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Home My WebLink About08-5649r. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Mark Edward Roche, Plaintiff VS. No. 0 9 -411 ? Civil Term. Pamela Kay Roche, Defendant Type of Document: Complaint in Divorce Notice to Defend Filed by: Mark Edward Roche 158 S. Franklin Street P.O. Box 552 Cochranton, PA 16314. 814-425-7700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Mark Edward Roche, Plaintiff vs. No. CIVIL TERM. Pamela Kay Roche, 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. When the grounds for 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, 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 ? w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Mark Edward Roche, Plaintiff, . No. OS S1,Y9 Civil Term. VS. In Divorce Pamela Kay Roche, Defendant, COMPLAINT IN DIVORCE, UNDER SECTION 3301 (c) or (d) OF THE DIVORCE CODE. 1. The Plaintiff is Mark Edward Roche, an adult and sui juris, who currently resides at 158 South Franklin Street, Cochranton, Crawford County, Pennsylvania, and has since June, 1986. 2. The Defendant is Pamela Kay Roche, an adult and sui juris, who currently resides at 60 Woodmyre Lane, Enola, Cumberland County, Pennsylvania, and has since July, 2005. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 21, 1980, at Cochranton, Crawford County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Neither party is a member of the active duty forces of the military at this time. 8. Plaintiff knows that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff avers that there are no children under the age of 18 born of this marriage. 10. The Plaintiff requests the Court to enter a decree of 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. Section 4904, relating to unsworn falsification to authorities. Mark Edward Roche, Plaintiff Dated: September 4-1 2008 fi b r a 30 [ tl C co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARK EDWARD ROCHE, Plaintiff vs : No. 4e" 56Hq Civil Term. PAMELA KAY ROCHE, Defendant ACCEPTANCE OF SERVICE f; AND NOW, this 90 day of September, 2008, I, Pamela Kay Roche, the Defendant in the above captioned action, hereby accept service of the Complaint in Divorce. 'J" K ?C Pamela Kay Roche N 0 -r R(rv . ?, ••' f 01/20/2009 00:20 18143372478 PAGE 02/03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARK EDWARD ROCK, Plaintiff vs. No. No. 08-5649 Civil Term In Divorce. PAMELA KAY ROCS E, Defendant. A.FMAVIT OF CONSENT 1. A Complaint in divorce under Section 201(c) of the Divorce Code was filed on September 24, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein axe made subject to the penalties of 18 Pa. C.S. §4904 :relating to unworn falsification to authorities. Date: January J?0 2009 `Pct xa Le? ?,:?2 ?KoJu- Pamela Kay Roche s? 15 .x. CIO 01/20/2009 00:20 18143372478 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARK EDWARD ROCHE, Plaintiff vs. No. No. 08-5649 Civil Term In Divorce. PAMELA KAY ROCIM Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §330I(C) OF THE DIVORCE CODE 1. I consent to the final entry of a final degree of divorce without notice. PAGE 03/03 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 unswom falsification to authorities. Date: January 2009 g"JA -A4 )Q1-7jt,4- Pamela Kay Roche _n C= _n ? _3 ; -' . nit IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARK EDWARD ROCHE, Plaintiff vs. No. No. 08-5649 Civil Term In Divorce. PAMELA KAY ROCHE, Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 201(c) of the Divorce Code was filed on September 24, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. I verify that the statements made in this affidavit are true,Aq correct. I understand that f statements herein are made subject to the penalties of 18 S. §4904 relati pj un orp? falsification to authorities. ? Date: Januarl?2009 ?? % ?' ? s C? ? 'Y"t d ? r \?? yy. ? ?. l.? ., _ V ? ...? ? y.;_.I "? y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARK EDWARD ROCHE, Plaintiff vs. No. No. 08-5649 Civil Term In Divorce. PAMELA KAY ROCHE, Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE 1. I consent to the final 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 statements herein are made subject to the penalties?a. C.S. §4904 relating to un? falsification to authorities. Date: Januali/ ?2009 Mark Edward Roche j ? ??.7 ? __ C'a s 1 : a-= ? . ?. - ?,? .,..? ?u;: ?} ,?-„ ? ?: _, ;? ..., _':: ?, wJ ?-; , IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARK EDWARD ROCHE, Plaintiff vs. No. 08-5649 Civil Term In Divorce. PAMELA KAY ROCHE, Defendant. PRAECIPE TO TRANSMIT CORD _. AND NOW, this16iay of January, 2009, comes Mark Edward,Roche, the Plaintiff, and directs the Prothonotary to submit the record, together with t1fd 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. The Complaint was filed September 24, 2008, and was accepted by the Defendant on September 30, 2008, an acceptance of service was filed on October 14, 2008. 3. Date of execution f the affi it of consent required by §3301(c) of the Divorce Code: by the Plaintiff: by the Defendant: Z 4. There are no related claims pending. / 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: Date Defendant's Waiver of Notice was filed with the Prothono espeC 1+ SlYiibmltteCl, Mark Edward Roche, r? G,?n t? ., ?` ` ? ?'- '? . c? - •:; '? ? ? ?? ?? . -? ?_, ?. ?' ?_? ? G ?' ?.,a ? .G` -. .. ;, ?? ?, ?.? Nark Edward Woclt, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA P-P-ICIN Koy l?orhL NO. 08- 5toyq DIVORCE DECREE AND NOW, it is ordered and decreed that /11 ar1C Edwaro(. ?odhc-- , plaintiff, and 1!y Roch't , 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.") Nonc e Court, Attest: J. a. 4n5X79!?10% 7 Prothonotary ? ?? , ?? -r ?? ?? h ? ? ? ?,? r ???.