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Home My WebLink About07-6350AMY L. RIDER, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * VS. * l * No. D2'-L3 5D Cw?L' ? * JOSEPH F. RIDER, * CIVIL ACTION - LAW Defendant * 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, 1 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 V AMY L. RIDER, Plaintiff VS. JOSEPH F. RIDER, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * NO. * * CIVIL ACTION - LAW * IN DIVORCE COMPLAINT COUNT I - DIVORCE UNDER §33010(6). c or (d) OF THE DIVORCE CODE 1. Plaintiff is Amy Rider, who currently resides at 3523 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Joseph Rider, who currently resides at 3511 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 8, 2005 in Camp Hill, Pennsylvania. 5. The parties are the parents of one (1) minor child: Aspen Payton Rider, born January 21, 2006. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. Plaintiff has been advised that counseling is available and that she may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued. 9. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are: (a) § 3301(a)(6) That the Defendant has offered Plaintiff such indignities as to render Plaintiff's conditions intolerable and life burdensome; and (b) § 3301(c). The marriage of the parties is irretrievably broken; and (c) § 3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time, Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. 10. Plaintiff respectfully requests This Honorable Court enter a Decree of Divorce. WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the marriage between Plaintiff and Defendant. Dated: ksle Respectfully submitted, WIL , LENOX, COLGAN & MARZZACCO, P.C. Angel R e t, Esquire 130 West Church Street Dillsburg, PA 17019 (717) 432-9666 I.D. # 202759 U .10/18/2007 12:34 AMY L. RIDER, 7174320426 Plaintiff VS. JOSEPH F. RIDER, Defendant THE WILEY GROUP * IN THE COURT OF COMMON PLEAS PAGE 06/06 * CUMBERLAND COUN'T'Y, PENNSYLVANIA * NO. * 'CIVIL ACTION - LAW * IN DIVORCE VERMICATION 1, Amy Rider, verify 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 herein are made subject to the penalties of 18 Pa. CS. §4904, relating to unworn falsification to authorities. Date: -? AM Plaintiff ril w V r - CD 1'1 w C AMY L. RIDER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6350 CIVL TERM JOSEPH F. RIDER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 30, 2007. 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 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. §4904 relating to unsworn falsification to authorities. Dated: AMY L. RI , Plaintiff C ra ° `n a" - n cR r J AMY L. RIDER, Plaintiff V. JOSEPH F. RIDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6350 CIVL TERM 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 in 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. Dated: 2 AMY L. R, Plaintiff ra €? ? r r to ?-wt ?, ,? .?..<. .??`,- tr: ? : `v , ?c?f ?? ?;.? Q AMY L. RIDER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-6350 CIVL TERM JOSEPH F. RIDER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 30, 2007. 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 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. §4904 relating to unsworn falsification to authorities. Dated: ? • 2 " d OSEP . RIDER, Defendant 'n t cra AMY L. RIDER, Plaintiff V. JOSEPH F. RIDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6350 CIVL TERM 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 consent to the entry of a final Decree in 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. 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. Dated: / , z " d p SEP RIDER, Defendant C'? t i:I? t/) ?rr, `?C7 ?J ? _ C t4 N < 1' C_: ? , :? .?," ...:? y, AMY L. RIDER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6350 CIVL TERM JOSEPH F. RIDER, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service of Plaintiff s Complaint in Divorce in the above-captioned matter filed on October 30, 2007, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Date: 11/06/07 Joseph F. Rider, Defendant ?>` rv `m.. --? ?, _ :? _-. •?-?x ??, L° ,.,", rs,, LLB;; AMY L. RIDER, Plaintiff v. JOSEPH F. RIDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION o? t"e35o NO. 06-23}8 CIV L TERM Please enter the appearance of Robert B. Lieberman, Esq AMY L. RIDER, in the above captioned divorce action. Date Robert B. L: 500 North T P.O. Box 10 Harrisburg, (717) 236-1, Attorney for as attorney for Plaintiff, man, Esquire Street, 12`x' Floor A 17108-1004 na ?? P-? ?, .. - ' } ? .. w r 1 ? -- -? ?? .114.,.x•` f .,,?,3 (' t?. ''° ;. -] ty.? _ rj? _-? ? r_.J ??. `:? ?? --?: AMY L. RIDER, Plaintiff IN THE COURT OF PLEAS CUMBERLAND CO?OMMON NTY, PENNSYLVANIA CIVIL DIVISION JOSEPH F. RIDER, Defendant dom. c 3s? NO. "-2318 CIVIL PRAECIPE TO TRANSMIT To the Prothonotary: Transmit the record, together with the following information to the court decree: 1. Ground for divorce: Irretrievable breakdown under 3301 (c) 4444-} of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of Complaint: Personally delivered 5 entry of a divorce 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent require by 3301 (c) of the Divorce Code: by plaintiff September 2, 2008, by defendant Se to ber 2 2008. b. (1) Date of execution of the affidavit required by 3301 () of the Divorce Code: V. (2) Date of filing and service of the plaintiff's affidavit 4. Related claims pending: the respondent: Complete either (a) or (b) a. Date and manner of service of the notice of intentior record, a copy of which is attached: b. Date plaintiffs Waiver of Notice in 3301 (c Prothonotary: September 12, 2008 Date defendant's Waver of Notice in 3301 Prothonotary: September 12, 2008 was filed with the (0) was filed with the Robert B. Lieberman, Esquire Attorney r Plaintiff file Praecipe to transmit N ; ?3 .,? i 4 ~ .:» 7 ._ ?? ' ^J `?_ "{„`^ _ ? .. ,. - f i' IN THE COURT OF COMMON PLEAS OF n )4V L' le' D EV?, CUMBERLAND COUNTY, PENNSYLVANIA V. lasePN\ NO. d,7.6356 clot, 'CGAH DIVORCE DECREE '? l d ?o g AND NOW, 4 , it is ordered and decreed that jM Y L . .1 0 E IZ- , plaintiff, and 3 0 T. G fA V. f- 14) itVZ , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") A1,6NC B e Court, Attest: J. Prothonotary ..? +? y `