HomeMy WebLinkAbout09-6342STEPHANIE L. ENCK
Plaintiff
V.
JUSTIN D. ROSARIO
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ??J- CP3 ?? ?rl i I t? 1'?N
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, 1 Courthouse Square, Carlisle, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
Respectfully submitted,
JOHN F. KING LAW, P.C.
By:
ohn F. King, Esquire
19 S. Hanover Street
Suite 103
Carlisle, PA 17013
(717) 258-4343
JOHN F. KING LAW, P.C.
John F. King, Esquire
ID #61919
19 S. Hanover Street
Suite 103
Carlisle, PA 17013
Tel.: (717) 258-4343/Fax: (717) 422-5526
STEPHANIE L. ENCK
Plaintiff
V.
JUSTIN D. ROSARIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. d ?- 3 Y -T-et,
CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Stephanie L. Enck, who currently resides at 1713 English Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17055, since May 2006.
2. Defendant is Justin D. Rosario, who currently resides at 32 Bay Avenue, 2' Floor,
Bloomfield, New Jersy 07003, since March 2009.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 6, 2008, in Harrisburg,
Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. 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.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
Respectfully submitted,
JOHN F. KING LAW, P.C.
Date: September,2U, 2009
J F. King, Esquire
19 S. Hanover Street
Suite 103
Carlisle, PA 17013
(717) 258-4343
VERIFICATION
I, Stephanie L.. ' :hereby acknowledge that I am the Plaintiff in the foregoing action;
that I have read the foregoing Complaint; and the facts stated therein are true and correct to the
best of my knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of 18 Pa.
C.S. Section 4904, relating to unworn falsification to authorities.
. '?rl AaAU' 0 ?? &,&
Steph ie L. Gyt?, K
Dated: ?-1Q/4n3 D?
FILE?-
F ...,F.,
?-Ir Fit..: I r,: O APY
?009 SEP 24 AH 101: DU
JOHN F. KING LAW, P.C.
John F. King, Esquire
ID #61919
19 S. Hanover Street
Suite 103
Carlisle, PA 17013
Tel.: (717) 258-4343/Fax: (717) 422-5526
Attorney for Plaintiff
STEPHANIE L. ENCK
Plaintiff
v.
JUSTIN D. ROSARIO
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009-06342
CIVIL ACTION -LAW
IN DIVORCE
PRAECIPE TO WITHDRAW COMPLAINT
TO: Prothonotary
Kindly withdraw the Complaint for Divorce filed on September 24, 2009, and so mark
the docket.
Dated: November ~, 2009
Respectfully submitted:
JOHN F. KING LAW, P.C.
By:
ohn F. King, Esquire
ID #61919
19 S. Hanover Street, Suite 103
Carlisle, PA 17013
(717) 258-4343/Fax: (717) 422-5526
Attorney for Plaintiff
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