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Home My WebLink About05-0707 NIP/- MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION-LAW IN DIVORCE DAVID L. RYDER, JR., Defendant NO. ()t' -7D7 CIVIL TERM 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 right 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, 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 LA WYER AT ONCE. IF YOU DO NOT HAVE LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford St. Carlisle, P A 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of ] 990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE DA VID L. RYDER, JR., Defendant NO.DS - 107 CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. ~ 3301(c) and !l3301(d) OF THE DIVORCE CODE The plaintiff, Monica J. Ryder, by her attorneys, the Family Law Clinic, sets forth the following cause of action: I. Plaintiff is Monica 1. Ryder, who currently resides at 504 Meadow Drive, Shippensburg, Franklin County, Pennsylvania 17257. 2. Defendant is David L. Ryder, Jr., who currently resides at 541 Newville Road, Shippensburg, Franklin County, Pennsylvania 17257. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on September 20, 1996 in Orrstown, Franklin County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since May 2004. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff or defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Date:~[ &/05 ~~.~~ CHARLENE . AQ lUNA Certified Legal Intern ~~jc ANNE MACDONALD-FOX THOMAS M. PLACE LUCY JOHNSTON-WALSH ROBERT E. RAINS Supervising Attomey F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (7 I 7) 243-2968 '. VERIFICATION 1 verify that the statements made in this Divorce Complaint are true and correct to the best of my personal knowledge and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Dated: Idjllr~ooLf I I r \! ~ "" c::'~ c:~") ~':)' j ""rl r"q e.) , OJ v r......J ($) en - MONICA 1. RYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : IN DIVORCE DAVID L. RYDER, JR., Defendant : NO.OS - '1c>1 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Monica J. Ryder, Plaintiff, to proceed in forma pauperis. 1, Charlene J. Aquilina, of the Family Law Clinic, student attorney for the party proceeding in forma pauperis, certify that 1 believe the party is unable to pay the costs and that 1 am providing free legal service to the party. Date:~ ~~ Charlene J. A uili Certified Legal Intern ~p?jL ANNE ACD NALD-FOX THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 I CO -ry ...."".. r....J (Ai en MONICA J. RYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE DA VlD L. RYDER, JR. Defendant : NO. 05-707 CIVIL TERM PROOF OF SERVICE Understanding that the making of any false statement would subject her to the penalties of 18 Pa. C.S. S4904 (relating to unsworn falsification to authorities), the undersigned verifies that Charlene J. Aquilina mailed a true copy of the Divorce Complaint on the Defendant by placing the same in the U.S. Mail, certified no. 70042510 0003 12472831, restricted delivery, return receipt requested, postage prepaid, on the 8th day of February, 2005 addressed as follows: David Ryder 541 Newville Road Shippensburg, P A 17257 Sender's receipt no. 7004 2510 000312472831 is attached hereto and incorporated by reference. On the 14th day of February, 2005, green return receipt no. 70042510 0003 12472831 was delivered to the Family Law Clinic, bearing the signature David L. Ryder, Jr. and showing a date of service of February 11, 2005. The return receipt is attached hereto and incorporated by reference. Date:~ (~,~ Charlene J ~qUi na Certified Legal Intern . Complete items 1, 2, and 3. Also complete item~ if Restricted Delivery is desired. . Print your name and address on the reverse so t t we can return the card to you. . Atta h this card to the back of the mail piece, or 0 the front if space permits. 1. Article Addressed to: F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 717-243-2968 D. Is delivery address di rent from item 1? If YES, enter delivery address below: /}c\iir! k\/rin 54 i I\I(LlV,iil kL(i:L .B1(lH(Jr~bvrJ' nt il!i6'1 .....--=-----.. 3. Service Type ~ertified Mail o Registered o Insured Mail o Express Maii ~eturn Receipt for Merchandise o C.OD. 2. ' 7DD4 2510 0003 1247 4. Restricted Delivery? (Extra Fee) Yes ,d-f 31 p~E!lrm~e11 , August 2001 102595-02-M-1035 ~ .;;; ~ -~ -, '0 'tA "" "" Cl'" ~ -,,::> ~ '? .c' tJ.' MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION..LA W IN DIVORCE DAVID L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM AFFIDAVIT OF CONSENI I. A Complaint in Divorce under !}3301(c) of the Divorce Code was filed on February 8, 2005 and served on the defendant on February 1 I, 2005. 2. 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. 3. I consent to the entry of a final decree of divorce aft.:r service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are trul: 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: b '~b-oS Q.~~1&L~. '""" ~ t;~\ -'"" ~e, , r"" --9,\:{ j "~~'" ~:~ ~ '')c"> ~;'.:: r\'l ,.") ';::"~\ ",7 "?1 .- Cr' ~ ~ "'" c_- ,~ ..- :;;:- l';'? MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION..LA W IN DIVORCE DAVID L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM 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 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. 3. I understand that I will not be divorced until a divofCl: 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 1 g Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: l-/).trOS" ~a~~, David L. Ryder" dant (') c ,~ ,....., = ~ ~: ,.- " - "'. ~ ... (') -l~\ --< -.r:-t1 t"\1f':: -Of"\'> 'nY <?\i::; ~5?1 ::.':'\ 2') :< -0 -,~ -"" r:-? .s;::- C' 17 MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE DAVID L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !}3301(c) of the Divorce Code was filed on February 8, 2005 and served on the defendant on February 11, 2005. 2. 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. 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. !}4904, relating to unsworn falsification to authorities. Date: 7/j()!o() f / o ,.- ....., c-;.:-.. = '-'" p ,- N <..r1 ~~ C) .., -t :::1:-n ~.~f~ .~ c;) '; )..., c1 ~,J ~ -;:, / ,-'~> -' .....'.,.i.;'j ::-~ :):} .-<: MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE DAVID L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM 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 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. 3. I understand that I wilI 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 lmd 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: 7/40hJ I I ~. ~der, P nti q .'! , ....> = = GJ1 c._ (-- f."'; r-.' U" c> "'T1 :r rll pg -nm -rJo :.,'j )..... :::~j~F. c':5?Q "':'::rn o :::~ :""~ .~ 3:-~. ::t.': -.l - MONICA J. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE DA VlD L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM CERTIFICATE OF SERVIC]~ 1, Douglas James Boorstein, hereby certify that on this 18th day of August, 2005, I am serving a true and correct copy of the following on David L. Ryder, Jr.: Defendant's Waiver of Notice ofIntention to Request Entry of a Divorce Decree Under ~3301(c) of the Divorce Code; Defendant's Affidavit of Consent; Plaintiffs Waiver of Notice of Intention to Request Entry of a Divorce Decree Under ~3301(c) of the Divorce Code; Plaintiffs Affidavit of Consent; Praecipe to Transmit Record; and Divorce Information Sheet Service was accomplished by first class U.S. mail, addressed as follows: Mr. David L. Ryder, Jr. 541 Newville Road Shippensburg, PA 17257 Date: 'lJr 12M>' ~u .. ~ Dougl Jaqles Boorstein Certi led Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 o C' ....., = ."0;:; Ul "'~ c: CO'-) o "'T1 ~ en :?J ~-)r:;:, -:'lCJ '0;" f \~~ (~~ i~~\ --I ::0 --<; CD -a :;1:: 0-' - MONICA 1. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE DAVID L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: FebruarY 1 1,2005, by U.S. mail, certified, restricted delivery, return receipt requested, postage pn:paid. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, July 20, 2005; by Defendant, June 26, 2005. 4. Related claims pending: none. 5. Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: July 25, 2005. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: July 14,2005. Date gf'6 /200 S- f FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 ~ = GJ" ~ GW) ~.\_- ~._ c.; ,p~~ ::.z - CP Q, :r"" rllr":: -on::; ~_o9 S~\(;.' :c. .";,'\ C)f,,) ~;;:rn '9\ ~ "':0 :..:. -0 ::r,; .r:- .' - -l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . . . . :+::f.:+: :f.:t: :+::ti ;+::f.:f.:f.;+':f.:f. + "''''':f;!; :to . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. MONTI'/\ .T RVDRR. No. 707 2005 Plaintiff VERSUS DAVID L. RYDER, JR. , Defendant DECREE IN AND NOW, DIVORCE ~~J , IT IS ORDERED AND .~ 'JfP) DECREED THAT MONICA J. RYDER , PLAINTIFF, AND DAVID L. RYDER, JR. , DEFENDANT, ARE DtVORCED 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 TH ATTEST: . :+: '+' Of.:f +: Of '+' :+; . . . .. + :4' ++,., . . +++ Cf+ 'f++:f. Of. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . ,~ ~ ~ ~IA 5O-y:",j> 7 .:7 7 /iffl;" 44>/ . 1"9 >C'cPe$ .. ~ j,.' ". _...1-'1, ------ MONICA 1. RYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE DAVID L. RYDER, JR., Defendant NO. 05-707 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been divorced from the bonds of matrimony on the 23rd day of August, 2005, hereby elects to retake and hereafter use her previous name of Monica J. Barnhart and gives this written notice avowing her intention to do so pursuant to the provisions of 54 Pa. C.S. ~704. ckr Wishes To Be Known As: ~ ~I ; (nu.to.. DAJLha\J" Moni a J. Ba rt COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND SS. On the 1i.!...'(jay of ;6;; If I iii h.J /l ) , 2005, before me, a Notary Public, personally appeared Monica J. Ryder;known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. ~ ' I. , . '. . ./';/' J' C/ OTAR~IC(Jf&L) 1\1;" Laurie L. vVGif, i';n '} :Jj:,> ~:, f1liidol8ton TI,vp., (~;I.:!f,,:;,:~r:Wi'oJ ," t';iy CO;IJmissj,:x-, ;:',., -; '.j :..J -" "'\ -~,. ~ ~ C'I 'l) ~.. "\." c:> , ...J ~ ...... (''', V f'.,.) 'iJ 1'. ,