The URL can be used to link to this page

Home My WebLink About01-5225BETH A. WOGAN, Plaintiff DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA CIVIL ACTION LAW No.- IN DIVORCE NOTICE You have been sued in court, ffyou following pages, wish to defend against the c/a/ms set forth in the 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 th.e. Plaintiff. You may lose money or property or other rights important to you, including custody or VlS~tation of your children. When the ground for the divorce is may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumber/and indignities or irretrievable breakdown of the marriage, County Court House, you 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 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 F/ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Car/is/e, PA 17013 Phone: (717) 249-3166 BETH A. WOGAN, Plaintiff DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA CIVIL ACTION LA W No. d/- C, I IN DIVORCE COMPLAINT UNDER SECTION 3301 (e) 1. Pla/ntiffis Beth A. Wogan, who currently resides County, Pennsylvania, since January 2001. at 542A Criswell Drive, Cumber/and 2. Defendant is David A. Wogan, who currently resides at 96 Cold Springs Road, Cumber/and County, Pennsylvania, since November 1998. 3. pla/ntiffand Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Pla/ntiffand Defendant were married in December 13, 1996, in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce this or any °therjurisdictiun. or for armulment between the parties hereto in 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is ava/lab/e, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Pla/ntiffrequests 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. § 4904, relating to unswom falsification to authorities. Date: Karl E. Rominger, Esqu~ Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 BETH A. WOGAN, : Plaintiff : : V. · DAVID A. WOGAN, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-5225 IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : COUNTY OF CUMBERLAND ) AND NOW, this 13th day of February, 2002, I, Karl E. Rominger, Esquire, attorney for Beth A. Wogan, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested, restricted delivery. The original return receipt card signed by the Respondent on September 10, 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated: February 13, 2002 By: Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 I.D. # 81924 EXHIBIT "A" · Complete items 1, 2, and 3. Also complete Item 4 if Restricted Detlvory is desired. · Print your name and address on the reverse so that we can retum the card to you. · Attach this card to the back of the mailpieca, or on the front if space permits. 1. Article Addressed to: 2. ,Nticle Nui PS Form 3~ ~s If YES, ente~ dailve~ baiow: ~No 3. Service Type ~ .JB"C~tmed Mai~ [] Exprees M~il [] Registered ~"Retum Receipt for MercharKIl~ [] Insured Mail [] C.O.D. 4. ~G~4,ed Deliver? (Extra Fee) ]~Ves BETH A. WOGAN, Plaintiff V. DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-5225 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 5, 2001. 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. § 4904, relating to unswom falsification to authorities. Date: ~.2 [i t/O,9 Beth A. Woganv, Plaintiff BETH A. WOGAN, : Plaintiff : .' v. : DAVID A. WOGAN, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-5225 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 5, 2001. 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. § 4904, relating to unswom falsification to authorities. David A Wogan, Defendant f .... NOTARIAL SEAL ~ DARCIE ^. NELL, Not,ary Public / Carlisle, Cumberlano Couaty ~~My Commiasion Ex ires~ ~N°v 24 JOt BETH A. WOGAN, Plaintiff V. DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-5225 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail, September 10, 2001. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff, February 11, 2002; by the Defendant, February 11, 2002. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 13, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 13, 2002. Date: February 13, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 IN THE cOUrT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Beth A. Wc~an Plaintiff VERSUS Defendant N o. 01-5225 Civil DECREE IN DIVORCE AND NOW, ~--O , ~ ~ IT IS ORDERED AND DECREED THAT R~eh A__ .w. og=_n AND David A. Wogan , 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: / PROTHONOTARY