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HomeMy WebLinkAbout05-0747 VIOLET L. ROSENBERRY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA {)LJ'7Lfl Civil Term : No. DENTON W. ROSENBERRY Defendant : ACTION 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. Where 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 at the Office ofthe Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 VIOLET 1. ROSENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term DENTON W. ROSENBERRY Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Violet L. Rosenberry, a competent adult individual, who has resided at 519 Herman Ave., Lemoyne, Cumberland County, Pennsylvania, since 1963. 2. Defendant is Denton W. Rosenberry, a competent adult individual, whose last known address is Box 56, Burnt Cabins, Pennsylvania, 17215. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and the Defendant were married on July 13, 1985 in Enola, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens ofthe United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. 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. S4904 relating to unsworn falsification to authorities. Date: ~ . ~ 0') e dams, Esquir J.D. o. 79465 64 S uth Pitt Street ar sle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ,......, ~ ,~) ~ '(-v ~ :scJ -e:.. ~ C- 2. - ~ ~ o ~ C2 ,--, (....,\ f:~-.-:.' c.:'::!' '-j \ ~.,-- c;J1 ~l ::;J In ~)~\ c~) c;; , -".,~ J:- ,. <:.>) ~ ~ VIOLET L.ROSENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Q')- 7 L/7 Civil Term DENTON W. ROSENBERRY Defendant ACTION IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated in 1995 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 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. S4904 relating to unsworn falsification to authorities. Date:;? - I-OS- <',", - CJ - en C) ! - VIOLET L. ROSENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 747 Civil Tenn DENTON W. ROSENBERRY Defendant ACTION IN DIVORCE NOTICE TO RESUME PRIOR SURNAME. To the Prothonotary: Notice is hereby given that the Plaintiff in the above matter: _X_prior to the entry of a Final Decree in divorce. OR _ after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of WILEY and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. s704. 'I (0 - ~?t~/ ~ Date:) ICfJ J -> "fd(J~ ' . ,N/J/. / zcJ- VIOLETL.ROSENBERRY Prior Name (~I/ :-;t;.I~ VIOLET L. RICHCREEK Signature of Name being resumed. COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the I f day of /n fr-.. , 2005 befon: me, the undersigned officer, personally appeared VIOLET 1.~ERRYNIOLET 1. RICHCREEK personally know to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes thtlrein contained. IN WITNESS WHEREOF, I hereunto set y hand and offici'll seal. -:;/ (lji;~;;l() otarY Public -" // My commission expires: NOTARIAL SEAL CHESTER E. CHRONISTER, Notary Pubflc Huntingdon Twp., Adams County \ My Commission Expires May 21, 2005 Member, Pennsylvania Association of Notanes - VIOLET L. ROSENBERRY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05 - 747 Civil Term DENTON W. ROSENBERRY Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this February 16, 2005, I, Jane Adams, Esquire, hereby certifY that on February 14, 2005, a certified true copy of the NOTICE TO DEFEND and COMPLAINT IN DIVORCE was served, via certified mail, return receipt requested, addressed to: Denton W. Rosenberry Box 56 Burnt Cabins, Pa. 17215 DEFENDANT "'"..."....,.......<^ . Compllll8 Items 1, 2, oneill.' AIeO co.~ ttem 4 W Reslrlcled DelIverY Is ..... . PrInt your name oneI Bddl8lllon the _t so that we can return the card to you. . Attach this card to the back 01 the mallpl8ceo or on the fnlnt ff apece pemlIIL 1. ArtIcle Add_to: ~en+Ot\ yJ. ROS6\ be('(\,Y B"" 50 B~n\- Cl).'t>'!l')s}^ l'nl$ . '. C I!llpMI MliI C_llIllIIptlooMo......_ 2.__ ~""'-1aI>e/J PS FOrm 38-11. ~ alJIIoI 7003 3110 0004 5775 4412 1_ .....1540 . . .-...-........ c_~:~o~ e Adams, Esquire J.D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 A TTORl\IEY FOR PLAINTIFF VIOLET L. ROSENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05 - 747 Civil Term DENTON W. ROSENBERRY Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this March 7, 2005, I, Jane Adams, Esquire, hereby certifY that on February 14, 2005, a certified true copy ofthe AFFlDA VII OF SEP ARA nON was served, along with the Notice to Defend, and Complaint in Divorce, via certified mail, return receipt requested, addressed to: , Dentol'l W. Ro-set\ htr/\1 , B 1Y.x S to 3. ,ServlcG li'pe. ,.' , /I CerlIf1e<IMIit B~n~ C~~i!)SI'j)\I72,';;\,;,: g~ ~., , 2.~~~ 1.1, 7003 3110 0004 5775 4412 , ~~f~t!j!~~~11v~'l'Wfo/!~9~;1 :!'1ji~~t,~/lIlIt11:1ltctIpt , DNo Denton W. Rosenberry Box 56 Burnt Cabins, Pa. 17215 DEFENDANT :' ill bompliltllltiltl~ i: 2. ilnd'il: A1litl i:On\plelli' ' , lIem 4 If Restricts,!, Dell"mY Is dll$lrilll. . , PrInt your ~.ms ilnd .dd_ bn the niverae so that we ,canretutri,the card to YOil,', ,;;' . Allech thl~ card to the back of the ItltlllplOce. ' or ~n the front,/f ,~pace pennlls. , 1. Article Addi'88Bed to! , ",.' "i.i",,',,' j,~. '.c, L,:.~ :'.\', C I:xpreoo Mell tl ftetum RsceIpt (or MerchsndIte " C' ':;" \;' 1~-l540 """., " - e Adams, squire . No. 79465 6 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF --------- '- -\~t . \." ,-~ -- c.:-' \ VIOLET A. ROSENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 747 Civil Term DENTON W. ROSENBERRY Defendant ACTION 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: L Ground for divorce: irretrievable breakdown under &330Hdl of the Divorce Code, 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted- deliverv. Delivered on: February 14.2005. 3, Date of execution of the affidavit required by ~3301(d) of the Divorce Code: By Plaintiff: February 7, 2005. Date of filing and service of the plaintiffs affidavit of separation required by ~3301(d) of the Divorce Code on respondent: Filed: February 10,2005, Served on Defendant: February 14, 2005, Affidavit of Service filed: March 10,2005. 4, Related claims pending: No claims raised. 5, Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Notice of intention was forwarded to Defendant via certified mail. and defendant personallv signed and received document on March 10.2005, Date: Lj' 1/ ~ dams, Esquire to. o. 79465 64 . Pitt St. arlisle, Pa, I 7013 (717) 245-8508 Attorney for Plaintiff n c. -~ ~~ '""'(11.:;:J ff', \ " ~? '-:.-' <f:,~~ ;< fJ)']- r~t "?;(.: ~~~. -7 3~ it> "" <or' ~ "'" \ (J'\ <:i -- -- ~ .-I :t.:-n (\1;;:: -0(1' ~9q "3~_:) ''-J~. ~:; C)r~ ~; (6 \-~ :.\:.-~ ,-. (J'\ u' VIOLET 1. ROSENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 747 Civil Term DENTON W. ROSENBERRY Defendant ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE TO: Denton W. Rosenberry Box 56 Burnt Cabins. Pa. 17215 DATE: March 7. 2005 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after March 27.2004. the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 St. Carlisle, Pa. 17013 (717) 249-3166 , VIOLET L. ROSENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, 05 - 747 Civil Term DENTON W. ROSENBERRY Defendant ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 330Hd) of the DIVORCE CODE 1. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry ofa divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. 2, Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if! do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verifY that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, S4904 relating to unsworn falsification to authorities. Date: Denton W, Rosenberry, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. ,~-,> ,.....-. C",:' -:1 .-.t ~I~ [(i .-, ~, ::r..,. "-:~" :;,J :!.....~ -.., (' C) f".) CJ VIOLET A. ROSENBERRY, Plaintiff IN THE COURT OF COMMON PLJ;AS CUMBERLAND COUNTY, PENN$YL VANIA vs. No. 05 - 747 Civil Term DENTON W. ROSENBERRY Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this March 31, 2005, I, Jane Adams, Esquire, hereby ce ifY that on March 10, 2005, a certified true copy of the NOTICE OF INTENT TO RE UEST FINAL I DECREE IN DIVORCE AND COUNTER-AFFIDA VII were served, via certified mail, restricted delivery, return receipt requested, addressed to: Denton W. Rosenberry Box 56 Burnt Cabins, Pa. 17215 DEFENDANT . Complete Items 1. 2, and 3. Also complete Item 4 if Restricted Delivery Is deslred. . Print your name and address on the reverse 80 that we can return the card to you. . Attach this card to the back of the mailplece, or on the front n space pennlls. 1. Article Addressed to: be" to" W. Rosell.hel'J' 13 01. S't, BV"I t- C~ birU: ('PA 172/ S I [) fxI>- Mall [) lIeIurn RecoIpt.... Mo........ Mall [) ll:.O.D. -"-"1'lII/I [)... 5775 4436 2. ArtIcle Number rr_ttom_... i PS Form 3811, Februeoy 2004 _............ , I"-t;::)pt;lJUWIY ..:1uvuUt 7003 3110 0004 'I OIllM 1140 J / e Adams, Esquire \.~. . No. 79465 ., ~ South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 i ATTORNEY FOR PLAINT~FF (~ ....., = r= c,n C~ -n ::::1 ,,',,::;:::!:, . ~ r- -g~, ) (j~ :; ':~~j C-) 1"';'1 ;po -0 ;;-'"J ;.: CJ r.v ~~+~~++++~+~+++~~++~~~~+ . . " " " . . . . . . . . . . " . . . " . " . . . . . " . . . . . . . . . . . " . . . . . . . . . . . . . . " . . . . . . " . . . . . . . . . . . . . . . " . . " . . . . . . . . . " . . . . . . . . " . . . +. + + VERSUS +~+.++.+.+++++++.+++.+++~++++++++++~+~+++~+++++++++++++++++ + . + + . . + . . + + . + + + + + + . + . + + + . + + + . + . + . + . + + + . + . . + . + . . + . + + + + . + . + + + + . + . + . + . + . + . + . + . + . . . . . + + . . . . . . . + + . . . . . + . . . . . +++++++++++++++++++++++~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Violet 1. Rosenberry, Plaintiff No, 05 - 747 Civil Term No. Denton W. Rosenberry, Defendant DECREE IN DIVORCE AND NOW,~ \ ...-- \L- ~), IT IS ORDERED AND Violet 1. Rosenberry , PLAINTIFF, DECREED THAT Denton W. Rosenberry 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; None. '-~, / "V / ;./} / , / ' / " ~--~ Am'T{l~ (' ~L___~_ PROTHONOTARY . . +~+'4'++'4'+'4'++++ +++++ +~++~++++++++++';. '+ +. +. +: + +. +. . J, , !?P' . P,. . .-:7 /t'TY,P1';J 't ;;;-n.'J ;t, .u !/ r j,/ (if Ii "-mJ/,~ ~1~ .:2. ~.F'm'/ it'r.k.'7 ..)/'JJ!) ,n n><' I't/~'!/ /. f/ ;tl . ,/C /;, . '