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HomeMy WebLinkAbout07-4216 • w Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBNEY E. STUBER Plaintiff v. JANET WENTZEL Defendant N0. 07- ~~,~fw CIVIL ACTION -DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS Civil Term 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. ~ r When the ground for 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. BY THE COURT: J 2 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBNEY E. STUBER Plaintiff v. N0. 07- ~~.~ ~ Civil Term JANET WENTZEL Defendant CIVIL ACTION -DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Rodney E. Stuber who currently resides at 26 Warwick Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 since in or around May 2005. 2. Defendant is Janet Wentzel who currently resides at 26 Warwick Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 since in or around May 2005. 3. The parties have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The parties were married on February 17, 2004 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 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. Wherefore, Plaintiff requests the Court to enter a divorce decree under section 3301(c) of the Divorce Code. Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: J u ly 11, 2007 2 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 Na. C.S. § 4904, relatingto unsworn falsecation to authorities. R ney E. Stuber Date: 0 7 ~G ~ C'7 /~.~ ~ ~J _`_~ t~ ` ' . ~'! - "Q ~ ,~ _ ? / ~ ~ _~ ~-~ ;-, ~; _:{i ~_. _-~ ~_-_: rein -;, t-. m t ~; ~ _~ ` r .. ~~:! o :~ ~,;; •-< Q Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 9.7101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBNEY E. STUBER Plaintiff v. N0. 07- 4216 Civil Term JANET WENTZEL Defendant CIVIL ACTION -DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. ~ f ~~~ Ja entzel Date: July , 2007 ~'' ~ ~~` ~ n~~ ~' -~ ~E: ~ _...~ f i t.,. -.~y ~ _ -`~ `"9t~~1 ~ ' _.._ ~h ~ .l 'J __~1t ~~ ~ ^". 0 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RODNEY E. STUBER Plaintiff v. N0. 07-4216 Civil Term JANET WENTZEL Defendant CIVIL ACTION -DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 18, 2007. 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. 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. odney E. Stuber Date: November 6, 2007. 2 ~ ~ Ma ~ a ~°~ ~ +C ~~ k ;+ ~ t ~ ~~- ~.. c.~ C"7 ..:' "^„~ "'~ ~..++ i Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717 233-3220 tbmQtbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RODNEY E. STUBER Plaintiff v. JANET WENTZEL Defendant N0. 07-4216 Civil Term CIVIL ACTION -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 1 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. y 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. odney E. Stuber Date: November 6, 2007 2 N ~ ~~ ~,~, ~ ~ ~ `fit ~ ~ ,~»~` -~.. ~_ ~ ~ Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RODNEY E. STUBER Plaintiff v. N0. 07-4216 Civil Term JANET WENTZEL Defendant CIVIL ACTION -DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 18, 2007. 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. 3. I consent to the entry of a final decree of divorce after service of notice of 0 intention to request entry of the decree. a 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. Ja t Wentzel Date: November 6, 2007 2 C`3 , ~~ ~ .~... ~ , .~-". ~. ti ~ .~ t y.._ -T~ . ~ M,. ~ a) ~ ~ t_' X ? _~.. ~ ! ~+ ~+ H^ y 1 C3 -. Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RODNEY E. STUBER Plaintiff - v. JANET WENTZEL Defendant N0. 07-4216 Civil Term CIVIL ACTION -DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 33O1(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 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. § 4904, relating to unsworn falsification to authorities. Jane Wentzel Date: November 6, 2007 2 r.~ c:a "' ~i ~ ~ Via, ~- 1 ~' t- "~ ~3 t4-. .~ ~. 'V ~- -vi ~~ £ ~ `~ .. •~ -r.d -~C 0 t ~ Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RODNEY E. STUBER Plaintiff v. JANET WENTZEL Defendant To the Prothonotary: N0. 07-4216 Civil Term CIVIL ACTION -DIVORCE PRAECIPE TO TRANSMIT RECORD 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))1~~^'"~"'~" of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Defendant accepted service on August 2, 2007, as confirmed by the Acceptance of Service filed on August 10, 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: November 6, 2007; by defendant: November 6, 2007. ~, -~1 (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: N/A. (2) Date of filing and service of the plaintiff s affidavit upon the respondent:: 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 a copy of which is attached: (b) Date plaintiffs Waiver of Notice was filed with the prothonotary: concurrently with this praecipe. Date defendant's Waiver of Notice was filed with the prothonotary: concurrently with this praecipe. Attorney for Plaintiff Date: November 7, 2007 2 ~ --~ f. ~~ --r ~ ~~-~ = "~ - , „~ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF I PENNA. -=; RODNEY E. STUBER Plaintiff VERSUS JANET WENTZEL Defendant 4216 Civil Term No 2007 DECREE IN DIVORCI~ ..~ r~.'o ~,~•~ . AND NOW, ~~ ~I ~~, IT IS ORDERED AND DECREED THAT AND Rodney E. Stuber Janet Wentzel 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. ATTEST: J. PROTHONOTARY ca~~/ -» c ~ .~~ - ~~ :. ..