HomeMy WebLinkAbout07-2314
RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
TAMI M. ROTZ, NO. d7~ ~-~ ~ CIVIL TERM
Defendant 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
will proceed without you and a decree of divorce or annulment may be entered against you for
any 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 Cumberland County Courthouse, Carlisle, Cumberland County,
Pennsylvania, 17013.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
Phone: (717) 249-3166 or (800) 990-9108
RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
TAMI M. ROTZ, : NO. ~ ~ ~l y CIVIL TERM
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
1. Plaintiff is Ronnie L. Rotz, an adult individual currently residing at 40 Cabin Lane,
Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Tami M. Rotz, an adult individual currently residing at 826 Rustic Hill
Drive, Chambersburg, Franklin County, Pennsylvania.
3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 27, 1998 in Cumberland County,
Pennsylvania.
5. There have been no other prior actions for divorce or annulment between the parties.
6. Neither the Plaintiff nor the Defendant are members of the United States Armed
Forces or its Allies.
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling. Knowing this, Plaintiff does
not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90)
days from the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301 (c) of the Domestic Relations Code.
Respectfully submitted,
Hannah Herman-Snyder, E quire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
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RONNIE L. ROTZ, Plainti
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RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
~,3ry
TAMI M. ROTZ, NO. 07- CIVIL TERM
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
I, Hannah Herman-Snyder, Esquire, counsel of record for Plaintiff, state that a true and
attested copy of a Complaint in Divorce was sent to Defendant, Tami M. Rotz, at her address of
826 Rustic Hill Drive, Chambersburg, Pennsylvania, by certified mail, restricted delivery. A
copy of said receipt is attached hereto indicating service was made on April 28, 2007.
Hannah Herman-Snyder, Esq ire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-SS51
(800) 347-5552
Sworn and subscribedd to
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RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
TAMI M. ROTZ, NO. 07-2314 CIVIL TERM
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on
April 20, 2007, and service was made nn April 2~, 2~'^'' by restricted
delivery, certified mail.
2. The marriage of 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 of Divorce after service of notice of
intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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.
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RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
TAMI M. ROTZ, NO. 07-2314 CIVIL TERM
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 THE FOREGOING 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.
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RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v.
TAMI M. ROTZ,
Defendant
CIVIL ACTION -- LAW
NO. 07-2314 CIVIL TERM
IN DIVORCF,
AFFIDAVIT OF CONSENT
A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on
April 20, 2007, and service was made on April 28, 2007 by restricted
delivery, certified mail.
2. The marriage of 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 of Divorce after service of notice of
intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PF,NALTIES OF 18 Pa.C.S. §4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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TAMI M. ROTZ, De end t
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RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
TAMI M. ROTZ, NO. 07-2314 CIVIL TERM
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree in 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 THE FOREGOING 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
IJNSWORN FALSIFICATION TO AUTHORITIF,S.
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TAMI M. ROTZ, Defendant
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RONNIE L. ROTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 07-2314 CIVIL TERM
TAMI M. ROTZ, :CIVIL ACTION-LAW
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:
1. Ground for divorce:
Irretrievable breakdown under §3301(c)
(Strike out inapplicable section).
2. Date and manner of service of the Complaint: by certified mail, restricted delivery on
April 28, 2007.
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: 08/01/07 by Defendant: 08/01/07
(b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code:
(2) Date of filing and service of the plaintiff s affidavit upon the respondent:
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 of plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: August 6, 2007
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: August 14, 2007
Hannah Herman-Snyder, Esqui
GRIFFIE & ASSOCIATES
Attorney for Plaintiff
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I N THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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Ronnie L. Rotz,
Plaintiff
NO. Q7=2314
VERSUS
Tami M. Rotz,
Defendant
DECREE IN
DIVORCE
AND NOW, roe' .Z/ , X07 IT IS ORDERED AND
DECREED THAT Ronnie L. Rotz ,PLAINTIFF,
AND Tami M. Rotz ,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.
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