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HomeMy WebLinkAbout07-5023GREGORY RHEN, Plaintiff v. KRISTEN D. RHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.: p? - 5aa3 Civ~ I -TTerrn CIVIL ACTION -LAW 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 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. 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 the Cumberland County Courthouse, 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 OFFICES SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 GREGORY RHEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA v. NO.: d ~. ~6 ~ 3 ~~! `Tu.., KRISTEN D. RHEN, :CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 3302 of the Pennsylvania Divorce Code; it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling, please advise in writing promptly by replying to: Prothonotary, Cumberland County Courthouse, Carlisle, PA 17013. 2 GREGORY RHEN, Plaintiff v. KRISTEN D. RHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is GREGORY RHEN, who currently resides at 1927 Deerpath Road, Harrisburg, Pennsylvania, 17110, Dauphin County since June 20, 2007. 2. Defendant is KRISTEN D. RHEN, who currently resides at 430 Woodcrest Drive, Mechanicsburg, Pennsylvania, Cumberland County since June 22, 2007. 3. Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff avers that Defendant has also been a bonafide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 5. Plaintiff and Defendant were married on July 1, 1994, in Las Vegas, Nevada. 6. Plaintiff and Defendant have lived separate and apart since November 28, 2006. 7. There has been no prior action of divorce or annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff avers that neither party is an active member of the United States Military or its allies. 3 10. 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. Being so advised, Plaintiff waives that right. 11. Plaintiff avers that Defendant has been advised of the availability of counseling and that Defendant may have the right to request that the Court require the parties to participate in counseling. 12. Plaintiff avers the grounds for divorce: a. The marriage is irretrievably broken; b. The parties consent to the divorce; or in the alternative, c. The parties have lived separate and apart for a period of two (2) years. WHEREFORE, Plaintiff, GREGORY RHEN, respectfully requests this Honorable Court enter a Decree in Divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. COUNT I -EQUITABLE DISTRIBUTION 13. Paragraphs 1 through 12 above are incorporated herein by reference as though set forth in full. 14. During the marriage, Plaintiff and Defendant have acquired various items of marital property and debt, both real and personal, which are subject to equitable distribution under the Divorce Code. 15. Plaintiff and Defendant are attempting to reach an agreement as to equitable distribution. 16. In the event the parties are unable to reach an agreement, Plaintiff requests that the Court equitably divide all marital property and debt. 4 WHEREFORE, Plaintiff, GREGORY RHEN respectfully requests this Honorable Court equitably distribute all property, both real and personal, tangible and intangible, and debt, acquired by the parties during the marriage. Respectfully submitted, Harrisburg, PA 17110 (717) 657-7770 ATTORNEY FOR PLAINTIFF 5 Supreme Court ID No. 84445 2000 Linglestown Road, Suite 106 VERIFICATION I, GREGORY RHEN, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. ~-~y-~~ GREG EN DATE ~. '~ ~ ~ c'. ~ ~ t~ ~~ v ~ ~ - Q ~ a __- ,.p "'` v ~..i ~~ Y~ ~~1 - l_ ~_'. c~:, ~~ _~ _°r.i ~~ T r~ .~.] {, ~`V. GREGORY RHEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA v. NO.: 07-5023 KRISTEN D. RHEN, :CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Carol Lindsey, attorney for Defendant do hereby accept service of the Divorce Complaint on behalf of Defendant, Kristen D. Rhen, and certify that I am authorized to do so. Date: Z__~ ~' Carol J. Lind , ~ Saidis, Flo r & 26 West Hi tree Carlisle, PA 17013 P.C. ° ~ ~~ ~- ~ ~ ~ a c~ r N ,r c, ~ ~s i + ~~ i~ ~ f ^ ~ f ~ ~i GREGORY RHEN, Plaintiff v. KRISTEN D. RHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.: 07-5023 CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Sectior_ 3301 (c} or 3301 (d} of the Divorce Code was filed on August 22, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90} 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. Section 4904, relating to unsworn falsification to authorities. Date: 1 a~ i ~ 2007 ~ STEN D. RHEN, Defendant ~,,,, ~9 ~--~ .--€ `.~ ~ ,~ ~~ ~ _' . tY•. ..«.. V s l A ~ , ti:;~ .. ; T"• V=~ _'t ,e GREGORY RHEN, Plaintiff v. KRISTEN D. RHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.:07-5023 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 Waiver 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. Date: ~ a ! ~ 2007 STEN D. RHEN, Defendant ,,~~ ... J ~ri ~ ;....~ C ~ ` 'S'1 ~ r ~~ ; f a? ` _ i ~~ , .. 4 r L::~> .; .. ~ _ ~~ GREGORY RHEN, Plaintiff v. KRISTEN D. RHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.: 07-5023 CIVIL ACTION -LAW IN DIVORCE -, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I .~ 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 Waiver 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. Date: f~ O~ ~ , 2007 GREGO N, Plaintiff ~: G ~ ,~- -.. -x YyF q y~,~ w ~i ~~.y[ "'\ GREGORY RHEN, Plaintiff v. KRISTEN D. RHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.: 07-5023 CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) or 3301 (d) of the Divorce Code was filed on August 22, 2007 . 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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. Section 4904, relating to unsworn falsification to authorities. Date; /~'a8 , 2007 GREG N, Plaintiff ~+i .,.r .t"' ~~ ~~~` ~ ,~ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~;., ~_~ GREGORY RHEN N o. 2007 VERSUS KRISTEN D. RHEN DECREE IN DIVORCE 5023 AND NOW, ~'V *~`~i.~,, IT IS ORDERED AND DECREED THAT Gregory Rhen AND Kristen D. Rhen ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAlN5 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. A Property Settlement and Separation Agreement dated August 3, 2007 is attached herein by reference, but not merged into the - ~, Divorce Decree. BY TH ATT E ST:~ ~ I~_ J. PROTHONOTARY ~ ~"~~ ~!~ ~. s ~.