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Home My WebLink About03-4989PENNSYLVANIA Becky Rovito Pennsylvania Divorce 9/16/2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Beckyann Ritter 141PorterAve. Carlisle, Pennsylvania 17013 SS~: 178-38-3001 Plaintiff Joseph Rovito 2421 Penn St. Harrisburg, Pennsylvania 17110 SS~: 191-46-4551 Defendant VS, No. C,J / 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 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 Plaintiff. You may lose money, property or other rights important to you, including the right to demand marriage counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 LAVVYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE: Dauphin County Bar Association Lawyer Referral Service Dauphin County, Harrisburg,: (717) 232-7536 Page 21 of 26 PENNSYLVANIA Becky Rovito Pennsylvania Divorce 9/16/2003 COUNSELING NOTICE UNDER Pa.R.C.P. RULE 1920.45(a)*( 1 ) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6) Indignities Section 3301 (c) Irretrievable Breakdown Mutual Consent Section 330t(d) Irretrievable Breakdown Two-Year Separation where the court determines that there is a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the: FAMILY DIVISION Administrative Court 1515 Market Street, Suite 1414 Philadelphia, Pennsylvania 19102 215-560-6300 5001 Louise Drive Mechanicsburg, Pennsylvania 17055 717-795-2000 Page?_2of26 PENNSYLVANIA Becky Rovtto Pennsylvania Divorce 9/16/2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Beckyann Rifler SS~: 178-38-3001 Plaintiff Joseph Rovito SS~: 191-46-4551 Defendant vS. : NO. O,.~ : DIVORCE : COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Beckyann Ritter, who currently resides at 141 Porter Ave., Carlisle, Pennsylvania 17013. She has resided at this address at least since June 2003. 2. Defendant is Joseph Rovito, who currently resides at 2421 Penn St., Harrisburg, Pennsylvania 17110. He has resided at this address at least since August 2003. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on 5/18/1994, at Clarence M. Mitchell, Jr. Courthouse, Baltimore, Maryland, County of Baltimore. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. Page 13 of 26 PENNSYLVANIA Becky Rovito Penl~yfvenia Divorc~ Plaintiff (Prb Se) 9/16/2003 Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Beckyann Ritter SS~: 178-38-3001 Plaintiff Joseph Rovito SS#: 191-46-4551 Defendant VS. NO. DIVORCE VERIFICATION I vedfy that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA. C.S., Subsection 4094, relating to unsworn falsification to authorities. Date: Page 14of26 PENNSYLVANIA Becky Rovito Pennsylvania EY~vorce 9/16/2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Beckyann Ritter SS~: '178-38-3001 Plaintiff Joseph Rovito SS#: 19%46-4551 Defendant vs. No. DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Beckyann Rifler, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his own knowledge that the Defendant Joseph Rovito herein is not in the military service as defined in the Solders' and Sailors' Relief Act of 1940 and its Amendments thereto, for the following reasons: At no time during our marriage have I ever witnessed my spouse report to or make contact with military personnel.. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. IN WITNESS THEREOF, I have hereunto set my hand and seal. N O"~ARY PUBLIC NOTARIAL SEAL CLAUDIA A, BREWBAKER, NOTARY PUBLIC Carlisle Bore, Cumberland County My Commission Expires April 4, 2005 Page 16 of 26 PENNSYLVANIA Becky Rovito Penceyfvania Divorce 9/19/2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beckyann RiEer SS~: 178-38-3001 Plaintiff Joseph Rovito SS~: 191-46-4551 Defendant vs. No. 03-4989 DIVORCE Beckyann Ritter, Plaintiff, being duly sworn according to law, deposes and says that Beckyann Rifler is the Plaintiff in the above captioned matter, that the Plaintiff has sent copies of the Complaint, properly endorsed, in Divorce to Joseph Rovito of Harrisburg, Pennsylvania 17110 (by registered mail, postage prepaid, return receipt requested to 141 Porter Ave., Carlisle, Pennsylvania 17013), the Defendant's last known address. SWORN and ~I~.~,CRIBED to b_ef.[g~?~m,e thi{~,,~."~' n day Notar~..J~ubli~ F~aintiff ~ r NOTARIAL SEAL JODY S. SMITH, NOTARY PUBLIC Carlisle Boro, Cumberland County My Corem ss on Expires April 4, 2005 Page 25 of 29 PENNSYLVANIA Becky Rovito Pennsylvania Divorce 9/19/2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beckyann Rifler SS~: 178-38-3001 Plaintiff Joseph Rovito SS~: 191-46-4551 Defendant vs. No. 03-4989 DIVORCE AFFIDAVIT AS TO SIGNATURE Beckyann Ritter, being duly sworn according to law, deposes and says that he is the Plaintiff in the above-captioned divorce; that he is familiar with the signature of the Defendant; and that the signature on the return receipt attached hereto as Exhibit "A" is the signature of the Defendant. IN WITNESS THEREOF, I have hereunto set my hand and seal Dated: ~.~) !c~)! ~)'~ NOTARY(~BLIC Page 26 of 29 ?003 1010 0001 1193 0524 PENNSYLVANIA Becky Rovito Pennsylvania Divorce 1/12J2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Beckyann Ritter SS#: 178-38-3001 Plaintiff Joseph Rovito SS#: 191-46-4551 Defendant vs. No. 03-4989 DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 19th, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unsworn falsification to authorities. SWORN and S,~.~_CRIBED to beforte me this Ic:~'"~day . , NOTARIAL SEAL JODY S. SMITH, NOTARY PUBLIC Cadisle Bore,, Cumber[and County My Commissio,q Expires Apri~ 4, 2005 Page 28 of 41 PENNSYLVANIA Becky Rovito Pennsylvania Divorce 1/17./2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'rY. PENNSYLVANIA FAMILY DIVISION Beckyann Ritter SS~: 178-38-3001 Plaintiff Joseph Rovito SS~: 191-46-4551 Defendant vs. No. 03-4989 DIVORCE ~J ~'~',~ ~ NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301¢c~ DIVORCE DECREE To: Joseph Rovito, Defendant You have signed a section 3301(c) affidavit consenting the entry of a divorce decree. Therefore on or after December 18th, 2003, the other party can request the Court to enter a final decree in divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the day in the paragraph above, or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. LAWYER REFERRAL AND INFORMATION SERVICE PHILADELPHIA BAR ASSOCIATION 1101 MARKET STREET, 11TH FLOOR PHILADELPHIA, PENNSYLVANIA, 19107-2911 TELEPHONE: (215) 238-6333 Page 36 of 41 PENNSYLVANIA Becky Rovito Pennsylvania DNorce 1/12/2004 iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY. PENNSYLVANIA FAMILY DIVISION Beckyann Ritter SS~: 178-38-3001 Plaintiff Joseph Rovito SS~: 191-46-4551 Defendant vs. No. 03-4989 DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 19th, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unsworn falsification to authorities. SWORN and Sy~B:~IBED to befpr~ me this/__.~/day ~ARIAL SEAL JODY S, ~ITH, NOTARY PUBLIC Carlisle Bor6, Cumberland County Exp,, April 4, 2005J Page 30 of 41 PENNSYLVANIA Becky Roy/to Pennsylvania Divorce ~N THieF--AS or t-, ,. ~2~oo4 F MBERLAND C NTY PENNSYLVANIA Beckyann Ritter SS#: 178-38-3001 Plaintiff Joseph Rovito SS#: 191-46-,4551 Defendant VS. No. 03-4989 DIVORCE You have signed a section 3301(c) affidavit COnsenting the entry of a divorce decree. Therefore on or after December 18th, 2003, the other party can request the Court to enter a final decree in divorce. Unless you have already filed with the Court a written claim for eCOnomic relief, you must do so by the day in the paragraph above, or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. LAWYER REFERRAL AND INFORMATION SERVICE PHILADELPHIA BAR ASSOCIATION 1101 MARKET STREET; 11TH FLOOR PHILADELPHIA, PENNSYLVANIA, 19107-2911 TELEPHONE: (215) 238-6333 Page36of41 IN THE COURT OF CC~4ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (b'~ - ~ CIVIL 19 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 3301 ( ..... ' --c ~_~c_ (Strike out inapplicable section) 2. Date and manner of service of the ccmplaint: ~C.~o )~ ~00,~ 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 the plaintiff ~ t' I~--/O~ by the defendant I/~ ~/O~ B. (1) Date of execution of the plaintiff's affidavit requJn?ed by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: ~] O ~ ~-- 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code ~_~ ~ttorney & ~laintiff/Defenda~t IN THE COURT OF COMMON OF CUMBERLANDCOUNTY STATE OF VERSUS PENNA. No. _0~- Hq t5 PLEAS DECREE IN DIVORCE ~ .,..o ,,.,. AND NOW, j IT IS ORDERED AND 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; PROTHONOTARY