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Home My WebLink About04-2605 6 GERALD E. STRAWSER, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 04 - ';(bDS C.j(,)\L~Eiz..n\. RHONDA STRAWSER, Defendant CIVIL ACTION - LAW 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 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 at the Cwnberland 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013-3308 (717) 249-3166 GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : No. 04 - ~bCS CI~~l '--r~ RHONDA STRAWSER, Defendant : CIVIL ACTION - LAW : DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE The Plaintiff, Gerald E, Strawser, by and through his attorney, Jeanne B, Costopoulos, Esquire, avers the following: 1. The Plaintiff, Gerald E. Strawser, is an adult individual who currently resides at 1650 Holtz Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant, Rhonda Strawser, is an adult individual who currently resides at 322 6th Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 23, 1990 in Mechanicsburg, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5, Paragraphs one (1) through four (4) are incorporated herein by reference as if set forth specifically below. 6. There have been no prior actions of divorce or for annulment between the parties, 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling, 9. There is no dependent children from this marriage. 10, This action is not collusive, WHEREFORE, the Plaintiff respectfully requests this Honorable Court grant the Plaintiff relief from the bonds of matrimony and order a Decree in Divorce, Dated: Ii/; Ifl RESPECTFULLY SUBMITTED: ~_Wo'_ 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR PLAINTIFF GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. RHONDA STRAWSER, Defendant : CIVIL ACTION - LAW : DIVORCE VERIFICATION I, Gerald Strawser, hereby verify that the statements made in the foregoing Complaint in Divorce 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: ,_~:..-lS"= '" (I Signature: /l~~ ~rald Strawser -p ~ ~ f' - \f:- ...c II () r-.-' . ;. , '-' C-J -" LQ Lv ~ , tJv 0- G ...c ~ '. ~ f- f! - .. . !i1- .. - ,-" .- GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2605 CIVIL TERM RHONDA STRAWSER, Defendant : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE 1. I, Gerald E. Strawser, am the Plaintiff in the above matter. 2. I personally know that the Defendant, Rhonda Strawser, is over the age of eighteen (18) years and that she currently resides at 322 6th Street, New Cumberland, Pennsylvania, 17070. 3. The Defendant is not in the military or naval servic,: of the United States or its allies or otherwise within the provisions of the Soldier's and Sailors Civil Relief Act of 1940 and its amendments. 4. I hereby verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to au1horities. Date: (o-c)V-dJ- Signature: ~~LP~ Gerald E. Strawser ~ Q. ~ ~ ~ --0<>1 ~ ~~~ ft' ",.... .; ~ e. l'i. ::;j'-.- %,/" ..... -:\;.::.\ ~t-,- ~ %~ ~ii...; ~ ,,",,- ~ -:& @;. '''' . . ?-l y~ ~ ~ GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2605 CrVIL TERM RHONDA STRAWSER, Defendant : CIVIL ACTION - LAW : DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDA VIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 15, 2003, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 4. I hereby verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 0-d/r/cD- Signature: 4./p~g~ ~;trawser ~ q. ~ t ~~ i(t\ :;e _ i~~.. ~ ~~ ~-t ..., "t<.~ 'iQ $ SI ~g ~ ~ ~ ~ - Jev GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2605 CIVIL TERM RHONDA STRAWSER, Defendant : CIVIL ACTION - LAW : DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 9,2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 94904 relating to unsworn falsification to authorities. Date: /iJ-/y-{)~ , ~ 7 .~ Signature: 6'~-tA&/ 2r~---:==. Gerald E. Strawser (1 <;; ~ ~t1 (0 \'3.; (, '~~J. ;::) .r'C; \:.f~. ~;~:S .4.. Gel t 0 2000 ~ 'f#. o c-> ...-\ 'j; ~ ..-\ ::t.,--n f\"\e .....> \"1' > :JJ t( (:i~_~\ ~2D /'- ,-\I C)' _A ~ ~ --0 ....,'1'~ _t... 0! rV r-:! GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2605 CIVIL TERM RHONDA STRAWSER, Defendant : CIVIL ACTION - LA W : DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. 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. 94904 relating to unsworn falsification to authorities. Dated: /0- /F'-GlC" Signature: 6~ ~~ Gerald E. Strawser g -~ >c -0 0. - r'T'I" ~ -.,' _.-"~ ~z~ F (,r-: ::::~; ;..; ~~~ \.:~ ~.t:- ~:, .~ r-) c::> c::> r;r o C'i -l N (J1 -0 :!."~ ~ .-4 :J:-r. n'r:: "0 (1:'; ',1 r.-r' ;:.) J,.. l:.:~j~-T)f ;~ -'Cl ~:'~~\r'~ o ---I J2" ~ '-;:;) N N GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2605 CIVIL TERM RHONDA STRAWSER, Defendant : CIVIL ACTION - LA W : DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 9, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 94904 relating to unsworn falsification to authorities. Date: ~ Signature~~ Rhonda Strawser o G. r0 ~ c~ C"' C) -n l') o c' c:) GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-2605 CIVIL TERM RHONDA STRAWSER, Defendant : CIVIL ACTION - LAW : DIVORCE DEFENDANT'S W ATVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301~) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses in do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. 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. 94904 relating to unsworn falsification to authorities. Dated: \ \ \, \ G \0 Signature: Rhonda Strawser " f (J c.": r-.~ ~ - 2.:, ~._,: ~~~ r---' r-...., '-' """'..'7< ..-.\0.. C;'~' ~' f""" <"..J' ~c~ .... - MARIA P. COGNETTI & ASSOCIATES JEANNE B. COSTOPOULOS, ESQUIRE Attorney J.D. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-2605 CIVIL TERM RHONDA STRA WSER, Defendant : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICE I, Jeanne B. Costopoulos, Esquire, verify that the Complaint in Divorce filed on June 9, 2004, was served upon Plaintiff via restricted delivery, certified U.S. mail, receipt number 7000 15300001 60020025 on June 14,2004. I verify that the statements made herein are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. MARIA P. COGNETTI & ASSOCIATES By: ~. JEANNE B. COSTOPOULOS, ESQUIRE P A Supreme Court I.D. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff Date: November 29, 2006 ... . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~haRk ~tt'tW)ff ) Zz. b ~ Jf{'ee.;t- AQvf CU~9Jldl 1J!- 17070 2. Article Number (rransfer from service label) PS Form 3811, August 2001 1060 Restricted DelivE 3, Service Type ~rtified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C,Q.D. 4. Restricted Delivery? (Extra Fee) Yes [')50 O(}~ ( 6 ~6z.. ooz5'" Domestic Return Receipt 102595-01-M-2509 (') ", ,= t=:; c c~.;. "1:1 s:: t.-i\ "Um 0 ::;:1 mrn rr; P:l Z:J:l c-) G ""?.-- "-n I ----I ..........- Ul {~~::; (~--. - i;: _.;:: ;::.. -d -.".. , , <") ,/ '.0 =:) rn , .. s;! .-<:' Ul ~n .< GERALD E. STRAWSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-2605 CIVIL TERM RHONDA STRAWSER, Defendant CIVIL ACTION - LA W DIVORCE PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 9 3301(c) ofthe Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on the 14th day of June, 2004, by certified mail, return receipt requested, receipt number 7000 15300001 60020025. 3. Date of execution of the Affidavit of Consent required by 9 3301(c) of the Divorce Code: by Gerald E. Strawswer, Plaintiff, on October 18, 2006, and by Rhonda Strawswer, Defendant, on November 7, 2006. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in 9 3301(c) Divorce was filed with the Prothonotary: October 25,2006. Date Defendant's Waiver of Notice in 9 3301(c) Divorce was filed with the Prothonotary: November 20, 2006. MARIA P. COGNETTI & ASSOCIATES By: JEANNE B. COSTOPOULOS, ESQUIRE P A Supreme Court LD. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff Date: November 29, 2006 (') c ;~;:> ~ c::::> 0-" o r" C-) 1 {..i1 :?" :::t.: ~ .-4 -:t:-" r-n?: -0""'. <JY ..~~~ /".1 n '~ -, ~ "p, U1 ~ . ,il;1 -7 /iPJ'....?r->11.1 ,r;7"'fJ,+Jo'l//.' ..1).' .' /f"/' '7'. r ih 1" If- 1':r4~ fli?l :z./{f';"': /19,/ . /'9 '711';' eel