The URL can be used to link to this page

Home My WebLink About07-4663PATRICIA C. ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY W. ROTZ, Defendant. CIVIL ACTION- 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 may proceed without you and a decree of divorce or annulment maybe 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Dauphin County Courthouse, Front & Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH THE 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 Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 PATRICIA C. ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. BRADLEY W. ROTZ, Defendant. CIVIL ACTION- DIVORCE AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notification de esta Demands y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicano en la Corte por escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se le advierte de que si usted falls de tomar accion Como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demands o caulquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importances pars used. SED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 GERALD S. ROBINSON, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 27432 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 -Phone (717) 232-5098 -Fax grobinson@robinson-geraldo.com PATRICIA C. ROTZ, v. BRADLEY W. ROTZ, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE COUNTI 1. Plaintiff is Patricia C. Rotz, who currently resides at 366 Maple Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Bradley W. Rotz, who currently resides at 6476 Spring Road, Shermansdale, Perry County, Pennsylvania 17090. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The parties were married on the 9th day of April, 2005, in Carlisle, Pennsylvania. 5. Neither Party is a member of the Armed Forces of the United States or any of its allies. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. 8. The marriage is irretrievably broken. 9. Defendant has offered such indignities to Plaintiff (who is the innocent and injured spouse) as to render Plaintiff s condition intolerable and life burdensome. 10. This action is not collusive as defined by § 3309 of the Divorce code. WHEREFORE, defendant respectfully requests the Court to enter a decree of divorce pursuant to §3301 of the Divorce Code. COUNT II -CUSTODY 11. Plaintiff incorporates by reference paragraphs 1 through 10 of the Complaint for Divorce as fully set forth herein. 12. There was one child born during this marriage, to wit: Paige C. Rotz, born 5/24/2006. 13. The child has resided with the following persons and at the following address since birth: Persons Address Dates Both parties 366 Maple Lane Birth to 7/6/2006 Carlisle, Pa 17013 Mother 366 Maple Lane 7/6/2006 to present Carlisle, Pa 17013 14. The Court of Common Pleas of Cumberland County, Pennsylvania, Family Division, has the sole and exclusive jurisdiction in this matter, pursuant to the Uniform Child Custody Jurisdiction Act for the following reasons: a. Cumberland County, Pennsylvania, has been the child's home county for the six (6) months preceding the commencement of the instant proceedings. b. It is in the best interest and welfare of the child that the Cumberland Court of Common Pleas of County, Pennsylvania, assume jurisdiction because the child has a significant connection with this jurisdiction, and there is available in this jurisdiction substantial evidence concerning the child's present or future care, protection, training and personal relationships. c. No other state has jurisdiction in this matter under the requirements of the Uniform Child Custody Jurisdiction Act and the Commonwealth Child Custody Jurisdiction Act. 15. The Plaintiff has not participated in any capacity whatsoever in any other litigation concerning the custody of the minor child in this or any other state. 16. The Plaintiff does not know of any other person other than the Defendant herein who claims to have custody or partial custody rights with the minor child. 17. The Plaintiff submits that it is in the best interests and welfare of the minor child that she be granted primary physical custody of the minor child, subject to Defendant's periods of partial custody. WHEREFORE, Plaintiff prays that this Honorable Court grant custody of the minor child of the parties to Plaintiff. Respectfully submitted, ROBINSON & GERALDO Date: ~~`~~ By. _ G ald S. Robinson, Esquire Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint 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. '~~; ~~. c ~ ~sh~ Patricia C. Rotz ~ ~ ~ .~, `~ ~ ~- ~.,? ~ '~' ~ ~ ~: f 3 C3 ~ O ~ ~ ~• ~ j... j y~~ ~" -"Y,F ~/ ~ O f nn`` T'~ ~M r ~~~ ~~ r.~~ ~ ~ + ~ W ~~ ~ ~ PATRICIA C. ROTZ iN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v. BRADLEY W.ROTZ DF..,FENDANT • 07-4663 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, August 13, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 18, 2007 at 1:00 PM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference maY provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn .Man an r. Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~ ~ ~ '~~~~ ~~~ ~9~~/ ~ PATRICIA C ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4663 BRADLEY W. ROTZ, Defendant. CIVIL ACTION- DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Divorce Complaint was served upon Bradley Rotz on August 21, 2007 at 6476 Spring Road, Shermans Dale, Perry County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service 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 falsfication to authorities. Respectfully submitted, ROBIN50N & GERALDO Dated: August 22, 2007 By: erald S. obmson, squire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ^ Complete items 1, 2, and 3. Also complete item 4 if Resbicted DeUvery is desired. i ^ Print your name and address on the reverse so that we can return the card to you. ^ Alrach this card to the back of the mailpiece, or on the front if space permits. 1. /Mlicle addressed to: Brad lei W ' Ro~'z (p'~ 7i/ Sp~~ri~ Qoa ot- Shtrma~ sc~G. t~, P/a- t ~o~ q A. Signature X "~. ~ ^ agent , Received by (Pifr-ted Marne) .gate of DaNwrr ~Y i?oT~ v D. is delNery address. different ttom item 1? ^ Yes ff YES, enter delivery address below: 3. Service Type C?e4 Mail ^ E~ rose Mail M" Iatered ^ insured MaN ^ C.O.q. 2. ~ 70tH 194A ^Oa4 1686 9363 rng,-sfe. tram seN~ce ~aaeil PS Form 3811, February 2004 l)ornMtlc RKurn Receipt 1oz585-02-M-1540 EXHIBIT D s n , r~ ~ -^i "C' ~..r ~ C. " 4.,., f `__ 'r^ (c w :~ ~~ ;~ ~ . PATRICIA C ROTZ, v. BRADLEY W. ROTZ, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4663 CIVIL ACTION-DIVORCE PROOF OF SERVICE SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this The undersigned makes the following return of service: the Order for Custody Conciliation Conference was served upon Bradley Rotz on August 21, 2007 at 6476 Spring Road, Shermans Dale, Perry County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. action. I verify that the statements made in this affidavit and return of service 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 falsfication to authorities. Respectfully submitted, ROBIN50N & GERALDO Dated: August 22, 2007 i •: ` . By r''~ Gerarl .Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 1 7 1 1 0-5320 (717) 232-8525 Attorney for Plaintiff ,~: ^ Complete items i, 2, and 3. Also complete item 4 if ResMcted Delivery is desin3d. ^ Print your name and address on the reverse stf that we can return the card to you. /teach this card to the back of the mailpiece, or on the front if space pertrtits. 1. Artlcle Addressed to: 6~adjcy ~o~ (o`~ "1 L Srxtnq Roams Sherr~rs~a~e~ P~+- l~e~q A. Signature X ~~~---c~C~i~--~"7~-~6 B. f3~e~ce~N~ed~by~(PIIMed Marne)- I C. j~tM lpD~a~y ~k-R4x~it~~ 1~ iU111 X11 D. Is delivery address different from Item 1? ^ Yes M YES, enter delivery address bebw: ~[Jo 3. Servbe Type (a~ertflfed Mail ^ Express Mail 47'fiagistered ^ Irraxed MaU ^ C.O.D. - ailr 2. ArtidelJumber 7pny 1940 QQ04 2686 9349 ' (Aansfer from servk;e label) _ P3 Form 3811, February 2004 Dortrsetlc Hednn ReoNpt 102595-02-M-1540 EXHIBIT ~... y ~,r !F ~ -^`# i J) .,A.-r 3~ai ... y ,.,, - _>l: .. __._ PATRICIA C. ROTZ, Plaintiff, v. BRADLEY W. ROTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-4663 CIVIL ACTION -LAW CUSTODY CUSTODY STIPULATION THIS AGREEMENT, made this ~~~day of ~ ~ , 2007, by and between Bradley W. Rotz, hereinafter referred to as "Father," and Patricia C. Rotz, hereinafter referred to as "Mother." WITNESETH WHEREAS, Bradley W. Rotz and Patricia C. Rotz are the natural parents of Paige C. Rotz, a minor child born on May 24, 2006; and WHEREAS, the parties have reached an agreement concerning the issues of custody and desire that this Stipulation be entered as Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, the parties hereby agree as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of the subject minor child. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. 1 a Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the parent then having physical custody. With regard to any emergency decisions, which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that pazent shall inform the other of the emergency and consult with him or her as soon as possible. Each pazty shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S. 5309. 2. Mother shall have primary physical custody of the subject minor child. 3. Father shall have periods of partial custody on an alternating weekly basis as follows: a. Week one (I) shall begin at 5:30 p.m. Wednesday evening and extend until Friday evening at S:30 p.m., and b. Week two (2) shall begin on Wednesday evening at 5:30 p.m. and extend until Saturday evening at 5:30 p.m. 4. The parties will alternate the following holidays beginning with Labor Day in 2007: • New Year's Day • Easter • Memorial Day 2 . .~ • July 4`~ • Labor Day • Thanksgiving The custodial period shall run from 7:00 p.m. the night preceding the holiday and extend unti17:00 p.m. the day of the holiday. On odd numbered years, Mother shall have the child for New Year's Day, Memorial Day, and Labor Day, and Father shall have Easter, July 4`~', and Thanksgiving. On even numbered years, Mother shall have Easter, July 4`~, and Thanksgiving and Father shall have custody of the child on New Yeaz's Day, Memorial Day, and Labor Day. Christmas will be divided into two segments. These segments will alternate with the other holidays. Segment A is from December 24a' at 1:00 p.m. until December 25~' at 1:00 p.m. Segment B is from December 25a' at l :00p.m. until December 26~' at 1:OOp.m. This schedule shall commence with Mother having the child for Segment A in odd numbered years and Father having Segment B. For even numbered years, during the Christmas holiday, Mother shall have the child for Segment B and Father shall have the child for Segment A. Father shall have custody on Father's Day and Mother shall have custody on Mother's Day. 5. Beginning in 2008, the parties shall each be entitled to one full week for summer vacation. It is understood that a week is defined as seven (7) days. The holiday schedule shall take precedence over the regulaz custody schedule. 6. The party whose custodial period is about to commence shall provide transportation. 3 7. All parties shall refrain from making derogatory comments about the other party in the presence of the children and to the extent possible shall prevent third parties from making such comments in the presence of the children whether "steeping" or awake. 8. During any period of custody or visitation, the parties to this Stipulation shall not possess or use any controlled substance; neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition. 9. Each party shall be entitled to reasonable telephone or a-mail contact with the child when he is in the custody of the other party. The parties shall provide to one another emergency contact telephone numbers. 10. Neither party shall relocate from a current address if such relocation will necessitate a change in the custody schedule as set for forth in the Order, or if the relocation will be to a location in excess of fifty (50) miles from the other party's then current address without (a) such party's first giving prior written notice to the other party not less than sixty (60) days prior to the planned relocation, and (b) either a written consent of the other party to such relocation or further Order of this Court. In the event of any intended relocation, either party may seek modification of the terms of this custody Order by filing a Petition to Modify Custody with the Prothonotary. 4 11. It is understood and stipulated that by the parties that upon mutual agreement an expanded or altered schedule maybe agreed upon between the parties and that such altered or expanded agreement would be in the best interest of the child. 12. The parties agree to supply the other with his or her complete contact information, including but not limited to residential address, cell phone numbers, home telephone numbers, and employers' telephone numbers. Should any of the aforementioned information change, each party has five (5) days from the date of the change to notify the other party. Each party shall make every reasonable effort to ensure they can reach and be reached by the other party concerning issues relevant to the minor children. 13. Should either party have the child spend overnight at a place other than their primary residence, the other party will be given the address and telephone number where the child is spending the night. 14. The parties shall organize ways for their children to maintain their friendships, extracumiculaz activities and other special interests, regardless of which household they maybe in. 15. The parties agree to refrain from encouraging the child to provide reports about the other party. Communication should always take place directly between the parties, without using the child as an intermediary. 5 . ~ ~ ~ 16. The parties agree that the child should be protected fram individuals with poor character (including, but not limited to, individuals involved with illegal activity, immoral or intemperate behavior or violent propensities). The parties shall, to the extent possible, avoid contact with such individuals bf poor character. 17. The parties shall permit and support the children's access to family relationships and events (funerals, reunions, graduations, etc.). Events will be accommodated by both parties with routine periods of custody resuming immediately thereafter. Each party shall have the option of proposing time or date variations to the other party when special recreational options or other unexpected opportunities arise. IN WITNESS WHEREOF, the Parties hereunto set their hands and seals the day and year first above written. _ Otis-y+~ W' ess fitness Patricia C. Rotz Bradley W. tz 6 Q t1~ ~ ~r ~ 3 r. ~ ~" '~ ' ~ SEP 132D01 ~ ~~ PATRICIA C. ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. N0. 07-4663 BRADLEY W. ROTZ, CIVIL ACTION -LAW Defendant. CUSTODY ORDER OF COURT AND NOW, this / 3 ~ day of ~ t~~[.cr , 2007, it is hereby ORDERED and DECREED that the attached Stipulation for Custody is entered as an Order of this Court. BY THE COURT: Distribution: D. Wassmer, Esquire, 4407 North Front Street, Harrisburg, PA 17110, Attorney for Plaints C~ 1~,5 AL`d l dley W. Rotz, 6476 Spruig Road, Shermansdale, Pa 17019, Pro Se ~Q/~3`~? l l ~~ ~~~~~ ~. ~ =~ Wd ~ ~ c~~~ ~~~~ 1~:lC~N~i-~1Cl~d soli. ~0 PATRICIA C. ROTZ, Plaintiff, v. BRADLEY W. ROTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4663 CIVIL ACTION- DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce code was filed on August 6, 2007, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 5. 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: February 7, 2008 ~~~-~~ Patricia C Rotz G"~ ^.a c:_ ° ~ ~ ~ ~F ~; ,trt , , -,-~ ~ ~ ~~ ~ . W 4.J ~..~"~ ~ V 'yy f/ s .. ~~ n~~ ~/r ~+..~J ~. + °" PATRICIA C. ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4663 BRADLEY W. ROTZ, Defendant. 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 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: February 7, 2008 ,~- o ~ C~ Patricia C Rotz, Plaintiff r-~ ~ ~ ~.-! •.~"1 "spry ^,~'~ r 1 ~ ~.~+` .,,.. ~ ikw; ut . _ ~ f... T ` l ..x, t'i ~~ A e PATRICIA C. ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4663 BRADLEY W. ROTZ, Defendant. CIVIL ACTION- DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce code was filed on August 6, 2007, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements hcreir~ are ~radc subject to the penalties of 8 Pa.C.S. ~ 4904 relating tG unsworn falsification to authorities. Date: February 7, 2008 Bra ley W. na n ~~~, -w - . _ _ : - :: ~ _... .~ ~ . , "~ ,:.~§ I s ; ~«~ 4 .~ ~ PATRICIA C. ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. BRADLEY W. ROTZ, Defendant. NO. 07-4663 CNIL ACTION- DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 330~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. Date: February 7, 2008 Lt~ Bradley W. l~.otz, Defen C') ~, cT.x -ri ~~~ ' r_ . ~ .,,,~- _~; `_ «.:a_~ ~ L e ~.:v :~' ~." :w~ rya i~ PATRICIA C. ROTZ, v. BRADLEY W. ROTZ, To the Prothonotary: IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4663 Defendant. CIVIL ACTION- DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under section 3301(c) of the Divorce code. 2. Date and Manner of service of the Complaint: Certified Mail Restricted Delivery on or about August 21, 2007. 3. Date of execution of the affidavit required by section 3301(c) of the Divorce Code: by Plaintiff on February 7, 2008 and by Defendant on February 7, 2008. 4. Related claims pending. The economic and custody claims have been settled by agreement. 5. Date the Plaintiffs Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: on February 19, 2008. -.. 6. Date the Defendant's Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: on February 19, 2008. Respectfully submitted, ROBINSON & GERALDO By d.._... ,~ Jai D. Wassmer, Esquire Att ey I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff. (-`, } h3 .:. a s: }::7 ~~ ~ ~ ` r;;,~ _.- , ' t i ; .T_7 r_ 1'~J '~i -~ :, b-• , ..,.. ~ .. _ ,: f....r I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. _;~~ - _ PATRICIA C. ROTZ II N O. Q7-4663 Plaintiff VERSUS BRADLEY W. ROTZ Defendant DECREE IN DIVORCE AND NOW, ~fi()ry -Zgr za~8 IT IS ORDERED AND DECREED THAT PATRICIA C. ROTZ PLAINTIFF, AND BRADLEY W. 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; The parties have resolved ell outstanding claims and any claims which have not been raised are hereby waived. E o,r~ , Gam' ?~~ •~~_~ > ~ ~ °, .~, s:~ .. PATRICIA C ROTZ, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4663 BRADLEY W. ROTZ, Defendant. CIVIL ACTION- DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff, Patricia C. Rotz, in the above matter, having been granted a Final Decree in Divorce on the 28`h day of February, 2008, hereby elects to resume the prior surname of Potteiger, and gives this written notice pursuant to the provisions of 54 P.S. § 704. Date: _I~.~~CJ1 C~ _ ~~ Signature ~G~~E 1 11C~ ~C~ T~CL~~j Q~ Signature of name being resumed ~J COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND ( . On the ~ day of I f , before me, a Notary Public, personall Y appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that s/he executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Goh4iVlfJNV4EALTH of PENNSYLVANIA Natar+`al Seal Jennifer ~,. Grave, Nofary Public Silver Sgrinc~ T,v~., C~~mber'and County Nota ~ Public my ~'.omrr~:ssF~r: Eac,7ires Jan. ~~, 2Q?2 Member, Penra~ylvanta Assoclaiinn of Notaries -{,~- ~ ~ a ~ ~' O ~ ~ ~--~ s: ~ . ~- ~ - :~-~ -,z ~ O ~ 'U ~ -rt ~ ~ ~ , - : - i z~ . Q . ; ~. . ~;. , av ~ ,~ ,r ~ k ._..,.>.. ~'~ -~~ .i~ ~: ^'i