The URL can be used to link to this page

Home My WebLink About05-5015 IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. No. () ~ - SOLS c;u ~ L <-r- 82-rYl Todd E. Rutledge, Defendant In Divorce a.v.m. 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. 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA Y BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Bar Association - Lawyer Referral Service Telephone 1-800-692-7375 (PA ONLY) or 717-238-6715 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 1990. 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. IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. No. Dr;; -SotS (!.L'u,L T~ Todd E. Rutledge, Defendant In Divorce a. v .m. COMPLAINT UNDER SECTION 3301(A) OR 3301(C) OR 3301(D) OF THE DIVORCE CODE COUNT I DIVORCE 1. Plaintiff is Julie B. Rutledge, a sui juris adult, who currently resides at 209 Chestnut Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Todd E. Rutledge, a sui juris adult, who currently resides at 209 Chestnut Drive, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately prior to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment of marriage between the parties except the action represented by this Complaint. 6. The marriage is irretrievably broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION SECTION 3502 9. The allegations of paragraphs 1 through 8 hereof are incorporated herein as fully as though set out at large. 10. The parties have been unable to determine and equitably dispose of their respective rights and interests in the marital property. 11. Plaintiff will, within 60 days after service of this Complaint upon the Defendant, cause to be filed an inventory and appraisement of all property owned or possessed at the time this Complaint is filed. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide, distribute and assign the marital property pursuant to the provisions of Section 3502 ofthe Divorce Code. \. if) /_l Date:..,.::JIt-~l'/t }:wu /~ jt.h - I By: Respectfully submitted: TRGOV AC LAW OFFICE . I' I /1 d.~//1" ) / -' .'/ , I c11' . 'v. (I (LlfN1;tr . TERI H tL STILTNER, ESQUIRE Attorney J.D. No. 86337 The Professional Arts Building 25 Penncraft Avenue, Suite 310 Chambersburg, Pennsylvania 17201 (717) 262-9091 r' Attorney for Plaintiff I verify that the statements made in this Complaint are true and correct, and understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. K..... p ~ ~ ~ ~ ~ ^ lJ .{q. 0 c..-:) r- c.f\ ..4 ~ ";.::.-:: - ~ ..0 ~< .' (/') :1: .." () r'1 rnF': ........ Q -a ~.ro c'i"9 '- ........ V, N '.,:-~ .- ~ 0 ~ c....) ':;'IQ; ~ C' C' .C....n W 0 ~ C)("'1 , .......~_. :?;p. \ -- Cv C-:? ~ ~ f j:'" c) ....... J;:" :~ p: b N ,~ 0) ~ P: () 7- - I...-L. r 0 ~ c.., (' IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. F.R. OS-SOlS Todd E. Rutledge, Defendant In Divorce a.v.m. AFFIDAVIT OF SERVICE 1, M. Teri Hall Stiltner, attorney for Julie B. Rutledge, Plaintilf abovc, hereby certify that J served a copy of the Complaint Under Section 3301 (A) or 3301 (C) or 3301 (D) of the Divorce Code on Todd E. Rutledge, Defendant by depositing at true and exact copy thereof in the United States maiL first class, postage prepaid, addressed as follows: Mr. Todd Rutledge 209 Chestnut Drive Shippensburg, PA 1757 TRGOV AC LAW OFFICE 0":'(1 ~f."k;t1 )r,,- \ - By: 'Pi,<LJk~ M, TERI HALL STILTN R, ESQUIRE Attorney I.D. No. 86337 , Trgovac Law Office Prolessional Arts Building 25 Penncraft Avenue. Suite 3 I 0 Chambersburg, Pennsylvania 17201 Telephone (717) 262-9091 Attorney for Plaintiff USPS - Track & Confirm ~' UNITED STtITES POSTllL SERVICE" Page] of I Home I Help I Sign In Track & Confirm Search Results Track & Confirm FAQ. Label/Receipt Number: 70051160000206610876 Detailed Results: . Delivered, October 03,2005,2:33 pm, SHIPPENSBURG, PA 17257 . Notice Left, October 01',2005, 1 :26 pm, SHIPPENSBURG, PA 17257 . Acceptance, September 30,2005,9:15 am, CHAMBERSBURG, PA 17201 0:.: 8Jck Enter Label/Receipt Number I fhmmr.ta USPs.t"(mr H(Jmt~. Go> Track & Confirm by email Get current event information or updates for your item sent to you or others by email. G (,r ~ 3. Servtce Type 'JIi Certlfled Mall 0 Express Mall o Registered 0 Return Recelpt for Merct1endl8e o Insured Mall 0 C.O,D. 4. Restricted Delivery? (Ext1a Fee) ~Yes 700S 1160 0002 0661 0876 SENDER COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. , . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Address&d to: \'-1\( ,T oM 'RvJ-\ecl.q~ (001 CJlt'Sh\l)t S:::.f\ n Shc:>r~.r'<<.b.A\~, ~ \lIS", RESTRICTED 2. Article Number (7Jansfer from service Isbel) PS Form 3811, February 2004 B. Received by (Prl red Name) C. Oat. of 'T~ D. Is delivery address different from item 11 0 Yes If YES, ant., deJJvery oddress below: )il:NO Domestic Return Receipt 102595-02-M-154O 1 http://trkcnfrml.smi.usps.com/PTSlntcrnetWeb/lnterLabeIOctail.do 11/4/2005 -'.". "'.~~ LilD f~lL;,~ (_~J J:':':-,\_. -0 -- ).~-' c-,; '-::' ~'3 '-, U1 c..n - C:5 -<:: I \.0 ~~ ;1(: --,--, , i ." ,. IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. No. 05-5015 Civil Term Todd E. Rutledge, Defendant In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Compliant in Divorce under Section 330l(c) or 3301 9(d) of Divorce Code was filed on September 23,2005. 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. 1 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 the Affidavit 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: /ohlkoCf :;;;}jt/?d~ Todd E. Rutledge ~ $" 5/~s ,--t -- --r Xi3 ':,X (~CJ c--t x> -';0 - :-< N ..D _.._,.l -< g S -on,-, 0;;:' fl., z.: ~:: r_l. ?; (- ~~ ~ ......, c::> c::> ~ Z o <: w o -0 ::E: o -n ~:u ~m '09 -'-l~ I-d 0- -..,.0 /-....rn 9 ~ - .. (..J1 .- C/ .---. . ~ ! . , IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. No. 05-5015 Civil Term Todd E. Rutledge, Defendant In Divorce a.v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. [ 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 the 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:~OJ/~o" ~1f!j& (") c: :;e:' '"tJ l"': [11((' Z;~:- 2:. t~.1 t;~:; z, ::(, ~ = <::r' ~ c,.) o -0 -:; ~ -' ~~ Bb ::::::.\""1', ::S-n ~~ S ~ (J1 ,f:"' IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. No. 05-5015 Civil Term '" Todd E. Rutledge, Defendant In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Compliant in Divorce under Section 3301(c) or 3301 9(d) of Divorce Code was filed on September 23,2005. 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 the Affidavit 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: 11 / cli/ tk> , o ~. ,...., c;:;. = c:1"' o rr'1 n ~ .-4 :I:-n rne -om '-nt? c~ c.J ~T:. :;~'\ (6~ -\ ':T-'": ~ w L,) ., Cl CJ"\ IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Julie B. Rutledge, Plaintiff Civil Action - Law v. No. 05-5015 Civil Term Todd E. Rutledge, Defendant In Divorce a.v.m. 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 of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 der.ree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in the Waiver 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: II / dJ btp " 2s~ ~~WOg~ Julie B. utledge ~ c:::;:l c:t:'" ~ c-> - c..:> ~ ~"'1"i rl1 to :9n D) Oe' ..-j -1, .~'\ - --f1 C4r'") 001 -\ ?o. :;..::: -0 -'f7 ~ t:.f! o 0" . IN THE COURT OF COMMON PLEAS OF PENNSYL VANIA - CUMBERLAND COUNTY BRANCH Julie B. Rutledge, Plaintiff CIVIL ACTION-LAW v. F.R. 05-5015 Civil Term Todd E. Rutledge Defendant IN DIVORCE a.v.m. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under ~ 330 I (c) of the Divorce Code. 2. Date and manner of service of the complaint: A Complaint was mailed to Defendant via certified mail restricted delivery, and was received by Defendant on October 3, 2005. An Affidavit of Service was filed on November 4,2005. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff on November 29, 2006; by Defendant on October 31, 2006. (b) (I) Date of execution of the affidavit required by ~ 3301 (d) of the Divorce Code: (2) Date of filing and service ofthe Plaintiffs affidavit upon Respondent: 4. Related claims pending: Settled by private agreement; 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: December 13, 2006. Date Defendant's Waiver of Notice was filed with the Prothonotary: November 30, 2006. :':":~-':lV'JnJ 9 8 : I Hd I Z :130 9002 AW10NOHICHd 3Hl .:10 301 :J::lO-Q::]l!::J ~~ ~~ ~~ ~ ~ ~~~~~~ ~~~ ~ ~ ~~~~"'''' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF JULIE B. RUTLEDGE Plaintiff VERSUS TODD E. RUTLEDGE Defendant No. OS - 5015 DECREE IN DIVORCE AND NOW'V~ "2-b ~, IT IS ORDERED AND DECREED THAT Julie B. Rutledge , PLAI NTI FF, AND Todd E. Rutledge , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECJk~ ~S ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; V~ ~ ~ 2 n;:r~~ "'-YvL ~ . ;u~ )~" ~L#.[2 ~1?W~.l TV J rj ./ L.Ci <:::/ /