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Home My WebLink About03-2551CHRIS LUBNOW, Plaintiff RONDA LEE LUBNOW, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENN$YLVANIA IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013 CHRIS LUBNOW, Plaintiff V® RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE NOTICIA Le han demandado a usted en la carte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o par abogado y archivar en la carte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la carte tomara medidas y puede entrar una arden contra usted sin previa aviso o notificacion y par cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros detechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME PaR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013 CHRIS LUBNOW, Plaintiff V® RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE COMPLAINT AND NOW, comes Plaintiff, by his attorneys, Rupp and Meikle and Richard C. Rupp, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, Chris Lubnow, is an adult individual residing at 591 Geneva Drive, Mechanicsburg, PA 17055. 2. Defendant, Ronda Lee Lubnow, is an adult individual residing at 65 Silver Crown Drive, Mechanicsburg, PA 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 26, 2002 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the Parties. 6. Plaintiff and Defendant are both citizens of the United States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as to the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff avers that there are no children born to the Parties under the age of 18. 10. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the Parties participate in counseling. 11. Plaintiff and Defendant separated on April 15, 2003. 12. Plaintiff asks the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. Respectfully submitted, 32 355 North 21st Street, Suite 205 Camp Hill, PA 17011 (717) 761-3459 Attorney for Plaintiff VERIFICATION I, Chris Lubnow, verify that the statements in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. CHRIS LUBNOW, Plaintiff CHRIS LUBNOW, !Plaintiff RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d IN DIVORCE understand that participate in col COUNSELING ~FFIDAVIT_ . I have beenI advised of the availability of marrmge counseling and 2. I understan~ the Domestic Rela 3. Being so ad' spouse and I partl handed down by t may request that the Court require that my spouse and I iseling. that the Court maintains a list of marriage counselors in ions Office, which list is available to me upon request. rised, I do not request that the Court require that my :ipate in counseling prior to a divorce decree being ~e Court. I understan~ penalties of 18 Pa authorities. Date: I that false statements herein are made subject to the C. S. Section 4904 relating to unworn falsification to CHRIS LUBNOW, Plaintiff CHRIS LUBNOW, Plaintiff RONDA LEE LUBNC)W, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA : NO. : IN DIVORCE e e AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301 ( c ) of the Divorce Code was filed on ~ ~/'2~ The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to of intention I verify that I understand that of 18 Pa. C.S. § 49 Date: I~)~' c~ lhe entry of a final decree of divorce after service of notice request entry of the decree. the statements made in this affidavit are true and correct. False statements herein are made subject to the penalties }4 relating to unsworn falsification to authorities. CHRIS LUBNOW, Plaintiff CHRIS LUBNOW, Plaintiff V® RONDA LEE LUBN4~W, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE WAIVER OF NC~TICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ii 3301 ( c ) AND 3301 (d) OF THE DIVORCE CODE 1. I consent to 2. I understan~ property, la~ divorce is gr 3. I understan¢ entered by t immediatel~ I verify that I understand that of 18 Pa. C.S. § 49 Date: he entry of a final decree of divorce without notice. that I may lose rights concerning alimony, division of ~yer's fees ar expenses if I do not claim them before a ~nted. i that I will not be divorced until a divorce decree is le Court and that a copy of the decree will be sent to me ]fter it is filed with the prothonotary. te statements made in this affidavit are true and correct. False statements herein are made subject to the penalties )4 relating to unsworn falsification to authorities. CHRIS LUBNOW, Plaintiff RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2551 IN DIVORCE CERTIFICATE OF SERVICE OF COMPLAINT CHRIS LUBNOW, Plaintiff RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE COUNSELING AFFIDAVIT 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 Domestic Relations Office, 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 authorities. penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to RONDA L~~OW, Defendant CHRIS LUBNOW, Plaintiff RONDA LEE LUBNOW, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 : IN DIVORCE AFFIDAVIT OF CONSENT_ A Complaint in Divorce under § 3301 ( c ) of the Divorce Code was filed on ~. The marriage of pldlntiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of 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. § 4904 relating to unsworn falsification to authorities. Date: RONDA LEE~ N~/V, Defendant CHRIS LUBNOW, Plaintiff RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQ_IJ_KST ENTRY OF A DIVOR~r DECREE UNDER 0 3301 ( c ) AND 3301 (d} OF THE DIVORCE CODr 1. I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, Icrwyer's fees or expenses if I do not claim them before a divorce is granted. 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. Date: j~(E L~/OW,' Dbfe~dant CHRIS LUBNOW, Plaintiff Ye RONDA LEE LUBNOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2551 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: e Ground for divorce: Irretrievable breakdown under (X) Section 3301(c) ( ) Section 3301(d) of the Divorce Code. Date and manner of service of the complaint: Certified Mail - June 16, 2003 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff, October 22, 2003 by defendant, October 23, 2003 (b)(1) Date of execution of plaintiff's affidavit required by Section 3301(d) of the Divorce Code: e Date: (b)(2) Date of service of plaintiff's affidavit upon defendant: Related claims pending:. ~ /ii'hard C. Rup~, Esqul~Ir Rupp and Meikle Attorney I.D. #34832 355 North 21st Street, Suite 205 Camp Hill, PA 17011 (717) 761-3459 Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of PENNA. CHRIS LUBNOW VErsus NO. __ 03-2551 DECREe IN DIVORCE AND NOW, , IT IS ORDERED AND DECREED THAT CHI{IS LUBNOW , PLAINTIFF, AND RONDA LEE LUBNOW ,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; BY The Cour' PROTHONOTARY