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Home My WebLink About09-4120 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF JOHN CHRISTOPHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JENNIFER J. CHRISTOPHER, : NO. 2009 - CIVIL TERM Defendant : IN DIVORCE NOTICE 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 in 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, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 TA NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF JOHN CHRISTOPHER, .Zzz- : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER J. CHRISTOPHER, Defendant : CIVIL ACTION - LAW : NO. 2009 - 7 / CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is John Christopher, an adult individual with a mailing address of 430 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Jennifer J. Christopher, an adult individual with a mailing address of 30 Kerrs Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on May 30, 2000, in Harrisburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. Jov? e, 15 , 2009 Or?. 11?' P J hn Christopher, Fkaintiff WOLF & WOLF, Attorneys at Law rv6 Is , 2009 BY: NATOLF, ESQUIRE Su ourt ID #87380 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff v FILE D-:D OF THr_ 20 Q9 JUN 16 P,4: 2: 0 6 na" -n - kx?? 44,?- NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 30 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF JOHN CHRISTOPHER,:jiV : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER J. CHRISTOPHER, Defendant CIVIL ACTION - LAW :NO. 2009 - l CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 26 / s , 2009 - 4, jan? J Christopher, Plainiff FILED - ;?-',=1vF OF THE 2 0 0 9 J'J N 16 P i 2: 6 7 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 97380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF JOHN CHRISTOPHER, III Plaintiff V. JENNIFER J. CHRISTOPHER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2009 - 4120 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, KARL E. ROMINGER, certify that I am counsel for the defendant in this matter and that I authorized to receive service of the complaint in this action. Furthermore, I hereby certify that on a , 2009, I received a certified copy of the divorce complaint filed in this action. WL? I-XQ- 12009 KARL -119. ROMINGER, ESQUIRE Counsel for Defendant E 01.3 Q JOHN CHRISTOPHER, III IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER J. CHRISTOPHER NO. 2009-4120 DIVORCE DECREE AND NOW, Se01EYnL~~( ~~,, , ,~_, it is ordered and decreed that JOHN CHRISTOPHER, III plaintiff, and JENNIFER J. CHRISTOPHER ,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.") The marital settlement agreement executed September 29, 2009 is incorporated but not merged into the instant decree. By the Court, Attest: J. Proth otary ~ ~ k JOHN CHRISTOPHER, III PLAINTIFF V. JENNIFER J. CHRISTOPHER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4120 CIVIL ORDER OF COURT AND NOW, this 21S` day of January, 2010, upon consideration of the Petition to Enforce Marriage Settlement Agreement filed by Defendant, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the relief requested should not be granted; 2. The Plaintiff will file an answer on or before February 11, 2010; 3. The Prothonotary is directed to forward said Answer to this Court. 4. A hearing on this matter will be held on Tuesday, March 16, 2010, at 11:00 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Nathan C. Wolf, Esquire Attorney for Plaintiff / Karl E. Rominger, Esquire Attorney for Defendant bas w ~ ~' ~.J ~Lt~. ~ ~.G.V i~z ~. f ~a ~• 'Y~ M. L. Ebert, Jr., J• C7 -7.3 ~J 6 :' ' : t-- T _ F_.' t . _. _ ti". "rS . ~- ~4r__ s ~c E`a -,_,x FEB 2 ~ zUyu 7 ~~~~-~r ~~y ~)r ! i1~ ~`}~_.~?il ,'ire, 1 ~ ~/"d-i T NATHAN C. WOLF, ESQUIRE p rr ATTORNEY ID NO. 87380 Z ~ ~ Q ~ ~ U ~ 3 h:~~ 10 WEST HIGH STREET CARLISLE PA 17013 (717, 241_4436 c~r~ ~~ ~..~~..~ti'+i ~~ ATTORNEY FOR PLAINTIFF ~ =-'.4jp;j;~~~~;',;i+. JOHN CHRISTOPHER, III : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW JENNIFER J. CHRISTOPHER, : N0.2009-4120 CIVIL TERM Defendant : IN DIVORCE ORDER OF COURT r~ C AND NOW this ~3 day of C t~ i"~1a-+' , 2010, upon consideration of the foregoing Petition for Leave to Withdraw as Counsel for Plaintiff John Christopher, III, the requested relief therein his hereby GRANTED and counsel is hereby authorized to file a praecipe to withdraw as counsel with the Prothonotary and to serve notice of this Order and such praecipe upon Plaintiff John Christopher, III and counsel for all other parties to this matter. This Order shall in no way effect the scheduling of the hearing on the Petition filed by the Defendant for Enforcement of the Marital Settlement Agreement, scheduled for March 16, 2010 at 11:00 a.m. before the undersigned in Courtroom 2 of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. BY THE COURT: M.L. E ert, Jr., J. D~'stribution: ~/N~than C. Wolf, Esquire ./Karl E. Rominger, Esquire ~ohn Christopher, III, pro se / Court Administration -~~~G~c..L l ~J 1~ ~ ~£_ a fa3~ca ~~ NATHAN C. WOLF, ESQUIRE AT'T'ORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 170]3 (717) 2A1-4436 JOHN CHRISTOPHER, III Plaintiff v. JENNIFER J. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2009-4120 CIVIL TERM IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please withdraw the appearance of NATHAN C. WOLF, ESQUIRE, as attorney of record for Plaintiff, JOHN CHRISTOPHER, III, in this matter. February 24, 2010 NATC. WOLF, ESQUIRE WOL & WOLF 10 West High Street Carlisle, PA 17013 717-241-4436 SUPREME COURT ID #87380 -. J T 1'il ~ ~ ~ _ - _... . ~-= ti~ E 37 .~ ~ _`X7 Cn --+C NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 JOHN CHRISTOPHER, III : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW JENNIFER J. CHRISTOPHER, : N0.2009-4120 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, hereby certify this day that I mailed a true and correct copy of the foregoing Praecipe to Withdraw Appearance of Counsel of Record, by U. S. Mail, postgage prepaid, to the following: John Christopher 327 E. Louther Street Carlisle, PA 17013 Karl E. Rominger, Esquire Rominger and Associates 155 South Hanover Street Carlisle, PA 17013 Counsel for Defendant Dated: February 24, 2010 Na n olf, Esquire