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HomeMy WebLinkAbout09-6187 CHRISTOPHER ROGERS, Plaintiff V. DARLENE M. ROGERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 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,' One Courthouse Square, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CHRISTOPHER ROGERS, Plaintiff V. DARLENE M. ROGERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. I?1 LNIN DIVORCE COMPLAINT AND NOW comes plaintiff, Christopher Rogers, by his attorney, Kent H. Patterson, and files this complaint in divorce, based upon the following: 1. Plaintiff, Christopher Rogers, is an adult individual residing at 124 Joy Lane, Second Floor, New Britain, Connecticut, 06053. 2. Defendant, Darlene M. Rogers, is an adult individual residing at 303 North Fayette Street, Apt. 7, Borough of Shippensburg, Cumberland County, Pennsylvania (Shippensburg PA 17257). 3. Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and defendant were married on September 14, 1991 in Pottsville, Schuylkill County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Plaintiff and defendant are both citizens of the United States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, plaintiff requests your honorable court to enter a decree in divorce dissolving the marriage between plaintiff and defendant and such further relief as the Court may determine equitable and just. ent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 Page 2 VERIFICATION I, Christopher Rogers, verify that the statements in the foregoing complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Christophe Roger o??d Date: CF r rr; 109 SEP t I Pry 4: 19 CUt?, 4N f? r 33?- . SO Qt- -,? y c it k- 6 so AA --osvy CHRISTOPHER ROGERS V. DARLENE M. ROGERS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6187 CIVIL DIVORCE DECREE AND NOW, 1~~1 ~, z ~~~~ , it is ordered and decreed that CHRISTOPHER ROGERS DARLENE M. ROGERS plaintiff, and bonds of matrimony. defendant, are divorced from the 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 Court, At t: J. Prothonotary (9.~, ~ o ~¢.r~-. c,op~ ,~,no~ te.~d -fr, A4h~ ~a-~e,cso~t. Gf~-{~-