HomeMy WebLinkAbout08-5550SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
: NO. Qg --353 Z' CIVIL TERM
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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY,
Defendant :NO. 6?-SSD CIVIL TERM
DIVORCE COMPLAINT
The plaintiff, Sandra Rosenberry, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in divorce:
DIVORCE UNDER 23 Pa.C.S. 3301(d) OF THE DIVORCE CODE
Plaintiff is Sandra Rosenberry, who currently resides at 304 Harvest Lane,
Shippensburg, Cumberland County, PA 17257, since approximately April 2004.
2. Defendant is Anthony Rosenberry, who currently resides at 4401 Jack Road,
Chambersburg, Franklin County, PA 17201, since approximately April 2002.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on October 15, 1999 at Hagerstown, Washington
County, Maryland.
5. Plaintiff and Defendant have lived separate and apart since approximately April 2002.
6. There have been no prior actions for divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Christina Ferreira
Certified Legal Intern
ROB INS
THOMA M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in the foregoing complaint are true and correct, to the
best of my knowledge, information and belief. I understand making any false statement
would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Date -! qq " ? 4f Plaintiff
Sandra Rosenberry
r; rr
t V)
?
:C -n
rn
c- n
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. i' '.SS 5 , CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow Sandra Rosenberry, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies .
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date 7- ( ? - 0
Respectfull submitted
Christina Ferreira
Certified Legal Intern
ROBE S
THOMAS M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
c° -n
Wg c? -n
sic
s ,, ..
rrl
-
0 n
Fri
;
am C 0
`4 ? tv.
y
ni
- q
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
: NO. 08-5550 CIVIL TERM
PRAECIPE TO REINSTATE COMPLAINT
To The Prothonotary:
Please reinstate the Divorce Complaint at the above-captioned docket.
Christina Ferreira
Certified Legal Intern
"-
Anne M Donald-Fox, IN T
Supervising Attorney
Date: November 7, 2008
(? N
0
t7
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLE _,i 'bF Pn
Plaintiff : CUMBERLAND COUNTY, PENNS?AN- -, ;
_ tv `t
v. : CIVIL ACTION - LAW =7;
IN DIVORCE y ty . ""` ;-7
ANTHONY ROSENBERRY .! N 5
cn
Defendant : NO. bFs - !55tD CIVIL TER --
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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY, ;
Defendant : NO. 0 5'L- > 0 CIVIL TERM
DIVORCE COMPLAINT
The plaintiff, Sandra Rosenberry, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in divorce:
DIVORCE UNDER 23 Pa C S 3301(d) OF THE DIVORCE CODE
2.
3.
4.
6.
7.
Plaintiff is Sandra Rosenberry, who currently resides at 304 Harvest Lane,
Shippensburg, Cumberland County, PA 17257, since approximately April 2004.
Defendant is Anthony Rosenberry, who currently resides at 4401 Jack Road,
Chambersburg, Franklin County, PA 17201, since approximately April 2002.
Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this complaint.
Plaintiff and Defendant were married on October 15, 1999 at Hagerstown, Washington
County, Maryland.
Plaintiff and Defendant have lived separate and apart since approximately April 2002.
There have been no prior actions for divorce or for annulment between the parties.
The marriage is irretrievably broken.
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.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Christina Ferreira
Certified Legal Intern
ROB INS
THOMA M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in the foregoing complaint are true and correct, to the
best of my knowledge, information and belief. I understand making any false statement
would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Date- Plaintiff
Sandra Rosenberry
..p
_.?
?:.
°.; ,
?.
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY,
Defendant : NO. 08-8550 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow Sandra Rosenberry, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date November 7, 2008
Respectfu ly submitted,
Christina Ferreira
Certified Legal Intern
ROB INS
THOMA M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
_ ..1
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
: NO. 08-5550 CIVIL TERM
PRAECIPE TO REINSTATE COMPLAINT
To The Prothonotary:
Please reinstate the Divorce Complaint at the above-captioned docket.
(Y-
A Q)1l\S1A1??-?
Christina Ferreira
Certified Legal Intern
obert E, Rains, Esq.
Supervising Attorney
Family Law Clinic
45 N. Pitt St.
Carlisle, PA 17013
(717)243-2968
Fax: (717)243-3639
Date: January 22, 2009
N
O
C C
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLE 'bF M
Plaintiff : CUMBERLAND COUNTY, PENNSAN? -? m
v. : CIVIL ACTION - LAW
IN DIVORCE a C M
ANTHONY ROSENBERRY
Defendant : NO. 6S - 55b;?!) CIVIL TERI? -- -<
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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association whmt, t We Ulm
32 South Bedford Street Ia sej t;l a31d Co 81 ld;ia
Carlisle, Pennsylvania 17013 g . 02 4,
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
:NO. 00s- -5550 CIVIL TERM
DIVORCE COMPLAINT
The plaintiff, Sandra Rosenberry, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in divorce:
DIVORCE UNDER 23 Pa.C.S. 3301(d) OF THE DIVORCE CODE
1.
2.
3.
4.
5.
6.
7.
8.
Plaintiff is Sandra Rosenberry, who currently resides at 304 Harvest Lane,
Shippensburg, Cumberland County, PA 17257, since approximately April 2004.
Defendant is Anthony Rosenberry, who currently resides at 4401 Jack Road,
Chambersburg, Franklin County, PA 17201, since approximately April 2002.
Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this complaint.
Plaintiff and Defendant were married on October 15, 1999 at Hagerstown, Washington
County, Maryland.
Plaintiff and Defendant have lived separate and apart since approximately April 2002.
There have been no prior actions for divorce or for annulment between the parties.
The marriage is irretrievably broken.
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.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Christina Ferreira
Certified Legal Intern
ROB E -SINS
THOMA M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in the foregoing complaint are true and correct, to the
best of my knowledge, information and belief. I understand making any false statement
would subject me to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to
authorities.
Date q Plaintiff 2?
Sandra Rosenberry
n
c?
F
4?
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
Defendant : NO. 08-5550 CIVIL TERM
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above matter, having filed a Divorce
Complaint on Member 19, 2008, hereby elects to retake and hereafter use her previous name
of Sandra Starliter, and gives this written notice avowing her intention in accordance with the
provisions of 54 Pa.C.S. § 704.
Wishes To Be Known As:
COMMONWEALTH OF PENNSYLVANIA
J.
Sandra Rosenbe
Sandra Starliper
COUNTY OF CUMBERLAND SS.
On the day of , 2009, before me, a Notary Public,
personally appeared Sandra Rosenberry, known to me to be the person whose name is
subscribed to the within document, and acknowledged that she executed the foregoing for the
purpose therein contained.
IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal.
OTAR BLIC
Notarial Seal
Laurie L. Wolf, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Feb. 14, 2010
?_ ? ..?,?
~ ?
? ..
?.
?
-
?f?
?.
? ? a
`?, ?"? ?`
?° '?"
i
?"??
t„ ? .
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY
Defendant : NO. 08-5550 CIVIL TERM
NOTICE TO DEFENDANT
If you wish to deny any of the allegations set forth in this affidavit, you must file a
counteraffidavit within twenty days after this affidavit has been served on you or the statements
will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated in April 2002, and have continued to live separate
and apart for a period of at least 2 years.
2. The marriage is irretrievably broken.
3. 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 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
andra Rosenberry
Plaintiff
tt
4?
ta-
=1
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY
Defendant : NO. 08-5550 CIVIL TERM
PRAECIPE TO REINSTATE COMPLAINT
To The Prothonotary:
Please reinstate the Divorce Complaint at the above-captioned docket.
Christina Ferreira
Certified Legal Intern
AA ,mac
Roberf/E, Rains, Esq.
Megan Riesmeyer, Esq.
Supervising Attorney
Family Law Clinic
45 N. Pitt St.
Carlisle, PA 17013
(717)243-2968
Fax: (717)243-3639
Date: March 16, 2009
N
C CQL7
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLE F n ??
Plaintiff : CUMBERLAND COUNTY, PENNS G AN-a -Drn
V. : CIVIL ACTION - LAW -?;
IN DIVORCE n am
ANTHONY ROSENBERRY cn ?
Defendant NO. OS - 566n CIVIL TER -- -?
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 tape 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, Cumberland' County Courthouse, 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, GO' TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH 1N oRMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
.
RUE C()p ?° Q RE CO"'
Cumberland County Bar Association x1; o wtwwt, g e uim t it"
32 South Bedford Street ?a s of said u ? ;C, a
Carlisle, Pennsylvania 170139 At .,
(717) 249-3166 -
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Plleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. YouG must attend the scheduled conference or hearing.
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERR?Y,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
NO. 5'?->o CIVIL. TERM
DIVORCE COMPLAINT
The plaintiff Sandra Rosenberry, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in divorce:
DIVORCE UNDER 23 Pa C S 3301 Q OF THE DIVORCE CODE
1. Plaintiff is Sandra Rosenberry, who currently resides at 304 Harvest Lane,
Shippensburg, Cumberland County, PA 17257, since approximately April 2004.
2. Defendant is Anthony Rosenberry, who currently resides at 4401 Jack Road,
Chambersburg, Franklin County, PA 17201, since approximately April 2002.
3. Plaintiff has been a bon4 fide resident in the Commonwealth for at least six months
immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on October 15, 1999 at Hagerstown, Washington
County, Maryland
5. Plaintiff and Defendant have lived separate and apart since approximately April 2002.
6. There have been no prior actions for divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and
right to request that the court require the parties to participate in counseling have the
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Christina Ferreira.
Certified Legal Intern
ROB S
THOMA M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN R1ESIVIBYER
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in the foregoing comPlaint are true and correct, to the
best of my knowledge, i4lbrmation and belief. I understand making any false statement
would subject me to the Penalties of 18 Pa.C.S.
authorities §4904, relating to unsworn falsification to
.
Date -la
Plaintiff
Sandra Rosenberry
C- N
c2
-n
HiM
S
`K Q
SANDRA ROSENBERR ,
Plaintiff
V.
ANTHONY ROSENBE Y,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
: NO. 08-5550 CIVIL TERM
CERTIFICATE OF SERVICE
I, Christina Ferrei
served a true and correct
4401 Jack Road, Chambe
mail, certified, restricted
complete upon receipt by
the attached green card.
Certified Legal Intern, Family Law Clinic, hereby certify that I
y of the Divorce Complaint on Anthony Rosenberry, residing at
ur, PA, 17201, by depositing a copy of the same in the United States
,very, return receipt requested, postage prepaid. Service was
ithony Rosenberry, on the 31St day of March 2009 as evidenced by
Christina erreira
Certified Legal Intern
1
of
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
J
OF THE PP,i`nNn- TAPY
2009 APR 14 AM 11: 56
--u 41Y
PEINNSYE:v' NIA
PS Fvn+t Mcrae+?+o
2.f--- -,
r 7au8 114a 4{D1 6165 J44
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY,
Defendant : NO. 08-5550 CIVIL TERM
CERTIFICATE OF SERVICE
I, Christina Ferreira, Certified Legal Intern, Family Law Clinic, hereby certify that I am
serving on this day a copy of the Plaitiff's Affidavit of Consent upon Anthony Rosenberry,
residing at 4401 Jack Road, Chambersburg, PA, 17201, by First Class Mail
C
-?4' I
Christina Ferreira
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
Date Apri123, 2009
OF THE
276009 z' 29 1`d'i S2. 3 i
R
SANDRA ROSENBERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
ANTHONY ROSENBERRY,
Defendant : NO. 08-5550 CIVIL TERM
CERTIFICATE OF SERVICE
I, Adam Britcher, Certified Legal Intern, Family Law Clinic, hereby certify that I am
serving on this day a copy of the Notice of Intention to Request Entry of § 3301(d) Divorce
Decree and a copy of the Defendant's Counter Affidavit Under 3301(d) of the Divorce Code
upon Anthony Rosenberry, residing at 4401 Jack Road, Chambersburg, PA, 17201, by First
Class Mail.
Adam Britcher
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
Cs THE
2069 ILA 13 IN] f.: 1
I r,
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 08-5550 CIVIL TERM
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 and separation for two years under §
3301(d) of the Divorce Code.
2. Date and manner of service of the complaint: United States Mail Certified Restricted
Delivery Return Receipt Request Postage Prepaid addressed to Anthony Rosenberry 4401 Jack
Road, Chambersburg, PA 17201 on March 31, 2009.
3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code: January
27, 2009; Date of filing the plaintiff s affidavit: February 2, 2009; and service of the plaintiff's
affidavit upon the respondent: April 23, 2009.
4. Related claims pending: None.
5. Date and manner of service of the Notice of Intention to Request Entry of Divorce
Decree and Defendant's Counter-Affidavit: United First Class Mail Postage Prepaid addressed to
Anthony Rosenberry 4401 Jack Road, Chambersburg, P 2 o May 13, 2009.
Date (P
Adam Britcher
Certified Legal Intern
Megan esmeyer, Esquire
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
SANDRA ROSENBERRY,
Plaintiff
V.
ANTHONY ROSENBERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 08-5550 CIVIL TERM
NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE
TO: DEFENDANT
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after June 5, 2009, the other
party can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in
divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to
this notice.
Unless you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief. The filing of the form counter-affidavit alone does not protect
your economic claims.
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.
IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please
contact our office. All arrangements must be made at least 72 hours prior to any hearing or
business before the court. You must attend the scheduled conference or hearing.
FILED-Offl";F
OF TWEE PPOTIH ?W)TA ?Y
209 JUN -5 AM 10: 52
#ENivSYEVANA
IN THE COURT OF COMMON PLEAS OF
SANDRA ROSENBERRY CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANTHONY ROSENBERRY NO 2008-5550
DIVORCE DECREE
cir AND NOW, 2 4VVue G?Ot)y 3-3 M
it is ord
ed and decreed that
SANDRA ROSENBERRY
ANTHONY ROSENBERRY
plaintiff, and
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.")
NONE
othonotary
Attest:
? - ? 1 ? off' ?v- ??? -? ? ?°?'? "
? t . '•.
?, j'u.r ? '??? ? a,} .3?r