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HomeMy WebLinkAbout04-4195 CHRISTINA ANN KARCHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW Defendant : NO.O~- 4lClS : IN DIVORCE CIVIL TERM ROBERT D. KARCHER, NOTICE 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. Ajudgment 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, High and Hanover Streets, Carlisle. 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 TIDS 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 Phone: (717)249.3166 CHRISTINA ANN KARCHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 04-4/9S : IN DIVORCE CIVIL TERM ROBERT D. KARCHER, COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Christina Ann Karcher, who currently resides at 511 Easy Road, Carlisle, Cumberland County, Pennsylvania, since May 15,2004. 2. Defendant is Robert D. Karcher, who currently resides at 123 Stoneycreek Road, Apt. 3, Fishertown, Pennsylvania, 15539 since April 2004. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 13, 1997 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiffhas 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. I verify that \he statements made in \his Complaint are true and correct. I understand \hat false statements herein are made subject to \he penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to au\horities. Date: f~p/ ~q~ Christina Ann Karcher, Plaintiff ANDREWS & JOHNSON 'P 0 --tq ~1i:.:O o Vi ~ U) ~ --.: (} ~ ?:! ~ 8 CHRISTINA ANN KARCHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 04- 4/% : IN DIVORCE CIVIL TERM ROBERT D. KARCHER, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 3'd day of September 2004, I, Ronald E. Johnson, Esquire, attorney for Kristina Karcher, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of Ihe Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at his residence at 123 Stoneycreek Road, Apt. 3, PO Box 174, Fishertown, PA 15539, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on August 30, 2004, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: intiff Sworn and subscribed to before me this 3'd day of September 2004 NOTARIAL SEAL W SHEllY SEXTON, Notary Public Carlisle .Boro, Cumberland County My CommISSIOn EXPires_~~~,~007 --~.....;.-~-----------""- Exhibit A ) j o c: -;". ~gfr; ~.:XI b.,: ~!.,'~;:,. r,:::ej 1> _." ~". t.r S:; ~? z ~ ...-{ ~F :rJ j .1f"_. '-orn -U? <)( J ;~Hi .~. 1 ie: ~'~! r" \.0 r...:, f".~' - . CHRISTINA ANN KARCHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 04 - 4/'1S : IN DIVORCE CIVIL TERM ROBERT D. KARCHER, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 3'd day of September 2004, I, Ronald E. Johnson, Esquire, attorney for Kristina Karcher, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- caplioned malter, upon the Defendant at his residence at 123 Stoneycreek Road, Apt. 3, PO Box 174, Fishertown, PA 15539, by depositing Ihe same in the U.s. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on Augusl30, 2004, indicating service was effected, is marked Exhibit "A", altached hereto and made a part hereof. ANDREWS & JOHNSON By: Sworn and subscribed to before me this 3'd day of September 2004 '. I ") iQ ; NOTARIAL SEAL J. SHELLY SEXTON, Notary PUblic Carlisle Boro, Cumberland CounIy My COmmlSSKJn EXPires~!~6:~~?! . - SENDER. COMPLETE THIS SECTION . 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 mallpieee, or 0 the front II space permits. 1. Artie Addressed to: Mr Robert Karcher 1~J S~R~~~~~~ ~uad hf!Jl;;. :r 1--'0 /7q Fishertown, PA 15539 2. ArtIcle Number (Transfer from setV/ce /sbeI) PS Form 3811, August 2001 - . . . . o Agent o Add_ C. Date of Delivery -.30 - D.lsdelivelyaddressd_1rom1tem1? 0 Ves If VES, enter dollvOl)/ acldress below: 0 N\ 3. ~Ice Type ~rti1led Mall 0 Exp_ Moll o Registered -s! Return ReceIpt for Me<chandlse o Insured Mall 'ctO.C.D. .. Restricted Delivery? /Extra Fee) Ves 7003 1010 0001 1185 1164 Domestic Return Receipt 102595.()2-M.1540 Exhibit A o ,;; . j ) o ~~ ,"-..' () C ?~ -.( ;""; \J~; ,.,.... r..; - Defendant : NO. 04-4195 : IN DIVORCE CIVIL TERM CHRISTINA ANN KARCHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v. : CIVIL ACTION - LA W ROBERT D. KARCHER, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330I(c) ofthe Divorce Code was filed on August 24, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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. 9 4904, relating to unsworn falsification to authorities. Date: s/mJ I ' ~ 0JI7/IJ ~ Christina Ann Karcher, Plaintiff ....--~ -, ;--.\' t~,...) (:~ ,,:<, CHRlSTfNA ANN KARCHER, Plaintiff : fN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 04-4195 : fN DIVORCE CIVIL TERM ROBERT D. KARCHER, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without Dotice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not c1airn 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. 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: flf~J~ ~ WMl~ Christina Ann Karcher, Plaintiff ;1 r:, r<! Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA ANN KARCHER, vs. : No. 04-4195 Civil Term : In Divorce ROBERT D. KARCHER, Defendant AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce code was filed on August 24, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice on intention to request entry of the Decree. I verifY that the statements made in the foregoing document are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ~~-r:~ 2-4 Robert D. Karcher Date: ;zJct;/t?S- r".' ,,:,^.:'.~ ~~/~ _;-c -,,",> I" ~. c:; I'," CHRlSTINA ANN KARCHER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-4195 Civil Term : In Divorce ROBERT D. KARCHER, Defendant. W AlVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE PURSUANT TO 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 concernmg alimony, division of property, lawyer's fees or expenses ifI 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 inunediately after it is filed with the Prothono\ary. I verify that the statements made in the foregoing document are lrue and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. Section 4904 unsworn falsification 10 authorities. ~~f~~::;L~ Date: ::::;:;, ...r:"'. .." r:-? C') '" CHRISTINA ANN KARCHER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 04-4195 : IN DIVORCE CIVIL TERM ROBERT D. KARCHER, 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: irretrievable breakdown under Section 330 I (c) of the Divorce Code. 2 Date and manner of service of the complaint: Restricted certified mail. return receipt reQuested dated August 30, 2004. 3. Date of execution of the affidavit of consent required by Section 330] (c) ofthe Divorce Code: by the Plaintiff March 8, 2005 ; by Defendant February 28, 2005 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: :3-('-(-1$.:> Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: 3 _ly_DS Date: March d, 2005 By: . Rona . Johnson, Esq. ~West Pomfret Street Carlisle, P A 17013 (717) 243-0123 (":' , - C'l ~~~'). ':':-d 1'"1' 1"') ("l I""j ~~~~ ~~*~~ ~~~~~+~++~~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + J. + + + + + + + OTHONOTARY + + + + + + + +++++++++++~? + + + + + + . + . . . . . . . . . . + . . . . + . . . ~ +~~:f.:f.+ :+:++ .. . . :+: ~~+~++~++~+~++ ++ . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY CHRISTINA ANN KARCHER PENNA. STATE OF Plaintiff NO. 04-4195 VERSUS + . . . ROBERT D. KARCHER Defendant . . . . . . . . . . . . . + . . . . + . . + . + + + . + + + + + . + DECREE IN DIVORCE NOW'~'~ -z-tJQG AND IS ORDERED AND Christina Ann Karcher DECREED THAT , PLAINTIFF. Robert D. Karcher 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; -4kJl\.-Q By TH + + + + + + + + + + + + + + + +.+ + + + ++:+:++ ++ + + ~+++"'+ .. + 'F. 'F. 'F. +. Of. 'f.;/oi 'f: + 10 'f. ~ ~ ~ ~~ ~ft, .9;; )JI. , ~~ i': 7' -7"" 14> /'?l 5iJ 51.." . "-. . . '" ~... ". ~ . "