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HomeMy WebLinkAbout05-4579 MADELINE SICA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D5-~r;"!9 {!/'oiL~, JAMES D. ROMBERGER, Defendant CIVIL 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 fol/owing 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 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 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 at the 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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 MADELINE SICA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O~ - Ai.s'79 GULL ~02.."'1 CIVIL ACTION- IN DIVORCE JAMES D. ROMBERGER, Defendant COMPLAINT Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Madeline Sica who currently resides at 1709 Wyndham Road, Camp Hill, Pennsylvania 17011. 2. Defendant is James D. Romberger who currently resides at 945 Lewisberry Road, Lewisberry, Pennsylvania 17339. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 20, 2004 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are: A. Section 3301 (c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Section 3301 (c) of the Divorce Code. McNEES WALLACE & NURICK LLC By I Helvy . #53148 100 Pine Stree . P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Dated: g J l.c I oS- Attorneys for Plaintiff VERIFICATION Subject to the penalties of 18 Pa. C.S.A. 9 4904 relating to unsworn falsification to authorities, I hereby certify that the facts set forth in the foregoing document are true and correct to the best of my information and belief. Dated: Cj IIJ;/ OS- ~Qd{Lrv Mad line Sica k{l~, / ", 0 n c:-..> ('- C:.:;) -n ~ a' r:-, (/) 8 D -..... r-"1 1 -..c'l h_:"j ~ \) I C'. C> -c:-, :::1.:: ( ') Cf) ~_... ell - C,) ~.;-~ '"' ~ '_.J ~ ~ .. ;< ~ 0'-' ~ :e ~ McNEES WALLACE & NURICK LLC By: J. Paul Helvy Attorney ID No. 53148 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile phelvva.ilmwn.com Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4579 MADELINE SICA, Plaintiff JAMES D. ROMBERGER, Defendant CIVIL ACTION- IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, James D. Romberger, Defendant herein, do hereby swear and affirm that have I accepted service of a true and correct copy of the Complaint in Divorce in the above- captioned action on 9 - /0 ,2005. 1/ () c .... q;~i'; z~:. U).,,: r~c:) .". ~C) ",,0 .>'c ~ '" = = CJ" (/) fT1 -0 ~ ~~ ~~, :C-n ()o Zrn 9 ;.>p '-< U1 -u :x 4? N N MADELINE SICA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-4579 JAMES D. ROMBERGER, Defendant CIVIL ACTION- IN DIVORCE AFFIDAVIT OF CONSFNT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 6, 2005. 2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days have elapsed since the date of 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. Section 4904 relating to unsworn falsification to authorities. " ld- -13- OS Date \. add~ ~C/CL I ,. ",. MADELINE SICA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-4579 JAMES D. ROMBERGER, Defendant CIVIL ACTION- IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. _1;j.-13 -OS Date ~adel<c~ ~'C'-1Ju Mad ne Sica v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4579 MADELINE SICA, Plaintiff JAMES D. ROMBERGER, Defendant CIVIL ACTION- IN DIVORCE AFFIDAVIT OF CON~FNT 1. A Complaint in Divorce under Section 3301 (C) of the Divorce Code was filed on September 6,2005. 2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days have elapsed since the date of 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. Section 4904 relating to unsworn falsification to authorities. /2.- f3- OS- Date ~M-,fj ~0"'- amesD.Rombe~er ;-~..l ., .~-! MADELINE SICA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4579 JAMES D. ROMBERGER, Defendant CIVIL ACTION- IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. /7- d. 0';- Date ~~ l2 fIl:m~ Jllmes D. Romberger -, "" -1 .1 > MADELINE SICA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4579 JAMES D. ROMBERGER, Defendant CIVIL 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: 1. Ground for a Divorce: 23 Pa. C.S. 93301(c) - Mutual Consent - Marriage irretrievably broken. 2. Date and Manner of Service of the Complaint: Date of service was September 10,2005. The Complaint was served via regular and certified U.S. mail, sent to James D. Romberger at 945 Lewisberry Road, Lewisberry, Pennsylvania 17339. An Affidavit of Acceptance of Service by U.S. Mail was signed by James D. Romberger on September 10,2005, and filed with the Prothonotary on September 15, 2005. 3. Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: By Madeline Sica: December 13, 200ei By James D. Romberger: December 13, 2005 4. Related Claims Pending: All outstanding claims have been resolved by agreement. 5. Plaintiffs Waiver of Notice in 93301(c) Divorce was filed on December 16, 2005. . 6. Defendant's Waiver of Notice in 93301 (c) Divorce was filed on December 16,2005. J. Pa Helvy, Esqu' e I. . 53148 I . , McNees Wallace & Nurick LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA 17'108-1166 Attorney for Plaintiff Date: December 20, 2005 (J --, 0 ~? ,:: <.:~:;, -n <J' -' 0 --1 n :::::11 (;':i , ,-q " rnp -nlG N -riG N :':),,(t~ -'1'; \ -0 :s-.':: -,,- ,,,c N () p ~, .r.:- :1.'1 -.l .-<: ;+:+:+0 Of. + ot' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~Of.++++~ot'~ot'+++~ot'+ot'+ +~++++Of.~Of.+++Of.~++Of.+++Of.+~++++'I'+Of.~ot'++ot'ot'+ot'~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'I'++Of.++'I'~++ ++Of.+'I''I'+Of.Of.'I'Of.Of.+ot'+++Of.+++++~++ot'? IT IS ORDERED AND . . . .. .. .. . . . ... IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. Madeline Sica No. 05 4579 VERSUS James D. Romberger DECREE IN DIVORCE AND NOW, ~)7 , J ~:S""Ol/YI. ~S Madeline Sica , PLAINTIFF, DECREED THAT AND James D. Romberger , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT The Marital Settlement Agreement dated December 7, 2005 shall be in ;decreer /' By PROTHONOTARY +'1' 'l'++ + Of. '+: + Of.~ +~'l' 'l'~ Of. + ~ J. -F'1~''''7f')f I-ftfj of )>~7' "'1M -r:l1f<'CY Jnpjl ~KI cy- -rrfl,w f-c1oeJ l?3.'rjrC) - ~O/ '1/' ... ..\.- .