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HomeMy WebLinkAbout05-3017 '. f'.\F1LES\DA TAfl.LE\General\Cun-ent\ 11223. I.com Created, 9/20104 0:06PM Revised: 6/10105 9:J2AM Jennifer L. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD, 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOSEPH D, RENEKER, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 05- 3011 CIVIL ACTION - LAW NATALIE L. RENEKER, Defendant 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, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, Upon your request, the Court may require you and your spouse to attend up to three sessions, A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 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 Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- :10 i'1 CIVIL ACTION - LAW JOSEPH D, RENEKER, Plaintiff NATALIE L. RENEKER, Defendant IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) or 3301 in) OF THE DIVORCE CODE I. Plaintiff is Joseph D, Reneker, who currently resides at 4190 Kittatinny Drive, Mechanicsburg, Pennsylvania 17050. 2, Defendant is Natalie L. Reneker, whose last known address is 80 Old Mill Road, Dillsburg, Pennsylvania 17019, 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing ofthis Complaint. 4, The Plaintiff and Defendant were married on October 12,2002, in Dauphin County, Pennsylvania, 5. There have been no prior actions of divorce or for annulment between the parties, 6, The marriage is irretrievably broken. 7, 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, 8, Plaintiff requests the Court to enter a decree of divorce. DEARDORFF WILLIAMS & OTTO By J it! L. pears, Esquire 10 Bas High Street Carlisle, P A 17013 (717) 243-3341 Date: ~\ ltJ (05 Attorneys for Plaintiff '. VERIFrCA nON The foregoing Divorce Complaint is based upon information which has been gathered bymy counsel in the preparation of the lawsuit, The language of the document is that of counsel and not my own, I have read the Divorce Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties, 1 ~1J ~ \'1-;' .t, h / , JosWh ~ Reneker I (/ L.// () c ~~ \/) ,';'- -~.- . ~:::'f' !--;. ,,_:~" ;t~,~ ;? ~f ~ 0, ~ ~ -.. ~ ...s:> 0 -- ~ ....... '-') " <.IJ, - -.s::> "-.) "" ~ ~ ..." ~ ~ >;> ~ "'-' = = en <- = ;;C ~ :f1 nl:!'i "0'- :::iEE OL .:.;:10 .c: ~"; ():D. ;;;;~) ~~jn :'-1 -'" LI '< o -0 ~;: ~, '" .(.- , F:\FILESIDA TAFlLEIGeneraJ\Currelltll ]223.1.005 Created: 9/20104 0:06PM Revised 6/17/05 3:49PM Jennifer 1. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO J.D. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff JOSEPH D, RENEKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 05- 3017 CNIL ACTION - LAW NATALIE 1. RENEKER, Defendant IN DNORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) I hereby certifY that a copy of the Complaint in Divorce was mailed to Defendant Natalie 1. Reneker at 80 Old Mill Road, Dillsburg, PA 17019 on June 13,2005, by certified mail, restricted delivery, return receipt requested, Attached is the Post Office return receipt sigI!ed "Natalie Reneker" and dated June 15,2005. 1Kf)Jtfl Jennifi r 1. pears, Esquire Sworn to and sub~yribed before me thi~'(fay of ~ ,.2r>o-r tILk~f& Notary Public NOTARIAL SEAL VICTORIA L. OTTO, NOTARY PUBLIC CARLISLE BDRO., CUMBERLAND COUNTY MY COMMISSION EXPIRES DEC, 2 2006 -, . Comp\8Ie Items 1, 2, and 3. NIlo compIllIe Item 4 If Restricled Delivery Is desinlcI, . Print VOW' name and eddreos on the - "" that we """ return the card to you, . Allach this card to the beck of the mallplece, or on the front If l!P8Cll permits, 1. ArtIcle Addr8&sed to: fJ14;f}aiJk ~ ~() likJ. fJ2dl ~ ~ ~A /7(J/9 ". SIgnol\ire X I D,lsclelMlry__"""'_1? IIY'ES, __ d8Ilwry address below: iSr. 3, SeIvIOo Type .I!i' CertIfIed Mail [J I!>cpr8M Mal, [J RegIstered [J RetUm Receipt fer Merohandlso [J 1!\OU(8d Mail [J C,O,D, 4,. _ DelIV81Y'1 (Extra Fee) lll::Veo 2, Ar1Ic:Io Nunm. (Illlns$r ""'" sordji8 tob'!O PS Form 381,1 , ~USl200.1. Ii 7003 1010 0001 1188 6999 .DomostIQ RelIa'n Rec:elPl '.............'540 a- a- a- ..D <0 <0 .-'I .-'I U,S, Postal Service", CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Postage $ I .(PO (:).3C 1.1;) 3,?C q,,\~ ~/..~~~~'j:: ~,r\ ~GV (1";0"- .-'I o o D Return R9Clept Fee \Endo_R_ D Restricted Delivery Fee M (Endorsement Required) o .-'I C6rtIfled Fee m o CJ t'- ToUll Postage & Fees $ (", c s: -occ S2~ ze- (f~J?-. () -r~ --! :I~; -r,i i' 'r--":' ril \,.' 1 r I P,.> CO - -". -,- ..- '2(~ ,-rn :,~ l'..) ( ~.'J c...:. ~ ....,.l ,-< - Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO 1.D, 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff JOSEPH D, RENEKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO, 05-3017 CIVIL ACTION - LAW NATALIE L. RENEKER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301(c) ofthe Divorce Code was filed on June 10, 2005, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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, 9 4904 relating to unsworn falsification to authorities, Date: ....- q.-)~.05 ~ " c: ~'~ ~ ~ 'A :.-0 'C1 Q, ~\ ~ ;:::4 "" ~ cJ' -0\:( ('(',I'.' "'l~ ~L~, ~(Tj'-,.,.- :.;:.', r;: ,: ~('j, ~G' .ye: -z:, ',2 - Jennifer 1. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD, 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOSEPH D, RENEKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 05-3017 CIVIL ACTION - LAW NATALIE 1. RENEKER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330Hc) AND ~ 3301 Cd) 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 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 waiver 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: 9-/lr(h- 0 ...., c = fil = "--~- e.n rll pJ V> -< rT1 ::I: ~?f,i'; ." m:::tl .~~~,.:' N ~~ ~::(',::: Cl ~(~ ""0 I' '-C :x: ~~:i:l p,-,;;: O~ ~.. ?;: ?5 ;:;;J w , Ul -< - F:lrILESIDA T AFILEIGenenl!ICuJTenll 1122J.l.affCOIl Created: 9/20/04 0,06PM Revised: 9/15/05 4:38PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD, 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff JOSEPH D. RENEKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 05-3017 CNIL ACTION - LAW NATALIE L. RENEKER, Defendant IN DNORCE AFFIDAVIT OF CONSENT 1. June 10,2005, A Complaint in Divorce under 9 3301(c) of the Divorce Code was filed on 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. 9 4904 relating to unsworn falsification to authorities. Date: 9;;9~ , IVa/a/AA~%C7'~/~' __ Natalie L. Reneker, Defendant (") c ;.;;~ ft; _.._i: i .L -~ Eh ;i ~ .- }-~ 7,f, "~,. C, J>c:: ~ "" = = c.n C/> rrl " N ~ :C::U nl..... ",m _::.06 o _..J -:rj- (:;:rJ ZO ~m :t -< :r:>o 3 'f.> N Jennifer 1. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD, 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOSEPH D, RENEKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 05-3017 CIVIL ACTION ., LAW NATALIE 1. RENEKER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~330Hc) AND & 330Hd) OF THE DIVORCE CODE I, 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 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 immediately after it is filed with the prothonotary, I verify that the statements made in this waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, S 4904 relating to unsworn falsification to authorities, Date: 9//9 h5 , UataL~/~t'70~- / Natalie L, Reneker, Defendant 0 ,.., ~ <:::> C "" < "" ~~ (/) -r)'.~J !=ti fT~-n Z~:; i8~ -::>'r N ~';_::, '..~ \... ~.,., ~' ~- ~ (:>5 ~~>F; z om ;;:>c: .;:> -"'l ~ .. ~ N -<. - HECEIVEL SEP 2 0 21185 MDwr F\FILE$\DAT AFILE\Gel1e,';).I\C\ln.~"t\ll :r.u, \, PM Creuted: 9/20/04 006PM Revised 4/;12/05 11.33AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH D. RENEKER, Plaintiff v, NO, 05-3017 CIVIL ACTION - LAW NATALIE L. RENEKER, Defendant 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. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code, 2. Date and manner of service of the complaint: via certified mail, restricted delivery on June 13,2005, Affidavit of Service filed, 3. Date of execution ofthe Plaintiffs affidavit of consent required by Section 3301 (c) of the Divorce Code; September 16, 2005; by the Defendant; September 19,2005. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice III S3301(c) Divorce was filed with the Prothonotary: September 20,2005. Date Defendant's Waiver of Notice III S3301(c) Divorce was filed with the Prothonotary: September 21, 2005, MARTS ON DEARDORFF WILLIAMS & OTTO (\ (\. \ ,\0/))/, Date: September 22, 2005 By Jennifer. s:-Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff n "" ~ "'" c: "'" :..,.. 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