... ._ t ~ ~ !` DANIELLE M. BROADS 1N THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 01-4936 CIVIL ACTION LAW NIGEL L. BROADS DEFENDANT 1N CUSTODY ORDER OF COURT AND NOW, Tuesday, October 30, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Flubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 15, 2001 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: ls/ Hubert X. Gilroy Esq_ Custody Conciliator The Court of Common Pleas of Cumberland County is required bylaw to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or'hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FI1VD OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 • r 1 pefypyylr_)(' _qt -.'y.- ~/Z%p/~Y//' ~A /d~~~// ~~~ ~ ~ ~`~ ~~irJ~~.171,sr~n~~~ uran~"i (li\j1i7J!yGll;;1V taJ ~~; 6'ic3 I ° r`l~id ILl ""J ''r f/ _:, 1 ~ ~ ~~ ~ I: ~7%F 3w r•~i'~s ate, M*P°a~a=tom... 1 `+ ~ ~~;-~ 2 9 2001 DANIELLE M. RHOADS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-4936 CIVIL TERM NIGEL L. RHOADS, CIVIL ACTION-LAW Defendant IN DIVORCE/CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ,Esquire, the conciliator, at on the day 2001 at A.M./P.M., for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order BY THE COURT, Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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, PA 17013 (717) 249-3166 DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4936 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE/CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Danielle M. Rhoads, an adult individual who currently resides in Cumberland County, Pennsylvania. 2. The Defendant is Nigel L. Rhoads, an adult individual residing at 23 Betty Nelson Court, Lot # 139, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present residence Sierra M. Rhoads with the Plaintiff The child was not born out of wedlock. Date of Birth 05/25/00 The child is presently in the custody of Plaintiff, who resides in Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates Nigel L. Rhoads and 23 Betty Nelson Court, Lot #139 05/25/00 to Danielle M. Rhoads Carlisle, Pennsylvania 17013 05/28/01 Danielle M. Rhoads with the Plaintiff 05/28/01 to present VERIFICATION I verify that the statements made in the foregoing Complaint for Custody 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 falsifi tion to authorities. C Danielle M. Rhoads DATE: ~ ~ (~ 7. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff requests your Honorable Court to grant her primary physical custody of the child. Respectfully submitted, O'BRIEN, BARK & SCHERER ~~% . ~ Michael A. Sc erer, Esquire I.D. # 61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.diNdomestic/custody/rhoads.com nEC 0 7 2001 ~~ DANIELLE M. BROADS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW NIGEL L. BROADS, NO.O1 - 4936 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this ~ day of December, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Danielle M. Rhoads, and the Father, Nigel L. Rhoads, shall enjoy shared legal custody of Sierra M. Rhoads, born May 25, 2000. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy temporary physical custody with the minor child as follows: A. On alternating weekends from Friday after Father's work until Sunday evening at 7:00 p.m. B. At such other times as agreed upon by the parties. 4. The parties shall work between themselves to arrange a shared holiday schedule for purposes of sharing or alternating custody of the minor child on major holidays. 5. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again sche uled with the conciliator for aconference. BY J. Edgar B. Bayley cc: Michael A. Scherer, Esquire Nigel L. Rhoads I 23 Betty Nelson Court t~f ~.' ~~' d/ Carlisle, PA 17013 Iv~-S c~ ;, ; ~ a -- _ : ; ~ (~~._; ~ L T ~" ,~; y _ v _ r ~\ ~~, r J ya `_ ,_ _', DANIELLE M. BROADS, Plaintiff v NIGEL L. BROADS, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1 - 4936 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Sierra M. Rhoads, born May 25, 2000. 2. A Conciliation Conference was held on December 6, 2001, with the following individuals in attendance: The Mother, Danielle M. Rhoads, with her counsel, Michael A. Scherer, Esquire; and the Father, Nigel L. Rhoads, who appeared without counsel. 3. There was an issue at the custody conciliation conference with respect to each parties respective responsibility when they have custody of the minor child. The conciliator reviewed those issues with the parents, and the matter should be resolved for the time being. There is also an existing PFA which includes a custody order and the parties request that the current status quo be incorporated into a custody order at this term and number. Based upon that request, the conciliator recommends the entry of an order in the form as attached. i a Cc ~~ DATE Hubert X. Gilroy Esquire Custody Conci 'ator DANIELLE M. RHOADS, Plaintiff v. NIGEL L. RHOADS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4936 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce from the Bonds of Matrimony on the 5th day of February, 2002 hereby elects to retake and hereafter use her prior name of Danielle M. Keck, and gives this written notice avowing her intention in accordance with the provisions of the act of May 25, 1939, P.L. 192 (23 P.S. 98), as amended. ~j Dated: ~ ~~ ~~ ~~~Zi~G ~%~d'l - ~~ Danielle M. Rhoads TO BE KNOWN AS ~-~ - ~ , Dame le M. Keck COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the 22nd day of February, 2002, before me, a notary public, personally appeared Danielle M. Rhoads to be known as Danielle M. Keck, 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 official seal. 5p Notarial Seal Jennifer S. Lindsay, Notary Public t Carlisle Boro, Cumberland County My Commission Expires Ncv. 29, 2003 Member, PennsyNaniaASSOCiafonof Notariss ~. ~' a ~ ~ C` - 'V ICJ ~' VJ ~~ c ~ -~ <: -_~ ~ ~ ~~ ~ . CI1 ;. _ -< .. ~ ~°: . _ Cal 5' 1 l ~~ ~~