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HomeMy WebLinkAbout07-4562LISA M. RHONE, vs. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA No. p ~ _ yr~~ Civil Term ACTION IN DIVORCE CHRISTOPHER T. RHONE, Defendant 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 +- LISA M. RHONE, Plaintiff vs. CHRISTOPHER T. RHONE, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ©~ - `~`~ G '~' Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Lisa M. Rhone, a competent adult individual, who has resided at 957 Ridge Road, Shippensburg, Cumberland County, Pennsylvania, 17257, since 2003. 2. Defendant is Christopher T. Rhone, a competent adult individual, who currently is believed to reside in Franklin County, at 6533 Mountain Drive, Chambersburg, Pennsylvania, 17201. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 20, 2001, in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. • 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, 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. 'sa M. Rhone, Plaintiff Respectfully submitted, Date: '~ 'i?j ~ , Q e Adams, Esquire ~.D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF N C ° W <', Zp tip.', ~ _ ; ~~ r ~ ~ ~ ' G'~ PT? ?~ m V i a'.'": ~ ~ ~ \.r' `/~ .~ / '~ ~ ~ ~-' N <~ n-t ~ ~ ~ v ~ ~ IN RE: LISA M. RHONE IN THE COURT OF COMMON PLEAS OF V CUMBERLAND COUNTY PENNSYLVANIA CHRISTOPHER T. RHONE CIVIL ACTION IN DIVORCE . N0.07-4562 AFFIDAVIT OF PERSONAL SERVICE On this, 8~' day of August 2007, I, ROBERT W. LINDSAY, PENNSYLVANIA STATE CONSTABLE, hereby certify that I personally served Divorce Notice on Christopher T. Rhone by handing him a copy of said Notice at Chambersburg Hospital at 4:50 P.M. I, ROBERT W. LINDSAY, PENNSYLVANIA STATE CONSTABLE, verify that the statements made in this affidavit 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.A, Section 4904 relating to unsworn Date, 9~' day of August 2007 iJ~/ obert .Lindsay Pevly State Constable Sworn to and subscribed before me this day of August, 2007 `~ C> ~. ~ ~ f ~ '~" i = m~ ~~~ ~ ` ~"; ~'_ . > ~~ =4?rn jai ~: 4 ' . C ~ . '~ ~ ..G, LISA M. RHONE, V. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ ~ - Lj ~1p ~ CIVIL TERM CHRISTOPHER T. RHONE, Defendant To the Prothonotary: ACTION IN DIVORCE NOTICE TO RESUME PRIOR SURNAME. Notice is hereby given that the Plaintiff in the above matter: _X_ prior to the entry of a Final Decree in divorce. OR after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of HOCKENBERRY avowing her intention pursuant to the provisions of 54 P.S. s704. Date: ~' , ' . D sa M. Rhone Prior Name Lisa M. Hockenberry Signature of Name being r s COMMONWEALTH OF PENNSYLVANIA ) )as COUNTY OF CUMBERLAND ) On this, the ~ day of ~ , 2007 before me, the undersigned officer, personally appeared LISA M. RHONE/L~~OCKENBERRY ersonall known to me or p Y ,( satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEAL~E~gy~ VAS tart' Public Jane A ~uNic carlisk Bolo, Canty My commission expires: .. My Commission Facpires Sep[. 6, 2008 - -_.. ~ - «~ c. ~ , -~ c s ~, ~ j . , rte,/.] 'fir t. :.~ ate ,, «.+y , . . ~ ~ .,, • ` `` LISA M. RHONE, vs. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 4562 Civil Term CHRISTOPHER T. RHONE, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on August 1, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 49Q4, relating~unsworn falsification to authorities. Date: ~~-~~ -~ 7 T. Rhone, ~fendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301(c) AND $33011d) OF THE DIVORCE CODE 1. I consent to 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 rela ' g to unsworn falsification to authorities. Date: ,~_ ~~ ~ ~'~ ~ Ch ~ pher T. Rhon efendant O c 't3 ":` t ~ " v ~ "~7 t-. _~ . ~ ~ •~ C iry ~:~ t~~-:,~ ,` r... t~j ~ ;~rl ~~', ?sr ~~-~,CT.~ ~ ~~ ~ ~rn ~ s- °D -c IN RE: LISA M. RHONE IN THE COURT OF COMMON PLEAS OF V CUMBERLAND COUNTY PENNSYLVANIA CHRISTOPHER T. RHONE CIVIL ACTION IN DIVORCE . N0.07-4562 AFFIDAVIT OF PERSONAL SERVICE On this, 8~' day of August 2007, I, ROBERT W. LINDSAY, PENNSYLVANIA STATE CONSTABLE, hereby certify that I personally served Divorce Notice on Christopher T. Rhone by handing him a copy of said Notice at Chambersburg Hospital at 4:50 P.M. I, ROBERT W. LINDSAY, PENNSYLVANIA STATE CONSTABLE, verify that the statements made in this affidavit 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.A, Section 4904 relating to unsworn Date, 9~' day of August 2007 ~~,,1,= . Lindsay State Constable Sworn to and subscribed before me this day of August, 2007 C7 ~ C c.+ Ti ~. L'': '~ ~' G'f -==' O ''= ~~ .. ~.~ x~ ~- -r-~ r~r ~ .~ ~ - a ~ - LISA M. RHONE, vs. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER T. RHONE, Defendant No. 07 - 4562 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on August 1, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 1 verify that the statements made in this affidavit are true and correct. I also 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~ L' M. Hockenberry, Plaintiff f/k/a Lisa M. Rhone WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 633011c) AND §3301(d) OF THE DIVORCE CODE 1. I consent to 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. Date: LI - ~ " t~~ ' L' M. Hockenberry, P aintiff f/k/a Lisa M. Rhone °cr~ ° =r. s_' / .:- Cam"' [" ~' ~~. ~.1 y., ~" ~~~j Q1~"'+ ~' ~ p N ..-t LISA M. RHONE, vs. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER T. RHONE, Defendant No. 07 - 4562 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please 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 of the Divorce Code. 2. Date and manner of the service of the Complaint: Via state constable, served on August 8, 2007, affidavit of personal service filed on August 10, 2007. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: April 3, 2008 By Defendant: November 15, 2007 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 19, 2007. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 7, 2007. Date: /,~ 7 (~~ Respectfully S Ja Ada`ms, Esquire I No. 79465 7 W. South St. arlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff -vim'. ?~ t ~ ~. I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. td . Lisa M. Rhone, Plaintiff ~,; ~ ~~ __ I I No. 07 - 4562 Civil Term NO. VERSUS Christopher T. Rhone, Defendant DECREE IN DIVORCE AND NOW, ~nf~ ~y ZOa~ IT IS ORDERED AND Lisa M. Rhone DECREED THAT Christopher T. Rhone AN D 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. BY THE OURT: ATT E S J PROTHONOTARY Y ~