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Home My WebLink About07-2850CHRISTOPHER H. ROBINSON, Plaintiff vs. MELISSA A. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. -):? - a 90 6,e?l 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 foregoing 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 in 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 Telephone: (717) 249-3166 I CHRISTOPHER H. ROBINSON, Plaintiff VS. MELISSA A. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, CHRISTOPHER H. ROBINSON, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is CHRISTOPHER H. ROBINSON, an adult individual who currently resides at 513 Jacob Lane in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is MELISSA A. ROBINSON, an adult individual who currently resides at 513 Jacob Lane in Mechanicsburg, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of 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 31 May 1998 in Hanover, York County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. uel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12ffi Street Lemoyne, Pa 17043 (717) 761-5361 A I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: A9g-tL-2.6,, Zgu-7 CHRISTOPHER H. ROBINSON w N ?l ? `C1 U\ ?) CHRISTOPHER H. ROBINSON, PLAINTIFF VS. MELISSA A. ROBINSON, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-2850 IN DIVORCE ACCEPTANCE OF SERVICE I hereby enter my appearance in the above matter on behalf of the Defendant Melissa A. Robinson, accept service of the Complaint, and acknowledge receipt of a copy of the Complaint this date. Date: ? 101cDonald T: Kissinger Attorney for Defendant Supreme Court ID #?_ 17) C.s? CHRISTOPHER H. ROBINSON, ) Plaintiff ) VS. ) MELISSA A. ROBINSON, ) Defendant ) IN THE COURT OF COMMON P EAS OF CUMBERLAND COUNTY, P NNSYLVANIA CIVIL ACTION - LAW NO. 07-2850 CIVIL TERM IN' DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 11 May 2007 and served upon the Defendant on or about:, 17 May 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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. 1 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 io the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. CHRISTOPHER H. ROBINSON t?ILP oa? - Lt? f i ( ..5j r c CHRISTOPHER H. ROBINSON, ) Plaintiff ) VS. ) ) MELISSA A. ROBINSON, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2850 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 11 May 2007 and served upon the Defendant on or about 17 May 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 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. A AA?AW Dated. f4QLISSA A. ROBINSON ?? m ? ?? ? ?? ??t° ~- t? P--- '? t7-? ?t`rv' . . r ? ? . ??:_ m ?? ? .. ??? : r ?? ? ?=?` ?. :? CHRISTOPHER H. ROBINSON, Plaintiff VS. MELISSA A. ROBINSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2850 CIVIL TERM 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 Section 3301(c). 2. Date and manner of service of the Complaint: Acceptance of Service indicating service on the Defendant on 17 May 2007. 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: 6 March 2008 by Defendant: 2 March 2008 (b) Code: Respondent: (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce (2) Date of filing and service of the Plaintiff's Affidavit upon the 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: Dated 6 March 2008, filed contemporaneously herewiT th. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 2 March 2008, filed contemporaneously herewith. rv---?w amuel ndes Attorney for Plaintiff " Date: e'?b1 --v ? ? r? ?: ?' -n ??:. -? t `` ?` ? - _ ;; :`? ` ?: 5 ? ? = IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CHRISTOPHER H. ROBINSON, Plaintiff 2007-2850 CIVIL TERM No. VERSUS MELISSA A. ROBINSON, Defendant DECREE IN DIVORCE ,( 2008 AND NOW, VA z-) c? IT IS ORDERED AND CHRISTOPHER H. ROBINSON DECREED THAT MELISSA A. ROBINSON AND 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 -Y/A 1 10 8 - &J. d,;'f 'I/ P EASCIA.A 117 ? I bV-) -k-) -4-k iy ?'. &ACLCS