The URL can be used to link to this page

Home My WebLink About07-6790,t JOSEPH A. LAUCK V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. () IoI q6 611-u?t C7?ZAI CIVIL ACTION - LAW ROCHELLE M. LAUCK 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 grounds 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 17013.3387. 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013.3302 717.249.3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH A. LAUCK Plaintiff NO. 0'7 - 6 -7 9d ? . V. CIVIL ACTION - LAW ROCHELLE M. LAUCK IN DIVORCE Defendant : COMPLAINT IN DIVORCE NO FAULT DIVORCE PURSUANT TO § 3301 (C) OR §3301(D) OF THE DIVORCE CODE AND NOW COMES, JOSEPH A. LAUCK, Plaintiff, who brings this action in divorce against the BONNIE L. MOORE, Defendant, upon a cause of action whereof the following is a statement: 1. Plaintiff, JOSEPH A. LAUCK, is an adult individual residing at 866 Cardinal Lane, Lewisberry, York County, Pennsylvania, 17339. 2. Defendant, ROCHELLE M. LAUCK, is an adult individual residing at 303 16th Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff and Defendant are citizens of the Commonwealth of Pennsylvania, having resided here for a period of more than six months immediately preceding the filing of this Complaint. 4. The parties were married in June 1999. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies. 6. There has been no prior action for divorce or annulment of this marriage instituted by either party in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling and has signed an affidavit attached hereto averring that he does not request such counseling. 8. The marriage of the parties is irretrievably broken. 9. There are two minor children to this marriage; a custody complaint has been filed in Cumberland County. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant will also file such affidavit. WHEREFORE, Plaintiff prays this Honorable Court to: a. Enter a Decree of Divorce under § 3301(c) or (d) of the Divorce Code; and b. Grant such other relief as the Court deems just and reasonable. Respectfully submitted, DATED: l/. D 7 O LAW OFFICES OF LESLI JACOBSON By: Allen D. Moyer • Attorney for Plaintiff No. 81846 8150 Derry Street Harrisburg, PA 17111.5260 717.909.5858 717.909.7788 [fax] 2 i JOSEPH A. LAUCK V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ROCHELLE M. LAUCK Defendant NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT I, JOSEPH A. LAUCK, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in the counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit with twenty (20) days after this affidavit has been served on you or the statements will be admitted. JOSEPH A. LAUCK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. CIVIL ACTION - LAW IN DIVORCE V. ROCHELLE M. LAUCK Defendant VERIFICATION I, JOSEPH A. LAUCK, do hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge and belief. I understand that false statements contained herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. ON THIS, the 7t" day of November, 2007, before me, a Notary Public and the undersigned officer, JOSEPH A. LAUCK personally appeared known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. N RY PUB Co mission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer L. Karr, Notary Public Swatara Twp., Dauphin County My Commission Expires March 7, 2011 Member, Pennsylvania Association of Notaries k V7 r V J S? JOSEPH A. LAUCK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 07-6790 CIVIL TERM V. CIVIL ACTION - LAW ROCHELLE M. LAUCK IN DIVORCE Defendant PRAECIPE TO ADD To the Prothonotary: Please add the attached Certificate of Service to the above captioned case. Thank you. LAW OFFICES OF LESLIE D. JACOBSON By: Allen D. Moyer • ID # 81846 Attorney for Plaintiff 8150 Derry Street Harrisburg, PA 17111.5260 717.909.5858 717.909.7788 [fax] 4w? JOSEPH A. LAUCK V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ROCHELLE M. LAUCK Defendant NO. 07-6790 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Allen D. Moyer, do hereby certify that a copy of the foregoing Complaint in Divorce'was this day served upon the following person in the manner indicted below: CERTIFIED FIRST CLASS MAIL Rochelle M. Lauck 303 16`h Street New Cumberland, PA 17070. DATED: 11.08.07 Allen D. Moyer Attorney for Plaintiff r.; ,., ??-- ?-, _? ? -^? ?:. ?t? , cam= =y ? 1 ??? ?f }} I n '? ? ...?-. i „ ?.Q..e _,a ? pmt -? JOSEPH A. LAUCK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-6790 Civil Term N ROCHELLE M. LAUCK : CIVIL ACTION - IN DIVORCE C °-`ri Defendant Fn t i..._ rn ACCEPTANCE OF SERVICE oa I, Rochelle M. Lauck, hereby accept service of the Complaint in Divorce: No Fault Divorce Pursuant to §3301 (c) of the Divorce Code this 8th day of November, 2007 and certify that I am authorized to do so. Rochelle M. Lauck JOSEPH A. LAUCK • IN THE COURT OF COM MON PLFYS Na Plaintiff : CUMBERLAND COUNTY, PENNS! VA6N v. : No. 07-6790 Civil Term - "' ROCHELLE M. LAUCK : CIVIL ACTION - IN DIVORCE Defendant C=; N) J rr; PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF 00 INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (C) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed the 7th day of November 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice. 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 understand that I will not be divorced until a Decree in Divorce 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;, A/ ' Joseph ALauck ?j JOSEPH A. LAUCK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-6790 Civil Term c a ROCHELLE M. LAUCK : CIVIL ACTION - IN DIVORCE Defendant DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER' -- tv ; { rn § 3301 (C) OF THE DIVORCE CODE N) 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed the 7t' day of November, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice. 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 understand that I will not be divorced until a Decree in Divorce 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: / ` 10 i I&JEe ffl- i'WuCk'i Rochelle M. Lauck s . is. Chad J. Julius The Law Offices of Leslie D. Jacobson Attorneys for the Plaintiff 8150 Derry Street, Ste. A Harrisburg, PA 17111 - 5260 717.909.5858 717.909.7788 (fax) JOSEPH A. LAUCK, Plaintiff V. ROCHELLE M. LAUCK Defendant F7L EL- ,-,- djF 7"f r vi 1 2010 LIAR 12 Pry 1: 10 1 is IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-6790 Civil Term CIVIL ACTION - IN DIVORCE PRAECIPE TO TRANSNIIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint in Divorce on November 8, 2007. (Original Attached.) 3. Complete paragraph (a): (a)(1) Date of execution of Plaintiff's Affidavit of Consent required by § 3301(c) of the Divorce Code: March 1, 2010. (Original Attached.) (a)(2) Date of execution of Defendant's Affidavit of Consent required by § 3301(c) of the Divorce Code: March 1, 2010. (Original Attached.) 4. Related claims pending: None. 5. Complete (a) and (b): (a) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: March 1, 2010. (Original Attached.) J . I*- (b) Date Defendant's Waiver of Notice was filed with the Prothonotary: March 1, 2010. (Original Attached.) Respectfully submitted, THE LAW OFFICES OF LES t DAVID JACOBSON Dated: March 3, 2010 Cha J. Juli s ID# 209496 8150 Derry Street Harrisburg, PA 17111 717.909.5858 717.909.7788 Fax Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Joseph A.Lauck V. Rochelle M. Lauck DIVORCE DECREE AND NOW, /'Z,7 X -,?1-3 , gs,90I0 , it is ordered and decreed that Joseph A. Lauck plaintiff, and Rochelle M. Lauck , 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.") NO. 07-6790 Civil Term By the Court, Att J. Pr thonotary 3•au• l C) Ce-r-v. C-c?pL. Ma;1Q- d o --?; -\-, G, -cCD bsco,n -g -aci - 1 C) -AZ lam cLQ? ,