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Home My WebLink About09-3842 KELLY K. DUNFEE-ROLLASON, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. MARK R. ROLLASON, Defendant NO. oq - 384 a CIVIL ACTION -LAW 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 4'h Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 L 1 KELLY K. DUNFEE-ROLLASON, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. . NO. 0 g - 3 9 Y-L ?,c<n Q TuM- MARK R. ROLLASON, CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Kelly K. Dunfee-Rollason, an adult individual who resides at 2619 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Mark R. Rollason, an adult individual who resides at 2103 Circle Road, Carlisle, Cumberland County, Pennsylvania 17013. 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. The plaintiff and defendant were married on March 17, 2006, at Mt. Holly Springs, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that plaintiff has the right to request that the court require that the parties participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce Timothy J. O'Connell, Esquire TURNER AND O'CONNELL 4701 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff Verification I verify that the statements made in the foregoing Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Date: 6A ?()q Ke y K. Dunfee-Roll on 1=1"'D-i FFICE OF THE P " THIONQTAW 2009 JUN 10 PM 1: 15 CUM6,1- -'L__ a ra.?N i Y P ci`Vr `I,`? $388. 50 Pb A TTY Gc. 41111 aw'sIst KELLY K. DUNFEE-ROLLASON, Plaintiff vs. MARK A. ROLLASON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-3482 CIVIL TERM 38419- CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements 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. Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code The parties to this action have continued to live separate and apart for a period of at least two years, since March 30, 2009. 2. The marriage is irretrievably broken. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: / Kel y K. unfee-Rollas N) KELLY K. DUNFEE-ROLLASON V. MARK A. ROLLASON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-34-89- CIVIL TERM DIVORCE DECREE 1) 7,P - AND NOW, ar , it is ordered and decreed that KELLY K. DUNFEE-ROLLASON , plaintiff, and MARK A. ROLLASON , 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 By the C Att J. Prothonotary / ?% 0 eo,,w.?/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff C) 9 Vs File No. J 7 IN DIVORCE (Y)Ark A. Ab t 1ASon Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by 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 surname of Dun!'L° P_ , and gives this written notice vowing his / her intention purs t to the provisions of 54 P.S. 704. Date: Signatur P? ft 5?00S-6.2 y Sign tore of name ing resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF A«,.jzl ) On the ic04 day of _ , 2011/3 before me, the Prothonotary or the 10, 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 / 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. fJJ Prothonotary or Notary Public 91 E;- THL "ROTHOHo :;,.. 2 11'ON 16 PH 12: 4 PENNSYLVANIA ?l. DD ?d P . •° a ;2 G o6 // KELLY K. DUNFEE-ROLLASON Plaintiff VS. MARK R. ROLLASON Defendant MOTION TO AMEND FINAL DECREE TO CORRECT NAME OF DEFENDANT AND NOW comes the plaintiff, Kelly K. Dunfee-Rollason, plaintiff in the above captioned action, who, through her attorney, Timothy J. O'Connell, respectfully submits as follows: 1. The above captioned divorce action was filed on June 10, 2009. 2. On May 24, 2011, this Court entered a final Decree in Divorce. 3. The Praecipe to Transmit erroneously listed the defendant's middle initial as "A" which resulted in the Decree in Divorce also listing the incorrect name of the defendant. 4. The correct name of the defendant is Mark R. Rollason. WHEREFORE, plaintiff requests that the court issue an amended Decree in Divorce correcting defendant's name to Mark R. Rollason. Respectfully submitted, I? Timothy J. O'Connell, Esquire TURNER AND O'CONNELL 4701 North Front Street Harrisburg, PA 17110 (717) 232-4551 IN THE COURT OF COMMON PLEAS ?V CUMBERLAND COUNTY, PENNSYLA M03 NO. 09-3842 -<> ..? CIVIL ACTION -LAW co -t, IN DIVORCE zo a C) r M? -a rn X) o° ?a x -? o? 2+ KELLY K. DUNFEE-ROLLASON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09-3842 MARK R. ROLLASON CIVIL ACTION -LAW Defendant IN DIVORCE Certificate of Concurrence I, Timothy J. O'Connell, Esquire, attorney for the plaintiff, hereby certify that on June 16, 2011, I spoke with Hannah Herman-Snyder, Esquire, attorney for the defendant, who indicated she would concur in the foregoing Motion. "Z_ Date: June 16, 2011 Timoth J. O'Connell, Esquire TURNER AND O'CONNELL 4701 North Front Street Harrisburg, PA 17110 717/232-4551 KELLY K. DUNFEE-ROLLASON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. MARK R. ROLLASON Defendant : NO. 09-3842 CIVIL ACTION -LAW IN DIVORCE Certificate of Service I, Timothy J. O'Connell, hereby certify that I served a true and correct copy of the foregoing by depositing same in the U.S. mail, first class postage prepaid, addressed as follows: Date: June 16, 2011 Hannah Herman-Snyder, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 Timothy J. O'Connell IN THE COURT OF COMMON PLEAS OF KELLY K. DUNFEE-ROLLASON CUMBERLAND COUNTY, PENNSYLVANIA V. MARK R. ROLLASON NO. 09-3842 AMFNDED DIVORCE DECREE AND NOW,1?7A V / , it is ordered and decreed that -,A V KELLY K. DUNFEE-ROLLASON plaintiff, and MARK R. ROLLASON , 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 By th ourt, Attest: J. =",A..,l Prothonotary al Alt D ?Cor ne 11 e _13 KELLY K. DUNFEE-ROLLASON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09-3842 MARK R. ROLLASON CIVIL ACTION -LAW Defendant IN DIVORCE Qj ORDER AND NOW, this 7 day of June, 2011, the final Decree in Divorce entered in the above case is hereby amended to correct the name of the defendant to Mark R. Rollason. 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