HomeMy WebLinkAbout01-7129CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2oo - '71 Pq C,v,'l
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 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.
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
2 Liberty Avenue
Carlisle, PA. 17013
(717) 249-3166
1-800-990-9108
CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 200 -
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE
DIVORCE CODE
1. The Plaintiff is Charles Martin Yocum, an adult individual who currently
resides at 323 Eighth Street, Apartment 2, New Cumberland, Cumberland County,
Pennsylvania 17070 and whose social security number is 195-38-9614.
The Defendant, Rhonda Sue Masser, is an adult individual, whose current
address is 321 Eighth Street, First Floor, New Cumberland, Cumberland
County, Pennsylvania 17070, and whose social security number is 194-54-
7461.
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Plaintiff and Defendant were married on October 7, 2000 in Harrisburg,
Pennsylvania.
-1-
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for
a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
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Plaintiff is a citizen of the United States and Defendant is a citizen of the
United States.
7. There has been no prior action for divorce filed in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are no children born of this marriage.
-2-
10.
Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable
Court to grant a Decree in Divorce.
Respectfully submitted,
Diane M. Rupich, Esquire
1017 North Front Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
-3-
VERIFICATION
I verify that the statements made in this Complaint in Divorce 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.
Charles Mart~n Yocum
Date: December 15, 2001
Ol gEC20 ?1~ I: 15
CUM~7~L~qD COUNTY
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CHARLES MARTIN YOCUM,
Plaintiff
Vs.
RHONDA SUE MASSER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No 2001- 7/022
CIVIL ACTION - LAW
IN DIVORCE
I, Rhonda Sue Masser, Defendant above named, hereby accept service of the
Complaint in Divorce Under Section 3301 (c) of the Divorce Code and acknowledge
that I have received a certified copy of said doctunent on the ~ / S'rday of December,
2001.
DATE: Decembera~,/ ,2001
BY:
Rhonda Sue Masser, Defendant
321 Eighth Street
First Floor
New Cumberland, PA. 17070
CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-7129
CIVIL ACTION - LAW
IN D1VORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on December 20, 2001.
The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing and service of the
Complaint.
I consent to the entry of a final Decree in Divorce after service of notice
of intention to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements made herein are made subject to the penalties of
18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
Date:
Charles Martin Yo'cum, Plaintiff
CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-7129
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(c) OF THE DIVORCE CODE
I consent to the entry of a final Decree in Divorce without notice.
I understand that I may lose rights concerning
property, lawyer's fees or expenses if I do not
divorce is granted.
alimony, division of
claim them before a
I verify that the statements made in this Waiver 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: ~/o~t/,2t:,o..x ~~/~ ~w~.,t,x:~---
Charles Martin Yocum, Plaintiff
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.
CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-7129
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on December 20, 2001.
The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing and service of the
Complaint.
I consent to the entry of a final Decree in Divorce after service of notice
of intention to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements made herein are made subject to the penalties of
18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
Date:
Rhonda Sue Masser, Defendant
CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER.,
Defendant
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-7129
CIVIL ACTION - LAW
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 in Divorce without notice.
2. 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.
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.
I verify that the statements made in this Waiver 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: '~/c~/~ 6-~ ~"ff/~f/,ff~,':~ ~t~ ~//'~~(~
Rhonda Sue Masser, Defendant
iN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE Of
CHARLES MARTIN YOCUM~
Plaintiff
VERSUS
RHONDA SUE MASSER,
Defendant
NO.
PENNA.
2001-7129
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
AND
CHARLES MARTIN YOCUM
RHONDA SUE MASSER
IT IS ORDERED AND
, PLAINTIFF,
, 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.
BY The COUrt:
ATT T:
PROTHONOTARY
CHARLES MARTIN YOCUM,
Plaintiff
VS.
RHONDA SUE MASSER.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-7129
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the Record, together with the following information, to the Court
for entry of a divorce decree:
1. Ground for divorce: Irretrievably broken under Section (X) 3301 (c) or
( ) 3301 (d) of the Divorce Code. (Check applicable section)
2. Date and manner of service of the Complaint in Divorce: By Acceptance
of Service on December 26, 2001.
3. [Complete either Paragraph (a) or (b).]
(a) Date of execution of Affidavit of Consent required by Section
3301(c) of the Divorce Code by Plaintiff, March 21, 2002; by
Defendant, March 21, 2002.
(b) Date of execution of Plaintiff's affidavit required by Section 3301
(d) of the Divorce Code: N/A; Date of service of Plaintiff's
affidavit upon Defendant: N/A.
o
Date of service of Notice of Intent to Finalize under Section 3301(d) of
the Divorce Code: N/A; Date of filing of Waiver of Notice of Intent to
Finalize by Plaintiff: Simultaneously herewith; by Defendant:
Simultaneously herewith·
Related Claims Pending: None
/ Diane M. iSils,'Egrqu'~re
· 1017 North Front Street
Harrisburg, PA 17102
(717) 232-9724
Attorney for (x) Plaintiff
( ) Defendant
Date: March 26, 2002