HomeMy WebLinkAbout10-3004ny
10 F
RICHARD A. ROSARIO,
Plaintiff
VS.
KATHRYN A. INGLE-ROSARIO,
Defendant
C"U"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 10 - 300
0'%V; L 1?t'fn
: CIVIL ACTION - AT 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 at the Cumberland 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, PA 17013
(717) 249-3166
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RICHARD A. ROSARIO,
Plaintiff
vs.
KATHRYN A. INGLE-ROSARIO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No.
CIVIL ACTION - AT LAW - IN DIVORCE
DIVORCE COMPLAINT
The Plaintiff, Richard A. Rosario, through his attorney, Marlin L. Markley, Jr., makes the
following Complaint in Divorce and, in support thereof, avers as follows:
The Plaintiff, Richard A. Rosario, is an adult individual who currently resides at 4
Hilltop Road, Mount Holly Springs, Cumberland County, Pennsylvania 17065.
2. The Defendant, Kathryn A. Ingle-Rosario, is an adult individual who currently
resides at 6 Mountainview Drive, Mount Holly Springs, Cumberland County, Pennsylvania 17065.
3. The Plaintiff and the 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 June 22, 2002, in Carlisle,
Cumberland County, Pennsylvania.
5.
6
7
have the right to request that the court require the parties to participate in counseling.
There have been no prior actions of divorce or for annulment between the parties.
The marriage is irretrievably broken.
The Plaintiff has been advised that counseling is available and that the Plaintiff may
8. This action is not collusive.
WHEREFORE, the Plaintiff, Richard A. Rosario, respectfully requests this Honorable
Court to enter a decree of divorce in this matter.
Respectfully submitted,
M 1, L kley, Jr., Esquire
3920 Mar t Street, Suite 303
r
- 4 - Z d?? Camp Hil ,Pennsylvania 17011
Date: ID# 8474 Tel. (717) 635-9538
RICHARD A. ROSARIO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. No.
KATHRYN A. INGLE-ROSARIO, CIVIL ACTION - AT LAW - IN DIVORCE
Defendant
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. § 4904, relating to unworn
falsification to authorities.
Date:
Signature:
Richard A. Rosario
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RICHARD A. ROSARIO,
Plaintiff
vs.
KATHRYN A. INGLE-ROSARIO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 10 - 3004
CIVIL ACTION - AT LAW -1N DIVORCE
AFFIDAVIT OF SERVICE
TO THE PROTHONOTARY:
I, Marlin L. Markley, Jr., Esquire, verify the Complaint in Divorce has been served
upon the Defendant indicated above by personal service as indicated by the attached
Affidavit of Process Server, pursuant to the requirements of Pa. R.C.P. 1930.4.
Respectfully
Marlin L~ arkley, Jr., Esquire
3920 Mar et Street, Suite 303
Camp ,Pennsylvania 17011
Date: May 25, 2010 ID# 847 5 Tel. (717) 635-9538
Affidavit of Process Server
IN THE COURT OF COMMONPLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
(NAME OF COURT)
RICHARD ROSARIO vs KATHRYN A INGLE ROSARIO 10 3004 CIVIL TERM
PLAINTIFF/PETITIONER DEFENDANT/RESPONDENT CASE NUMBER
1 RICHARD KREITZER being first duly sworn, depose and say: that I am over the age of 18 years and
not a party to this action, and that within the boundaries of the state where service was effected, I was authorized by law to
perform said service.
service: I served KATHRYN A INGLE ROSARIO
NAME OF PERSON /ENTITY BEING SERVED
with (list documents) NOTICE TO DEFEND AND COMPLAINT
by leaving with KATHRYN INGLE ROSARIO SELF At
NAME RELATIONSHIP
® Residence 6 MOUNTAIN ROAD MT HOLLY SPRING PA
ADDRESS CITY/STATE
^ Business
ADDRESS CITY/STATE
51210
DATE
AT 7:00 PM
TIME
^ Inquired if subject was a member of the U.S. Military and was informed they are not.
Thereafter copies of the documents were mailed by prepaid, first class mail on
DATE
from
CITY STATE ZIP ---
Manner of Service:
® Personal: By personally delivering copies to the person being served.
^ Substituted at Residence: By leaving copies at the dwelling house or usual place of abode of the person being
served with a member of the household over the age of and explaining the general nature of the papers.
^ Substituted at Business: By leaving, during office hours, copies at the office of the person/entity being served with
the person apparently in charge thereof.
^ Posting: By posting copies in a conspicuous manner to the front door of the person/entity being served.
Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above, I have been
unable to effect process upon the person/entity being served because of the following reason(s):
^ Unknown at Address ^ Moved, Left no Forwarding ^ Service Cancelled by Litigant ^ Unable to Serve in Timely Fashion
^ Address Does Not Exist ^ Other
Service Attempts: Service was attempted on: (1) 2
DATE TIME ( ) DATE TIME
(3) (4)
DATE TIME DATE TIME (5) DATE TIME
Description:. Age45 Sex F Race~N Height 5'8" Weight Hair BR Beard NO
Glasses NO
v~
SIGNATU E F PROCESS SERVER
SUBSCRIBED AND SWORN to before me this day of , 201 p , by j~+c.4~,r.~ ~6-/"1s,N
Proved to me on the basis of satisfactor evidence to be the erson(s) o eared before me.
~oM~oH~i~T~lor` P~rwrsr~v~l~
Noral~aLsEla~
LINDASAWYER,NdaryPubllc ~ SIGNATURE OF NOTARY BLIC
Camp Mill Aoro, QymfaetWltp COUnty
M Glt>m~~ Slily ~~, ~j~ ~ NOTARY PUBLIC for the state of 1 I"
~„~ FORM 2 NATIONAL ASSOCIATION OF PROFESSIONAL PROCESS SERVERS
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T H! 10
30 AM 9: tt `
RICHARD A. ROSA-RftERLAN) ?? ? IN THE COURT OF COMMON PLEAS OF
Plain?, S Y L VA N I A'
: CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 10 - 3004 Civil Term
KATHRYN A. INGLE-ROSARIO, CIVIL ACTION - AT LAW - IN DIVORCE
Defendant
PRAECIPE TO WITHDRAW APPEARANCE
To the Prothonotary:
Please withdraw the appearance of Marlin L. Markley, Jr., Esquire on behalf of the Plaintiff,
Richard A. Rosario.
Respectfully
Date: March 30, 2012
Marlin L ar ey, Jr., Esquire
3920 Market treet, Suite 303
Camp Hill, ennsylvania 17011
ID# 84745 Tel. (717) 635-9538