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HomeMy WebLinkAbout04-2729 WILLIAM E. ROBISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW (2iu LL'T 82..w'\.. v. No.04 - ~?').9 ULIE E. ROBISON, Defendant 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 at the Cumberland County Court House, 1 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 THI S 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 S. Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 or (800) 990-9108 L~~ Attorney for Plaintiff WILLIAM E. ROBISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW c'~L/~ v. NO. 04 - a7~9 ULIE E. ROBISON, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is William E. Robison, an adult individual who is sui juris and resides at 1081 Pebble Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Ulie E. Robison, an adult individual who is sui juris and resides at 147 Lee Ann Court, Enola, Cumberland County, Pennsylvania, 17025. The present whereabouts of the Defendant, Ulie E. Robison, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 4, 1958 in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. TUCKER ARENSBERG, P.C. By: ~d9J1~kLA' ~~ndra L. Me;lt;~~-.~ P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorney for Plaintiff VERIfICATION 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. &iad#~'-AUM~ William E. R~~;n Dated: C,JNolf 68813.1 (J -iq.. -,:::J - 7"~ ~ !tt- \) (-) .....' 0 = C'-. C:? -n ....0;.- <.- --l err :::r:1} - "-> , P1r:- G lrl D ..,,-- -(lrl'l , ::'9 ~ 01 : ,~c'"":; - - r _; "r, ..0 ~ ,,';, -.J ::1'.: _.~' C) - ~)."n - r.....) , f?- .- 0) +- '-Z WILLIAM E. ROBISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. ULIE E. ROBISON, Defendant NO. 04-2729 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF DAUPHIN AND NOW, this 29th day of June 2004, personally appeared before me, a Notary Public in and for the aforesaid Corrunonweal th and County, Shaun M. Kovach, who, being duly sworn according to law, deposes and says that she is the secretary for Sandra L. Meilton, who is the attorney for the Plaintiff and that she mailed a Divorce Complaint on June 22, 2004, to Mrs. Ulie Robison, 147 Lee Ann Court, Enola, Pennsylvania 17025, by Certified Mail No. 7002 2410 0001 2366 6866, return receipt requested, and the same was received by her on June 23, 2004 as indicated by the Return Receipt Card, which is attached hereto. ~frJ i~oAA. Shaun M. Kovach SWORN TO AND SUBSCRIBED before me, this 29th day of June 2004. F8'~'~o, ~~c~ NotarIal Seal PaUIne Patti Thomas, NoIaJy PI.tJIc CilyOl HantsIxng, Dauphin CaI1ly MyCcrmisslon Expllll8 Mar. 24, 2!:1Jl Member, Pemsyfvanlo _ OfNollrlll ...ll ...ll '" ...ll ...ll ...ll m ru U.S. Postal Service,. CERTIFIED MAIL". RECEIPT (Domestic Mail Only; No Insurance Coverage Pro ided) r'l CJ C Return Reciept Fee t:J (Endorsement Required) Postage <0 <:'''>UA'''"' :.:.:. n' 'q",'"" .;)dL.-w:_ iiL"", ;~/~ ./ "YS:>i\ . 'f~ 'f) ".( ~~'~;;~ ;'0'; 'L~:! \~_ 8~~ <. 80~L\/' ~-~-- Certified Fee D Restricted Delivery Fee r=I (Endorsement Required) ~ ru Total Postage & Fees ru CJ CJ r'- Ii;} HII _lilt." L.S~ W en -.., c:> ~6 <: -0 ~(') ..;:;. j~ ~~? N z "';1 w -, U) ... '- ~'0 ( ", ",-:J o -n .~ --f- i-ll WILLIAM E. ROBISON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION - LAW v. Defendant NO. 04-2729 CIVIL TERM : IN DIVORCE ULlE E. ROBISON, 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, divisi n of property, lawyer's fees or expenses jf I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decr e is entered by the Court and that a copy of the decree will be sent to me immediately afte it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I unders and that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 904 relating to unsworn falsification to authorities. Date: 10/29/04 / William E. Robison, Plaintiff s:-3 '? -- ",,:..- C). -'"- o -T1 ....; ~.\- fi-\ , (,,,,) ~--::) ::;;:, c~' 0, .~ ----- WILLIAM E. ROBISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION - LAW v. Defendant NO. 04-2729 CIVIL TERM : IN DIVORCE ULlE E. ROBISON, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code wa filed on June 15,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and n nety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerning alimony, division of pro rty, 5. I verify that the statements made in this affidavit are true and corr lawyer's fees or expenses if I do not claim them before a divorce is granted. understand that false statements herein are made subject to the penalties of 18 Pac .S. 94904 relating to unsworn falsification to authorities. Date: 11/1/04 :tL-. ~ R~~ Ulie E. Robison, Defendant r--' C';:' (;,,:> J;;- -~ s:i I 0) -'~.1 (j -1'1 .--' ::1::. -" ii1p; .,4P-, :"__t.)C"J U~) ~.1~ :1~ ()C' ",?:.rn . , >.:-\ ~,""" (;,;,) (;:::J -' ~il :'< - WILLIAM E. ROBISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION - LAW v. NO. 04-2729 CIVIL TERM ULlE E. ROBISON, Defendant : IN DIVORCE 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, divisi n of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decr e is entered by the Court and that a copy of the decree will be sent to me immediately afte it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I unders and that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 904 relating to unsworn falsification to authorities. Date: 11/1/04 {JL.i- r f~~ Ulie E. Robison, Defendant 72640.1 ~~ :';:~, J-' \ '-'" ~ _.~, ~,:c,~ \:1.\.~:. -ell"!} :.\1'-1:) i..) (.". -J -~-, ~'\\,. "'1"1 '>('yt\ ..,.,." c:: ?i:~ .'"'-. ."-~"') '::3 ..---- WilLIAM E. ROBISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYlVA IA CIVil ACTION - LAW v. NO. 04-2729 CIVil TERM ULlE E. ROBISON, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code wa filed on June 15, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and n nety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerning alimony, division of pro lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and corr understand that false statements herein are made subject to the penalties of 18 Pa. .S. S4904 relating to unsworn falsification to authorities. Date: 10/29/04 01d /I~ ~~ "f at -I ~1'h1) William E. Robison, Plaintiff GO .;:;:.:l c-;.;.> .c- '.:'~::1 ...~ , G,) <:? ,.::> -..! o -n .-; ~T' ,'"::\lT1 (-- :q(:) ; J(.;,,) (:'') ,.l~~ ~'l?~ ~~'.'5 en -1 ~:I~: WILLIAM E. ROBISON, IN THE COURT OF COM CIVIL DIVISIO CUMBERLAND COUNTY, P VS. ULIE E. ROBISON, NO. 04-2729 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorc decree: 1. Ground for divorce: Irretrievable breakdown under S3301 (c) JOOt~(rtl):mXtlDmIi}jl7lxllll!l]fiXmunn (Strike out inapplicable section). 2. Date and manner of service of the complaint: June 23 2004 certified ail 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by S3301 (c) of the Divor e Code: by plaintiff 10/29/04 ; by defendant 11 1 04 (b) (1) Date of execution of the affidavit required by S3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmi record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in S3301 (c) Divorce was filed with the Prothonotary: 11/3/04 (mailed 11/2/04) Date defendant's Waiver of Notice in S3301 (c) Divorce was filed with the Prothonotary: mailed 11 2 04 Attorney for Pia ntiff / OeleHdaHl r-' c;::.~ C::.,> (:,:::\ -'~ \ 0J () "yj (,.1 c? -l .--j ".:J,,-r'\ 1(1\"--,';:: :q~!j ,,''1 ".)IC) ::.i;~?t ~':.:)In :'.,:A ol ",' " " " " " " . . " " . . . . . . " . . + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + . + + " + + + + + + + " " + + . + + " + + + + + + + " + " + + " + + " + + + + + + + + + " . ~~~~~ ~~~ ~ ~~~~~~~ ~~~~ ~~~~~ ~~~~~~~~~~~~~~~~~~~~ ~++ +++~ ;Ii;+:+ilo: ++ ,+dli:f.:+: IN THE COURT OF COMMON PLEA + + + + + + + + . . + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + " + + + + + + + + + + + + + + + . + OFCUMBERLANDCOUNTY WILLIAM E. ROBISON PENNA. STATE OF No. 04-2729 CIVIL TERM VERSUS UUE E. ROBISON DECREE IN DIVORCE l)~ (0 2004 AND NOW, , IT IS ORDERED AND WILLIAM E. ROBISON DECREED THAT , PLAINTIFF, UUE E. ROBISON AND , DEFENDANT ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. + + .. + + + + . + + + + + + + + " J. ~ + " + + " PROTHONOT RY + + " + +~++++++++++ ++ :+: ++ +++++;Ii~ ATTEST: ++;t: + '" + ++ Of;+' :+: +;1' +;1' ++:+: ..Jrp ;' AfJ":' ~ YI &, II ~ P ~. ~ Mill"9 ;,1/, ~\' . ."