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HomeMy WebLinkAbout03-5617CHRISTINA R. ROGERS, V. WILLIAM G, ROGERS, Plaintiff : : : CIVIL ACTION: LAW : NO. : Defendant : DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE TO DEFEND AND CLAIM RIGHTS TO: William G. Rogers c/o Theresa Barrett Male 513 North Second Street Harrisburg, PA 17101 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. When the ground for divorce is indignities or irrelrievable breakdown of the marriage, you may request man/age counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, PA 17013 1(800) 990-9108 #289521 CHRISTINA R. ROGERS, V. WILLIAM G. ROGERS, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION: LAW NO. 03 - ~'~,,/7 DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Christina R. Rogers, is an adult individual currently residing at 929 Nixon Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, William G. Rogers, is an adult individual currently residing at 1408 Henderson Ridge, Olive Hill, Kentucky, 41164. 3. Defendant, William G. Rogers, is a Sergeant with the 101st Airborne Division currently stationed in Mosul, Iraq. 4. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately prior to the filing of this Complaint. 5. Plaintiff and Defendant were married on September 18, 2000, in Jefferson County, New York. 6. Defendant is in the United States Army, thereby falling under the provisions of the Soldiers and Sailors Civil Relief Act of the Congress of 1940 and its Amendments, and has agreed to waive protection of said Act. 7. Plaintiff's Social Security number is 203-60-3920; Defendant's Social Security number is 524-87-9798. 8. There have been no prior actions of divorce or for annulment between the parties. #289521 10. 11. 12. 13. Defendant. 9. Plaintiff has been advised that counseling is available, and that Plaintiffmay have the right to request the Court require the parties to participate in counseling. There was one child bom of this marriage: William H. Rogers (d.o.b. 04/12/01). The marriage is irretrievably broken. The parties have been living separate and apart since April 1, 2003. Plaintiff requests the Court to enter a degree of divorce, divorcing Plaintiff and WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and any such other orders that are appropriate and just. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: #289521 -2- VERIFICATION I, Christina R. Rogers, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to anthorities. Date: #289521 0 Theresa Barrett Male Supreme Court # 46439 53.3 North Second Street Harrisburg, PA 3.7103. (7~.7) 233-3220 Counsel for Defendant CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA R. ROGERS Plaintiff WILLIAM G. ROGERS Defendant COURT OF COMMON PLEAS OF : NO. 03-5617 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 330~.(c) of the Divorce Code was filed on October 24, 2003. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Date.~ ~~~, 2004 William G. Rogers Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Defendant CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA R. ROGERS Plaintiff WILLIAM G. ROGERS Defendant COURT OF COMMON PLEAS OF NO. 03-5617 Civil Term I consent to the entry of a final decree of divorce without notice. 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 unswern falsification to authorities. - ,, -vu .... ~/ ~ William G. Rogers Date: g ~o ~ ~ ~072~04 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE CIVIL ACTION - DIVORCE CHRISTINA R. ROGERS, V. WILLIAM G. ROGERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION: LAW NO. 03-5617 CIVIL TERM Defendant : DIVORCE AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff Christina R. Rogers in the above-captioned divorce action, hereby certify that a tree and correct copy of the Complaint in Divorce was served upon Defendant's counsel, Theresa Barrett-Male, Esquire, on November 14, 2003. Attached hereto, marked as Exhibit A, and incorporated iherein by reference, is the Acceptance of Service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (7173 238-8187 Attomeys for Plaintiff 303193-1 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel For Defendant COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA CHRISTINA R. ROGERS : Plaintiff : : v. : NO. 03-5671 Civil Term : WILLIAM G. ROGERS : Defendant : CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. ~ certify that I am authorized to accept service on behalf of defendant. Theresa Barrett Male, Esquire Theresa Barrett Male Supreme Court # 46439 5't3 NorLh Second Street Harrisburg, PA :17~.01 (7:17) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA R. ROGERS Plaintiff V. WILLIAM G. ROGERS Defendant NO. 03-5617 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on October 24, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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. ! Chris[ina R. Rogers '~J Date: ~/0~ ,2004 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA R. ROGERS Plaintiff V. WILLIAM G. ROGERS Defendant NO. 03-5617 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on October 24, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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. Christina R. Rogers Date: t///,~,/O L/ , 2004 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA R. ROGERS Plaintiff V. WILLIAM G. ROGERS Defendant NO. 03-5617 Civil Term CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 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. gers ~J Date: .2004 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 1710'~ (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA Ro ROGERS Plaintiff V. WILLIAM G. ROGERS Defendant NO. 03-5617 Civil Term CIVIL ACTION - DIVORCE 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. Ground for divorce: irretrievable breakdown under § (3301(c)) (3301(d)) of the Divorce Code, (Strike out inapplicable section). 2. Date and manner of service of the complaint: defendant's counsel accepted per the acceptance of service filed of record. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code; by plaintiff: 04/12/04; by defendant; 02/26/04. (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: N/A (2) Date of filing and service of the plaintiffs affidavit upon the respondent: N/A (a) Related claims pending: No economic claims were raised of records. (Complete either (a) or (b).) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: concurrently with this praecipe. § 3301 (c) Divorce was filed with the Date defendant's Waiver of Notice in Prothonotary: 03/11/04. Attorney For Defendant April ~ ~ ,2004 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF CHRISTINA R. ROGERS Plaintiff NO. PENNA. 5617 Civil 2003 VERSUS WILLIAM G. ROGERS Defendant AND NOW, DECREED THAT DECREE IN 2004 t · ina R. Rogers , PLAINTIFF, AND William G. Rogers , 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