HomeMy WebLinkAbout04-6444
KATHLEEN A. ROTH
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERALND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: DIVORCE
~ No. 0'/ -t 'lit
SCOTT A. ROTH
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
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
the Court may enter a decree of divorce or annulment against you. A judgment may also be
entered against you for any other claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
When the grounds for divorce include indignities or irretrievable breakdown of marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, High and Hanover Streets, Carlisle,
Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYERS FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOOSE THE RIGHT TO 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, P A 17013
(717) 249-3166
KATHLEEN A. ROTH
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERALND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
: NO. CIVIL TERM
SCOTT A. ROTH
Defendant
: IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the Court require
you and your spouse to attend marriage counseling prior to a divorce being handed down by the
Court. A list of professional marriage counselors is available at the Domestic Relations Office,
13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
KATHLEEN A. ROTH
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERALND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: DIVORCE
SCOTT A. ROTH
Defendant
: No.
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
Kathleen A. Roth, Plaintiff, by and through her attorney, Valerie J. Faden, Esquire,
respectfully represents:
1. The Plaintiff is Kathleen A. Roth, an adult individual currently residing at
106 North Lakeview Drive, Harrisburg, Dauphin County, Pennsylvania 17110.
2. The Defendant is Scott A. Roth, an adult individual currently residing at
5500 Bear Creek Drive, Mechanicsburg, Cumberland County Pennsylvania 17050.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for a period in excess of six (6) months immediately preceding the filing of this
Complaint.
4. Plaintiff and Defendant were married on September 25, 1976 in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. Plaintiff and Defendant separated on or about November 23, 2002.
7. The causes of action and sections of the Divorce Code under which Plaintiff is
proceeding are:
A. Section 3301(c) - the marriage of the parties is irretrievably
broken.
B. Section 3301(d) - the marriage of the parties is irretrievably
broken. The parties separated on or about November 23, 2002.
8. This action is not collusive.
9. The parties plan to enter agreements for the resolution of their divorce and
equitable distribution issues through the collaborative process.
10. Plaintiff has been advised of the availability of marriage counseling and that
Plaintiff may have the right to request that this Honorable Court require the parties to participate
in counseling.
II. Plaintiff does not request that the Court require that she and her spouse participate
in marriage counseling prior to a divorce decree entered by this Honorable Court.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a final
decree in divorce.
Respectfully submitted,
Date: l-:/.2~</ Of.(
/"
'//.. l ,/1
By: l/W1a~.z:.ik--...
Valerie J. Faden.i~;"
J.D. # 87442
2807 Market St.
Camp Hill, PA 17011
(717) 920-9460
VERIFICATION
I, Kathleen A. Roth, do verify that the facts contained in the foregoing Complaint
are true and correct to the best of my knowledge, information, and belief. I understand
that false statements are made subject to the penalties of 18 Pa.C.S. ~4904 relating to
unsworn falsification to authorities.
Date: //;2- c2 / - 6 t
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IN THE COURT OF COMMON
PLEAS
/
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OFCUMBERLANDCOUNTY
*
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STATE OF
"'1
PEN NA.
Kathleen A.
Roth
No.
04-6444
Ci viI
Plaintiff
VERSUS
Scott A.
Roth
Defendant
DECREE IN
DIVORCE
1(. 'fT G<..M.
AND NOW.
~
17
...;:r
, ~ . IT IS ORDERED AND
Roth
DECREED THAT
Kathleen A.
. PLAINTIFF.
AND
Scott A.
Ro;\Jh
. DEFErHJANT,
ARE DIVORCED FROM THE BONDS OF MATf"IMONY.
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.
The terms
of the Marital Settlement Agreement dated December
21,
into this Decree
in Divorce.
2004
incorporated but not merged
are
.+
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