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Home My WebLink About09-4714I,f V WILLIAM GREGORY ROTHMAN, Plaintiff V. CAROLYN A.U. ROTHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :No.: 0(? - q'71 q : CIVIL ACTION : IN DIVORCE (S'Lot "-? 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 on the first floor of the Cumberland County Courthouse, Carlisle, Cumberland County, PA. 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 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 the Court Administrator at (717) 780-6624. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. WILLIAM GREGORY ROTHMAN, Plaintiff A. CAROLYN A.U. ROTHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :No.: 09- 47111 ?cuc? : CIVIL ACTION : IN DIVORCE COMPLAINT UNDER & 3301(0 OF THE DIVORCE CODE AND NOW, comes the Plaintiff, pro se, who brings this Divorce action and avers as follows: 1. Plaintiff is William Gregory Rothman, an adult individual, who currently resides at 1 Gunpowder Rd., Mechanicsburg, Cumberland County, Pennsylvania, 17050 since June 15, 2001. 2. Defendant is Carolyn A.U. Rothman, an adult individual who currently resides at 1 Gunpowder Rd., Mechanicsburg, Cumberland County, Pennsylvania, 17050 since June 15, 2001. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 28, 1997 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. This 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. 9. Defendant has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully Submitted, Date: 7 b.S bd d V j William go Rothman, Pro Se VERIFICATION I, William Gregory Rothman, verify that the statements made in this Petition 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: 7 i, ;vd r -al William Grego R hman 211Ou 3'JI L 1 3 Ii 2- 1- ?d-?33? So r?? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 WILLIAM GREGORY ROTHMAN, Plaintiff V. CAROLYN A.U. ROTHMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4714 CIVIL ACTION -LAW IN DIVORCE ANSWER TO COMPLAINT IN DIVORCE AND COUNTERCLAIM AND NOW, this 30'' day of July, 2009, comes Defendant, Carolyn A.U. Rothman, by and through her attorney, Barbara Sumple-Sullivan, Esquire and files this Answer to Complaint in Divorce and Counterclaim. 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Denied. After reasonable investigation, Defendant is without knowledge to form a belief as to the truth of the averment and same is denied. 9. Admitted. 10. Admitted. 1 COUNTERCLAIM OF DEFENDANT/COUNTERCLAIM PLAINTIFF COUNTI EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 of Defendant's Answer to Complaint in Divorce and Counterclaim are incorporated herein by reference. 12. The Defendant/Counterclaim Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Defendant/Counterclaim Plaintiffrequests this Court to equitably divide said property in accordance with Section 3501 of the Pennsylvania Divorce Code. COUNT II SUPPORT. ALIMONY PENDENTE LITE AND ALIMONY 13. The averments in paragraphs 1 through 12 of Defendant's Answer to Complaint and Counterclaim are incorporated herein by reference thereto. 14. Defendant/Counterclaim Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Defendant/Counterclaim Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. 2 COUNT III ATTORNEY'S FEES AND COSTS 15. The averments in paragraphs 1 through 14 of Defendant's Answer to Complaint and Counterclaim are incorporated herein by reference thereto. 16. Defendant/Counterclaim Plaintiff is unable to sustain herself during the course of this litigation and has employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Defendant/Counterclaim Plaintiff requests an award of counsel's fees and expenses. WHEREFORE, Defendant/Counterclaim Plaintiff, Carolyn A.U. Rothman, prays this Honorable Court to enter judgment: A. Awarding Defendant/Counterclaim Plaintiff a decree in divorce; B. Equitably distributing the marital property; C. Awarding Defendant/Counterclaim Plaintiff support, alimony and alimony pendente lite; D. Awarding Defendant/Counterclaim Plaintiff counsel fees, costs and expenses; and E. Awarding other relief as the Court deems just and DATE: July 30, 2009 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Defendant/Counterclaim Plaintiff 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 WILLIAM GREGORY ROTHMAN, Plaintiff V. CAROLYN A.U. ROTHMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-4714 CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Carolyn A.U. Rothman, hereby certify that the facts set forth in the foregoing Answer to Complaint in Divorce and Counterclaim are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. DATED: July 30, 2009 C, vvttl?__ Carolyn .U. Rothman Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 WILLIAM GREGORY ROTHMAN, Plaintiff V. CAROLYN A.U. ROTHMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4714 CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Answer to Complaint in Divorce and Counterclaim in the above- captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Mr. William G. Rothman 1 Gunpowder Road Mechanicsburg, PA 17050 DATED: July 30, 2009 Barbara Sumple-Sullivan, Esquire Attorney for Defendant/Counterclaim Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 00 ?'? P a?dto0+ k ? ? SSID c 3 aa$#158 Law Office of Michelle Christian By: Michelle Christian, Esquire Attorney I.D. No. 88598 606 Corporate Drive Langhorne, PA 19047 Phone: (215) 806-5932 Fax: (215) 550-6603 WILLIAM GREGORY ROTHMAN Plaintiff VS. CAROLYN A. U. ROTHMAN Defendant IN THE COURT OF COMMOM PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-4714 : CIVIL ACTION -LAW IN DIVORCE ENTRY OF APPEARANCE Please enter my appearance as attorney for William Gregory Rothman, Plaintiff in the above- captioned matter. MICHELLE CHRISTIAN, ESQUIRE ATTORNEY FOR PLAINTIFF ALED-+ FFICE OF THEE Pi?OTH INIIOTARY 1009 OCT 28 PM 12= 5 8 P - WILLIAM G. ROTHMAN V. CAROLYN A.U. ROTHMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4714 DIVORCE DECREE AND NOW, it is ordered and decreed that WILLIAM G. ROTHMAN , plaintiff, and CAROLYN A.U. ROTHMAN , 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. All matters have been resolved by the parties' Marital Settlement Agreement dated December 29, 2008, as amended by Addendum to Marital Settlement Agreement dated March 16, 2011. B e Court, Attest: otary cs 13 ?? - CerE CoP „,49' ltd ?(ofic j so//, Van f