Loading...
HomeMy WebLinkAbout01-05225IN THE COURT OF COMMON PLEAS Plaintiff VERSUS Defendant N O. 01-5225 civil DECREE IN DIVORCE AND NOW, /~fi~+^vai, ZU ~ 208 'Z-IT IS ORDERED AND A DECREED THAT RctYl A WACJ~,Ti , PLAINTIFF, AND David A. Wogan ,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 COURT: PROTHONOTARY ,. , ,; BETH A. WOGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 01-5225 DAVID A. WOGAN, Defendant 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: L Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail, September 10, 2001. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff, February 11, 2002; by the Defendant, February 11, 2002. 4. Related claims pending: None. 5. Date Plaintiffls Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 13, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 13, 2002. Date: February 13, 2002 C - Kazl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 r> ~.: c _ ~~~ r' ~ r,~ r~ ` s _- - _ ~ - ~n ; <. - ~ .- ~.;. Y r.~( ' ~ ~ ~~ `~ ~~i ~~ ~'J 4fl .-~ BETH A. WOGAN, Plaintiff v. DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW n No. ©~,~~~~ C 11~6~ 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 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, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 BETH A. WOGAN, Ev THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. ©~ _ ~~ t-~ ~ h~ l DAVID A. WOGAN, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Beth A. Wogan, who currently resides at 542A Criswell Drive, Cumberland County, Pennsylvania, since January 2001. 2. Defendant is David A. Wogan, who currently resides at 96 Cold Springs Road, Cumberland County, Pennsylvania, since November 1998. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married in December 13, 1996, in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto 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 in Divorce. I verify that the statements made in this Complaint 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: Q/3o/DI ~ C~J°r~.a.'~ Beth A. Wogan, laintiff By;.-' Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 3 BETH A. WOGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 01-5225 DAVID A. WOGAN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND AND NOW, this 13`h day of February, 2002, I, Karl E. Rominger, Esquire, attorney for Beth A. Wogan, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested, restricted delivery. The original return receipt card signed by the Respondent on September 10, 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated: February 13, 2002 By: ~~ Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 I.D. # 81924 EXHIBIT "A" 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 maiipiece, or on the front if space permits. 1. Article Atldressed to: ~t11 D Gr)o~ AN ~ Q~ ~~~S~r"~s ~L~ 51~ , ~s~-l 7O1 ~3 C. ~' Agent , D. Is delNery atldress diflerer~M6m item 1 Y LJ Ye; If VES, enter tlelivery address below: ~'No 3. Service Type 'Certified Mail ^ F~cpress Mail ^ Registered ~ Return Receipt for Merchandise ^ Insuretl Mail ^ C.O.D. 4. Restdcted Delivery? (EMra Fee) _ 'yes 2. Article Nul 2D44 P9 Form 3E 3-M-i7HB BETH A. WOGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 01-5225 DAVID A. WOGAN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 5, 2001, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 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 aze made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: ~' /I I /b~ ~ "" ~-'~ Beth A. Wogan, Plaintiff wulw..~.~i~ao-:. ~.~~ ..~.. exec ~xunai~ » 2'~ s-i ..~ ".... ., x ~ ~.x;x~&uV.rxm - aim' AFANd a i. c~ ~-, <__- i°,~ `cc: ~ -., -~ to Wiz`, <.; c.~ - r :: r_=; ~-, - =' -; -r < lr ~~ ~. BETH A. WOGAN, Plaintiff v. DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-5225 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 properly, 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. Date: a~i t /Cfa ~ ~~) Beth A. Wogan, Plaintiff ~x:. ~:ws_.naw A.~,ra ,x~•p,. e es Rs.,xa.:v a z:.~. « ., s--.. .... ::: tt..~_as~. ~1..bs'u3siu=4.~w~t4!'M~&iiP""'• ,.•,~-Yes~cv ~N ' }! "rj ~,'! ('; G.]. :'/ 2 vim. ~ s- _ `= ( _ y ~ {t`. _ cL 5 ~ ~, l7 -.~ ~, BETH A. WOGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 01-5225 DAVID A. WOGAN, Defendant IIQ DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 5, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 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:a - j ~ - Q ~ a~rn a S ub~.r ~~ ~~r~ ~-11-oa NOTARIAL SEAL ~~ DARCIE A. NEIL, Notary Public Oarlisle, Cumberland Cou,~t 11L4V LLL A. YY V~. LALL, 11 \.1Li11LLCLLLL ' t 5lii~E34lbtrll.bR'awvs~xuw.uw=mmitucar ~m~ w.r..~ : w.._-u.ar~vser&w ~~'~&`d~ `+~'k~rsumm. ` ,d C i C°: G_ - f•,~ -1 _ 'C7 t"i; ~ "_~ .~'' _i. C -.-_ t~" yam(' 1L` _ __ ~~ ~~ BETH A. WOGAN, Plaintiff v. DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-5225 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 properly, 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 subj ect to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. // t ~~ Dater l! David A. Wogan, Defend ~e~rr1 .l ~~-`-~'J~r-~L~ NOTARIAL SEAL DARCIE A. NEIL, Notary Public Cari'~s{e, Cumber{and County My Commission Expires Nov, 24, 2065 '. ~~