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HomeMy WebLinkAbout03-5237YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : _. : 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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 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 Court of Common Pleas, One Courthouse Square, 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 OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : : NO. .. .. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe romar action con prontitud, se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede set emitido en su contra por las Corte. una decision puede tambien set emitida en su contra pot caulquier otra queja o compensacion eclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. ,_ : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE And now comes Plaintiff, Yvoune C. Risser, by and through her attorneys, Law Offices of Craig A. Diehl, and files this Complaint in Divorce, respectfully stating in support thereof the following: 1. Plaintiff is Yvonne C. Risser, an adult individual who currently resides at 1517 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Robert A, Risser, an adult individual who currently is incarcerated at the Cumberland County Prison at 1101 Claremont Road, Carlisle, Pennsylvania 17013. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Divorce Complaint. 5. Plaintiff and Defendant were married on April 20, 2002, in Cumberland County, Pennsylvania. 6. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since July 3, 2002. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Defendant is not a member of the armed fomes of the United States or any of its allies. 9. Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff prays this Honorable Court enter a Decree in Divorce and granting such other relief as this Court deems just and proper. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Dated: q]l'l],l.O~a) B '.~'~_J(~/~ [ L'inda A. Clotfelter, Esquire [ A,3omey ID No. 72963 x,~464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, YVONNE C. RISSER, verify that the statemems in the foregoing DIVORCE COMPLAINT are true and correct to the best of my knowledge, information and belief. 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: ~NNE C. RISS~R, Plaintiff YVONNE C. RISSER Plaintiff VS. IN THE COURT OF COMMON PLEAS O F CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5237 CIVIL TERM ROBERT A. RISSER, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Kindly reinstate the complaint in the above-captioned proceeding. Date: 11/7/0~ Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Camp Hill, PA 17011 (717)763-7613 Attorney for Plaintiff YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-05237 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Linda A. Clotfelter, Esquire, counsel for Plaintiff, Yvonne C. Risser, do hereby affirm that the original return receipt of the Complaint in Divorce sent by Certified Mail, Restricted Delivery, Return Receipt Requested, which return receipt appears to contain the signature of Robert A. Risser, is set forth below. The undersigned understands that the statements herein are made subject to the penalties of 18 P.S. § 4904 relating to unsworn falsification to authorities. Dated: .11 1 oo3 LAW OFFICES OF CRAIG A. DIEHL (717) 763-7613 YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-05237 CIVIL TERM : : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on this date, a true and correct copy of the foregoing document was served upon the opposing parties by way of United States First Class Mail, postage prepaid, addressed as follows: Robert A. Risser 315 Hemlock Road Mechanicsburg, PA 17055 LAW OFFICES OF CRAIG A. DIEHL Date: II/l~/l)~ Cl~a'cy(4(. Jay, U4eg~at~ssistant 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-05237 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE &FFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 3, 2003. 2. The marriage of 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 ora final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses ifI 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 are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date:~ -/~'-- 0.~ ~ant YVONNE C. RISSER, Plaintiff ROBERT A. RISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : .. : NO. 03-05237 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE A~FFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 3, 2003. 2. The marriage of Plaintiffand 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 ora final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses ifI 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 are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ONNE C. RISSER, Plaintiff YVONNE C. RISSER, Plaintiff VS. ROBERT A. RISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03~05237 CIV/L TERM : CIVIL ACTION. LAW · IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE U.__NNDER § 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that ! may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 unswom falsification to authorities. Date: SSER, Defendant YVONNE C. KISSER, Plaintiff VS. ROBERT A. KISSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · NO 03 05237 CIVIL TERM .. : CIVIL ACTION. LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (C) OF THE DIVORCE CODI,_; 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 ifI 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. ~/YONNE C. RISSEP~, Plaintiff YVONNE C. PASSER, Plaintiff VS. ROBERT A. PASSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ._ : NO. 03-05237 CIVIL TERM ._ : CIVIL ACTION - LAW : IN DIVORCE pRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: I. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint was filed on October 3, 2003. 3. Date and manner of Service of the Complaint: Certified Mail, Return Receipt Requested, Restricted Delivery on November 15, 2003, as evidenced by the Acceptance of Service filed on November 20, 2003. 4 The Plaintiffs Affidavit .o,f Consent was executed by the Plaintiff on February 15, 2004, and filed onFebruary 18, 2004. The Defendant s Affidavit of Consent was executed °nFebruary 15 2004, and filed on February 18, 2004. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under ivorce Code on February 15, 2004, and said waiver was filed on February 18, 2004. Defendant 3e3x~u(tCld°af~v'Dver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c)of the Divorce Code on February 15, 2004, and said waiver was filed on February 18, 2004. There are no related claims pending. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Camp Hill, PA 17011 (717) 763-7613 IN The cOURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF YVONNE C. RISSER, Plaintiff VERSUS ROBERT A. RISSER, Defendant PENNA. N o. 03-05237 Civil DECREE IN AND NOW, DIVORCE 2004 , IT IS ORDERED AND DECREED THAT AND YVONNE C. RISSER ROBERT A. RISSER _,PLAINTIFF, _,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; None. ATTEST: