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Home My WebLink About04-0139 FRANCES M. RAFFENSBERGER,: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. () 'I . /39 Civil Term MICHAEL W. RAFFENSBERGER,: ACTION IN DIVORCE Defendant 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 FRANCES M. RAFFENSBERGER,: IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYL VANIA vs, No. o'{-IYf Civil Term MICHAEL W. RAFFENSBERGER,: ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Frances M. Raffensberger, a competent adult individual, who resides in Cumberland County, Pennsylvania. 2. Defendant is Michael W. Raffensberger, a competent adult individual, who has resided at 200 Mill Street., Mount Holly Springs, Cumberland County, Pennsylvania, 17965, since 1998. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 3, 1979 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together; however both are adult individuals. 8. Plaintiff and Defendant are both citizens of the United States of America. 9, Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. .- r l-:'~"J jV\, e,1't,l2..v--lv'A'-(A Frances M. RaffensJtetger, Plaintiff Respectfully submitted, Date: I ~ !z - OL! 0~ Adams, Esquire I. . No. 79465 6 South Pitt Street Carlisle, Pa. 170 I3 (717) 245-8508 ATTORNEY FOR PLAJNTITF r--) ......, c:;::, U <..'-,") -- -Ii --,.( ~::.:, '- ::J , ,. -/ -2~: ,- ~ ~ f-, (':) f-<' ,::.1 \3 \: 0- --r '-. ::_J" '- lJo' .... -<:. (;'. -.... <;-.. '" ,._~ -.... '" '" --.J , '<: v, "Q c'. -...--.-.--"'--'- FRANCES M. RAFFENSBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04 - 139 Civil Term MICHAEL W. RAFFENSBERGER,: ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this February 18,2004, I, Jane Adams, Esquire, hereby certify that on or about February 10,2004,1 caused a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE in the above-captioned matter to be served on Defendant via Pennsylvania State Constable Irving Wallace at the address listed below: Michael W. Raffensberger 200 Mill St. Mount Holly, Pa. 17065 DEFENDANT Respectfully Submitted: J e Adams, Esquire .D. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Irving Wallace Pennsylvania State Constable 3 Y2 East Louther Street Carlisle, PA 17013 FEBRUARY 10, 2004 JANE ADAMS A TTORNEY A T LAW 36 SOUTH PITT STREET CARLISLE PA. 17013 RE: MICHAEL W. RAFFENSBERGER REMARKS: SERVED MICHAEL W. RAFFENSBERGER Served MICHAEL W. RAFFENSBERGER @10:15AM on 01-10-04 AT 100 MILL STREET MOUNT HOLLY PA. 17065 /~ Irving Wallace Pennsylvania State Constable 3 ~ East Louther Street Carlisle, PA 17013 Phone 717-243-6778 Fax 717-243-7937 (") c: "l) tf i",'.- cA-' ":.. - ._/ w:::: ~::T >~~' z ~ ..., = = ..c- ..." r-; = (") ,1 ~ rll-n r' -urn :D'? (:.)('- ~'~~ ain ~'-f 55 -< co ? _c a c::> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA " l='("'CI (\<.....'" ~ . -Ro.~ ....".,'b~"'<if Plaintifi'-' Vs FileNo. d,DO~-\~q IN DIVORCE fv'.-. \c..'h",~\ \J..1 R",We.."'-h<<l'-",Q...f Defendanr NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one 6y marking "x"] ~ prior to the entry of a Final Decree in Divorce, or _ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior sumame of -:s ~ 1\ ", .. ( , and gives this written notice avowing his I her intention pursuant to the provisions of 54 P.S. 704. Date: ....1/ J ~ ) 0 l/ b,-,,- A_VV\. I~ ,- J....., S' I , Si ture h....._- Yh.~Q/n..-----'o"""" Signature of name being resumed COMMO'NW1\ALTH O'F PENl'fSYL VANIA) CO'UNTY O'~t.urJn~,p.. O'n the J2f1..-day of -.0 J<Ui '- . 200fi, before me, the Prothonotary or the , notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ~Q. /3l/1n,,~b/ NOTARIAL SEAL CLAUOIAA. BREWBAKER. NOTARY PUBLIC Carlisle Boro. Cumberland County My Commission Expires April 4, 2005 Notary Public Jv ~ ........ ~ ....0 ~ o<:l ~ ~ ""- ~ c o ~ ~ >-- ~ ~ o c- ~-O~ ...., = () = -n .&- :::- """' -0 I-n ;:0 r:'f-"' -om W :r,CJ C}l :.:.:!Q 2-: ..-'--Tl C)~ -~ !y~ fT~ \.D :,~-~ <::> -:n N ..< ': C ~~ ,;:- =2 FRANCES M, RAFFENSBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2004 - 139 Civil Term MICHAEL W, RAFFENSBERGER,: ACTION IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEP ARA TION 1. The parties to this action separated on October 20, 2003, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3, I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I 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, S4904 relating to unsworn falsification to authorities, { / I ,,_ Date: :0 d I , :):::. 11Jn.-n..l!1-? YY\. 3 -"'~ . "'" Frances M, Jenner, formerly known as Frances M. Raffensberger, Plaintiff i_.j .~. ) ~_::J~l -h r" " " C) ,-. Ci FRANCES M. RAFFENSBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2004 - 139 Civil Term MICHAEL W. RAFFENSBERGER,: ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 12,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 12 -I k- _0> WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(e) AND &3301(d) OF THE DIVORCE CODE I. I consent to 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! 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 faIse statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relatin to unsworn fi lsification to authorities. Date: \Z--l0-6~- ----~ FRANCES M. RAFFENSBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2004 - 139 Civil Term MICHAEL W. RAFFENSBERGER,: ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT I. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 12,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: FfJ la/2:/) :;- ht/Mur~ V/I1 3~ Frances M. Jenner, Plaintiff Formerly known as Frances M. Raffensberger WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(0) AND &330I(d) OF THE DIVORCE CODE I. I consent to entry of a final decree of divorce without notice. ? I understand that I may lose rig..ltts concerning alimony, division of property, lawyer's fees or expenses i fI do not claim them before a divorce is granted. 3. (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. Date: ) d-, I a-,~ l 0.'::>- ~/j ~- VJ.-1 ;<:, e" .~~" Frances M. Jenner, Plaintiff Formerly known as Frances M. Raffensberger ....> C":.) 0 <.'.'.~1 C._n -n 0 ::::1 p n ;'-.) ill , ,- C.) ,~ -.J FRANCES M. RAFFENSBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2004 - 139 Civil Term MICHAEL W. RAFFENSBERGER,: ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 1S330\(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via Constable, delivered on February 10, 2004, Affidavit of Service filed February 18, 2004. 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff: December 12,2005 By Defendant: December 28, 2005. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: December 13,2005. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: December 29, 2005. Date: \2.1 ;ud D S Adams, Esquire I. . No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff __ ~ ;:;"1 ,-_OJ ~---;-i ., -r ;\'\ C-.; \.9 ~.-:--. 't''t' 't':+: :+: 't' " " " " " " " " " . . . " . " . . . . . " . " . " . " . . " . " . . . . . . " " . . " " . " . :+:+.:+:+Of:++' +.++. +.+. +'+'+:+: :+: :t; ++.+ +.++ :+:+.:+: +. :+:+.+.:+:+:+:+ +. +. +. +. +. Of::+::+: +.:+: :+::+: '+':+::+: +:+: . . " n IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Frances M. Raffensberger, Plaintiff No. 04 - 139 Civil Term NO. VERSUS Michael W. Raffensberger, Defendant DECREE IN DIVORCE . . . . . . . . . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +:++'+':+:+.+ AND NOW. :r~"~~_1 c::::.r /0 :!)r c.. . tv! , ~ ,IT IS ORDERED AND Frances M. Raffensberger, n/k/a Frances M. Jenner PLAINTIFF. DECREED THAT Michael W. Raffensberger . DEFENDANT, AND 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:~ '. J , ~~ P"OT"ONO""' . . " . :+: :+: :t; :+: :+: +. +. :+: :+: :+: :+: :+: :+: :+: Of+' :+:'+'+.:+:+''1' :+:'+':+:+. :+:+.+ :+:'+':+:+:+:+ :+: :+: ~:+::+::+: :+::+::+:+.'+' :+::+:++.:+:+. :+:+.:+:~++.+:+:+:+: . . " . . . . . . . . . . . . . . . + . . " . . . . . . . . . " . " . . . . . . . . " " . " . . . . . . . . . " + . . . . . . . . . . . . . . " . . . . . . . . . . " . . . . . " . . . . . 17j-3Q. 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