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HomeMy WebLinkAbout08-6694 Rhonda J. Roades Plaintiff V. Timothy A. Roades Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 08- ?f&gLf CIVIL TERM 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 ground 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, Cumberland County Courthouse, 1 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Rhonda J. Roades Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 4 G f `/ CIVIL TERM Timothy A. Roades Defendant 2 3. IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is 2b0(\d& ?Wd?'who currently resides at ,. /-\ . , . i _ S I LdC - i?lq)l) LA OA Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for al least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on t)O ?, I ?- 1 at -L?ora?o Caua?u C,R. 5. The marriage is irretrievably broken, and the parties separated on M G-L-A Q,, () 0 7 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. Cumberland- County, Pennsylvania. Defendant is 1 _(IfA who currently resides at 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. IIIIA07 ?4wdoL. &0(d,?4- Date laintiff, Pro Se 1, ?oloda &-'desverify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: Plaintiff, Pro Se Assisted by: Michael J. Whare, Esq. Law Offices of Michael J. Whare 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 _, eV ?' ?" ?, N `?., .?. ` ? ?? ?['s ? ?? ,?' D ,-° I Rhonda J. Roades Plaintiff V. Timothy A. Roades Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- &( CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Rhonda J. Roades, Plaintiff, to proceed in forma ap uperis. I, Michael J. Whare, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Michael J. Whare, Esqu re Attorney for Plaintiff Law Offices of Michael J. Whare 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 ' ?t ??? ??_ .w -rc ... N ?? ,C?' J Rhonda J. Roades IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08- (p q a CIVIL TERM Timothy A. Roades Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on 9YO r 1a :) OD'? v 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 divorce. 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. ction 4904 relating to unsw rn falsification to authorities. Dat Signature. 1 Timothy . Roades, Defendant na ? Asa Xf- -C D 4 Rhonda J. Roades IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08- 4 ? 4 7 CIVIL TERM Timothy A. Roades Defendant IN 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 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 relati?lg to unsworn falsification to authorities. J Date- Signature: Timothy es, D en a C o K - u U7 r tf v 1 =- N .? -? Rhonda J. Roades IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- lr(, ?? CIVIL TERM Timothy A. Roades Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on N_0 el /a dov F. 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: Signature: -10JM12 Rhonda J. Roades, Plaintiff u ?,: ?'? Rhonda J. Roades IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- V 1e'? CIVIL TERM Timothy A. Roades Defendant IN 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 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: 1 C Signature: Oh I)MLQ OPOA OA--, Rhonda J. Roades, Plaintiff OF* THE F- ARY 2009 MAY - IL) PH e : 4 2 RHONDA J. ROADES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law TIMOTHY A. ROADES, Defendant : No. 08-6694 IN DIVORCE ACCEPTANCE OF SERVICE I, Timothy A. Roades (Defendant), accept service of the Complaint in Divorce under section 3301 (c) and (d) of the divorce code Date Timothy . Roades, Defe dent 1820 East Vineyard Rd. Phoenix, AZ, 85042 FILED-CIT OF THE Ri lill',?%Olm 2009 MAY 22 FPM 9: 34 ` ?. F. c e . RHONDA J. ROADES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 08-6694 TIMOTHY A. ROADES, Defendant INDIVORCE PRAECIPE TO TRANSMT- RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Filed November 12, 2008, was served on the Defendant by first class mail. Defendant signed an Acceptance of Service dated November 18, 2008 (attached hereto as proof of service- Exhibit A). 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: by the Plaintiff on April 28, 2009 and filed on May 4, 2009; by the Defendant on March 3, 2009 and filed on March 12, 2009. 4. Related claims pending: None 5. (b) Date Plaintiffs Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: May 4, 2009. r Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: March 12, 2009. Respectfully submitted, Date: 5°a /-0 q ,Michael J. Wh , Esquire 37 East Pomfret Street Carlisle, Pa 17013 (717) 243-3561 Supreme Court ID # 89028 Attorney for Plaintiff OF THE' ,ns 1TARY 2009 A Y 22 2 1A"rri yl. ^0 C L } IN THE COURT OF COMMON PLEAS OF RH NDA J. ROADES, CUMBERLAND COUNTY, PENNSYLVANIA V. A. ROADES, : NO 08-6694 CIVIL TERM DIVORCE DECREE AND NOW, , ?it is ordered and decreed that F% A J. ROADES, A. ROADES, plaintiff, and defendant, are divorced from the of matrimony. Any existing spousal support order shall hereafter be deemed an order for 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 clairos remain indicate °None.") the Court, Attest: J. 'j a. "Oz Prothonotary J .4'- ;W4?