HomeMy WebLinkAbout05-5524
Heather L. Paterno, Esquire
It) #25454
GOLDBERG, KATZMAN & SHIPMAN, P.c.
320 Market Street
POBox 1268
Harnsburg, P A 17108.1268
(717) 234-4161. (717) 234.416\ (facsimile)
( 'mmse/ lor jJ/wnflll
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. O~ - ~1)5:J.Lf
Civil Term
ERIN N. ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is JOSHUA N. ROSENCRANCE, whose current address is 1429
Meadow Lane, Dauphin, DauphinCounty, Pennsylvania.
2. Defendant is ERIN N. ROSENCRANCE, whose current address is 169 Sheep
Bridge Road, York Haven, Cumberland County, Pennsylvania.
3. Plaintiff is the Father, and Defendant is the Mother of the Children, who are the
subject of this action.
4. Plaintiff seeks shared legal and primary physical custody of:
Name: Bryce Edward Rosencrance
Date of Birth: January 10,2003
Name: Mikayla McKenzie Rosencrance
Date of Birth: April 31, 2005
Present
Residence:
169 Sheep Bridge Road
York Haven, Pennsylvania
5. Bryce and Mikayla Rosencrance (hereinafter referred to as "the Children") were
born during the marriage of the parties. Plaintiff and Defendant were lawfully married on
August 31,2002.
.
6. From birth to present, the Children have resided with the following people at the
following addresses:
9/05 - Present
169 Sheep Bridge Road, York Haven, Pennsylvania
With Defendant and the children's maternal grandmother, Colleen Bashore
4/03 - 9/05
221 S. 5th Street, Lemoyne, Cumberland County, Pennsylvania
With Plaintiff and Defendant
1/03 - 4/03
1429 Meadow Lane, Dauphin, Dauphin County, Pennsylvania
With Plaintiff, Defendant and the children's paternal grandparents, Jeff and Laura
Rosencrance
7. Plaintiff has no information of a custody proceeding concerning the Children
pending in a court of this Commonwealth.
8. The best interests and permanent welfare of the Children will be served by the
relief requested.
9. Plaintiff has not participated as a party, witness or in another capacity or in other
litigation concerning the custody of the Children in this or another Court.
10. Plaintiff currently lives with his parents, Laura and Jeff Rosencrance at 1429
Meadow Lane, Dauphin, Dauphin County, Pennsylvania.
11. To the best of Plaintiffs knowledge, Defendant resides with the Children and her
mother, Colleen Bashore, at 169 Sheep Bridge Road, Yark Haven, Cumberland County,
Pennsylvania.
OD,\ f./,PCDOCSIDO('S\/27609\ /
2
WHEREFORE, Plaintiff respectfully requests that the Court grant the parties shared
legal custody and that he be awarded primary physical custody of his children, Bryce Edward
Rosencrance and Mikayla McKenzie Rosencrance...
/ 1/-1
/ ~ /
GOT;; G K
/ '~i/1'1~i7
~ather Patem<ji ,
A1tomey I.D. ~~i506
Xo Market Street
P.O. Box 1268
.' arrisburg, PA 17108-1268
(717) 234-4161
(717) 234-6808 (facsimile)
Date:
','1 01 ~ r'
/u'lv,U')
Attorney for Plaintiff
OO,l./A IPCDOCSIDOCSI/27609\/
3
VERIFICATION
I verify that the statements contained in the foregoingcOM:PLAINT FOR Cl)'STODY are
true and correct to the best of my knowledge, information and belief. I understand that false
statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities.
Date:
'0-'2-0 -o~
~CRANCE
-
() -tq,.
-r:J 7' -'!
1t- ~ -
,
\)
~ \:J
~ (}J (
-c ' ,
0- ~ . ',\
- ~ C') :.::.:l
~ -:t "
-... ,
~ r', ....,
~
-L (/;
..
..
"'....,
--_._~-----------"-_._-_._--
-------------------- - -
~
Ikil(h\:1 ['<I!<:1ll0, E~qum;
1))'iS7S0h
(j()II)BmG KAI'i'JvJ.\1\, P,C
120)l.'larkctSlrccl
I', () Box 1268
11!lITI'iliurg.Pi\ 1710S-12(,S
1717)2JcJ-.oJ16l:1717)234-4161(tacsimile)
_~'I}!!'.1 J_..~~!J!:!: i '1(/ 1I1/J1/
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. () S' - .s' S:<L./
Civil Term
ERIN N, ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND
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 with twenty (20) days after this
Complaint and Notice are served, by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the claims set forth against you,
You are warned that if you fail to do so, the case may proceed without you and a judgment may
also be entered against you by the Court without further notice for any money claimed in the
Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
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,
I.A WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MA Y LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LA WYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
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 Court Bedford Street
Carlisle, P A 17013
Telephone: (717) 249.3166
Of)-\ f..j ',f'( 'j)OC')"'DOC5l". I 27-130\ /
.
l-lelHher L Paterno, Esquire
ID#87506
GOLDBERG KATZMAN, r,C
320 Market Streel
POBox 1268
ltarrisbllrg, PA 17108-1268
(717)234-4161.017)134-4161 (facsimile)
(-o/In.\d/iJrl'lmnliff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
JOSHUA N, ROSEN CRANCE,
Plaintiff
v.
NO. 0<; - c;5:2~
Civil Term
ERIN N, ROSENCRANCE,
Defendant
CIVIL ACTION ~ LAW
IN DIVORCE
WAIVER OF COUNSELING
JOSHUA ROSENCRANCE, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that
I may request that the Court require my spouse and I to participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Office of
the Prothonotary, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
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. Section 4904 relating to
unsworn falsification to authorities.
Date: lb-~() .0S
~~NCRANCE
<-
HCiIlher L" Paterno, Esquire
I D. 1'~7506
{jOLDI'lERG I(ATZ\IAN, P,C
.'20 ~larkct Street
1'. () Box 1268
Harrisburg,I'A 17108-1268
(717)D4-4161,(717)2J4-4161 (facsimile)
('(lilllldjorl'!illllllfl
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JOSHUA N. ROSENCRANCE,
Plaintiff
\,
NO, (J5' - ).t:;;).L(
Civil Term
ERIN N. ROSENCRANCE,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
COMPLAINT IN DIVORCE
1, Plaintiff, JOSHUA N. ROSENCRANCE, is an adult individual, who currently
resides at 1429 Meadow Lane, Dauphin, Dauphin County, Pennsylvania.
') Defendant, ERIN N, ROSENCRANCE, is an adult individual, who currently
resides at 169 Sheep Bridge Road, York Haven, Cumberland County, Pennsylvania.
3. Plaintiff avers that he has been a bona fide resident in the Commonwealth of
Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint.
4. The parties were married on August 31, 2002 in York, Pennsylvania.
5. There have been no prior actions of divorce or annulment filed by either of the
parties hereto.
6, Plaintiff has been advised of the availability of counseling and that Plaintiff has
the right to request that the Court require the parties to participate in counseling,
7, Plaintiff requests the court to enter a decree of divorce.
COUNT I
8. The averments of paragraphs 1 through 7 herein are hereby incorporated by
reference thereto.
9, The marriage is irretrievably broken.
WHEREFORE, Plaintiff prays Your Honorable Court to:
a) Enter a Decree in Divorce, divorcing the P1aintifffrom the bonds of
matrimony heretofore existing between Plaintiff and Defendant; and
b) Order such other relief as the Court deems just and reasonable.
GOLDB~RG KA TfMA~({C:,- ,.'
, ,,_/
,-- /
~
----.-;--__n_____
.J / /
/ t er Pate,D./
j;(" t mey l.D.ff87506
o Market Street
, .0, Box 1268
Harrisburg, PA 17108.1268
(717) 234-4161
(717) 234-6808 (facsimile)
Date:
/'(.: , I ,1 (")'
. .- " I - ~ _
Attorney for Plaintiff
2
VERIFICATION
I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are
true and correct to the best of my knowledge, information and belief. I understand that false
statements contained herein are made subject to the penalties of 18 Pa,C,S, Section 4904 relating
to unsworn falsification to authorities.
Date: /0.'-0 '0"-
S?~CRANCE --
" /
.J
-4q..
-p ~ :c
~ '*'- \)
V)
:i~V
C> ..0 -J
~ S ?-
"f:
J:'
,- , ,-^,
,\
__I
,,--- ~
'!
...;.'.
--------
.
JOSHUA N. ROSENCRANCE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
05.5524
CIVIL ACTION LA W
ERIN N. ROSENCRANCE
DEFFNDANT
IN CUSTODY
ORDER OF COURT
AND NOW.,. .,_..Iues,da~,No"e.mberOI,,20,OS ...___' upon consideration oCthe attached Complaint.
it is herchy directed that parties and their respective counsel appear heCore Melissa p, Creevy, Esq.
at .,MDJ l\1_anl~ve's, 1901 StateSt, CamP Fiill,Pi\ 1701} on . "Frid",,,,December 09,2005
, the conciliator,
at 11:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort \vill be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children ajl:C five or older mav also be present at the conference. Failure to appear at the conference llll.l\
provide grounds for entry of a temporary or pennanent order.
Thc cnurt hereby directs the parties to furnish any and all existing Protection frnm Abuse nrders,
Special Relief orders, and Custndy orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By:
. IsL__M.el~sa P'(]l'e~,VJ1..E.sg.
Custody Conciliator
, ',{\
u_-r--4 .
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disahilites Act of 1990. For information about accessible Cacilities and reasonahle accommodations
availahlc to disahled individuals having business hefore the court, please contact our ortlce. All arrangements
Illllst be made at least 72 hOLlrs prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR A TTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY 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
3" South Bedford Strcet
Carlisle, Pennsylvania 170 I 3
Telephone (7 I 7) "49.3 I 66
~fJt7:Z~ ~
1I-;p '7 /'CfrMI ~/i.,
~;Yfp~r~~n
'v'lNV,\lAS~jN'3d
l't.1nr('" ''''::'.'',;i'~:....!::C11Nn~
~l\i,'""." '. "~'''''''
CS :6 HV 2- AON saUl
AtJVlGNO:jlCUd 3H! :10
38/:!Xj-{j311:l
5r:;- C'-)/
So- (',//
50(",/1
-
. ~.
IlealllcrL l'nterno, hquire
I D #15454
(;OLDBERG, K/\ TZMA:'>J & SHIPMAN, P,C
320\1arkelStreet
p O,IlQxI26&
Harrisburg, PA ]7108-12611
(717)234-41(,1:(7]7)234-4]61 (facsimile)
_('<lIIII.I"! !{Jrl'lum!ljl
JOSHUA N, ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 0[; - ~t;5;),y
Civil Term
ERIN N. ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
I. Plaintiff is JOSHUA N. ROSENCRANCE, whose current address is 1429
Meadow Lane. Dauphin, DauphinCounty, Pennsylvania.
2. Defendant is ERIN N. ROSENCRANCE, whose current address is 169 Sheep
Bridge Road, York Haven, Cumberland County, Pennsylvania,
3. Plaintiff is the Father. and Defendant is the Mother of the Children, who are the
subject of this action.
4. Plaintiff seeks shared legal and primary physical custody of:
Name: Bryce Edward Rosencrance
Date of Birth: January 10,2003
Name: Mikayla McKenzie Rosencrance
Date of Birth: April 31, 2005
Present
Residence:
169 Sheep Bridge Road
York Haven, Pennsylvania
5. Bryce and Mikayla Rosencrance (hereinafter referred to as "the Children") were
born during the marriage of the parties. Plaintiff and Defendant were lawfully married on
August 31. 2002.
:. . ~
6. From birth to present, the Children have resided with the following people at the
following addresses:
9/05 . Present
169 Sheep Bridge Road, York Haven, Pennsylvania
With Defendant and the children's maternal grandmother, Colleen Bashore
4/03 - 9/05
--- 221 S. 5th Street, Lemoyne, Cumberland County, Pennsylvania
With Plaintiff and Defendant
1/03 - 4/03
1429 Meadow Lane, Dauphin, Dauphin County, Pennsylvania
With Plaintiff, Defendant and the children's paternal grandparents, Jeff and Laura
Rosencrance
7. Plaintiff has no information of a custody proceeding concerning the Children
pending in a court of this Commonwealth.
8. The best interests and permanent welfare of the Children will be served by the
relief requested.
9. Plaintiff has not participated as a party, witness or in another capacity or in other
litigation concerning the custody of the Children in this or another Court,
10. Plaintiff currently lives with his parents, Laura and JeffRosencrance at 1429
Meadow Lane. Dauphin, Dauphin County, Pennsylvania,
11, To the best of Plaintiffs knowledge, Defendant resides with the Children and her
mother. Colleen Bashore, at 169 Sheep Bridge Road, York Haven, Cumberland County,
Pennsylvania.
on...\ /.!'J'cooC<"VJOCSI! 27609', f
2
"
~
WHEREFORE, Plaintiff respectfully requests that the Court grant the parties shared
legal custody and that he be awarded primary physical custody of his children, Bryce Edward
Rosencrance and Mikayla McKenzie Rosencrance,,,
/, -
/ I
GOI;,
'j f "
'11,,1;" 1 I,
,(,k/j jV
~ather Patern<;i ,
Altorney LD. #lYiS06
~o Market Street
PO, Box 1268
arrisburg, P A 17108-1268
(717) 234-4161
(717) 234.6808 (facsimile)
Date:
IOlloC)
Attorney for Plaintiff
OLJMA \pr IJOCS',DO('S',j 2 7609\,1
3
'.
"
VERIFICATION
I verify that the statements contained in the foregoing CoMPLAINT FOR CUSTODY are
true and correct to the best of my knowledge, information and belief. I understand that false
statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities,
Date:
,0.2.0 .oS-
~CRANCE
-
() -tq.
-,:J 7"- ~
}I:- q. -
I;)
- "'<;:) \:J
...( tJ-J ("'c
cr ~ -,J ';1
~ ( , .'"
r--> ...:t ~
~ ,...,
1- .' .
,-.f", ".
-
----
..
Heather L. Paterno, Esquire
Attorney I. D, No. 87506
Goldberg Katzman, P.c.
J20MarketStreet
P_O. Box 1268
Harrisburg, PA 17]08-1268
relephone: (717)234-4161
Allornl!-ys(or "faint!t!
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5524 Civil Term
ERIN N, ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
)
)
)
SS:
COUNTY OF CUMBERLAND
Personally appeared before me, a Notary Public, in and for said Commonwealth and
County, HEATHER L. PATERNO, ESQUIRE, who being duly sworn according to law deposes
and says that on October 26, 2005, she sent a copy of the Complaint in Divorce by certified mail,
return receipt requested, to Erin N. Rosencrance, at 1 epbridge Road, York Haven,
Pennsylvania 17370, and the return receipt card sign d rin ose ra d shown as
being delivered October 27, 2005, is attached heret h eo
Sworn to and subscribed before me
this !;./ day of:lVtm.errk1 ,2005.
'.,l~l_
Nolana! Seal
Sally A. Marsh, Nolaly Public
City Of Harrisburg, Dauphin County
My Commission Expires Sept. 17, 2(X)6
Men~ P~nr'l<:.vt\""",:,~:',--;';;.;r'c":i:)~;nr; Of Notartes
,Mar , Notary Public
My Commission Expires: 9/17/06
..ODMA IPCDOCSIDOCSl9793817
.1(
U.S. Postal Service
CERTIFIED MAIL RECEIPT
(Domestic Mall Only: No Insurance Coverage Provided)
Return Receipt Fee
~ (Endorsement Required)
I:J Restricted Delivery Fee
o (Endorsement RequIred)
o Total Postage & Fees $
...D
'" S'
CJ
nJ si
CJ .,
CJ CI
f'-
Certified Fee
U1
",
CJ
<0
",
CJ
r'l
f'-
Postmark
H....
ID-d..(r05
Erin N. Rosencrance
169 Sheepbridge Road
York Haven, PA 17370
:,. .
"
SENOER: CUVlPLETE 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 maiipiece,
or on the front if space permits.
A.Si~re ._
X/ /?~-
ecetvecl by (Printed Name)
1. Article Addressed to:
C. Date of Deli~
O}'7.o01
D. Is delivery address different from item 1? 0 Yes
If YES. ~'dQJlvfl~ address below: 0 No
Erin N. Rosencrance
169 Sheepbridge Road
York Haven, PA 17370
;-",
RESTRICTEO DF:L1VERY
2, Article Number 7002 0460
(Transfer from service label)
PS Fonn 3811, February 2004
3. _ Type
)(j CertIfIed Mall 0 Express Mall
o Registered p( Return Recetpt for Merchandise
o Insured Mall 0 C.O.D.
.. Restricted Delivery? (Extra Fee)
)B( Ves
0002 7103 8035
Domestic Return Receipt
102595-02-M.1~
(")
~--;
r->
(;~
C;"
<;:.J'I
5
...c
I
W
~
:1.,...
P'c
-n0l
:1,9
'~_i,O
~-'.~:r!;
.:~~:~.
""
__or
-",.
,^,
.'
".:>
'~
"-'
-
f<. ,_ ; , ,_. Li hhl\ _~ . L
1
JOSHUA N, ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5524 CIVIL TERM
v.
CIVIL ACTION - LAW
ERIN N. ROSENCRANCE,
IN CUSTODY
Defendant
AND NOW, this day of March, 2005, counsel for the parties, having requested a thirty
(30) day continuance on February 6, 2006, and the Conciliator having received no further request for
the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above
captioned matter.
OR DE TO RELlN UISH JURISDICTION
:270808
/
//
V1Nv'i\lASNN:Jd
I "Jn~." -, ,. ~"~"'wn"
rU..1'1 :U..: ~_"'.;':~ ':'::;:::,'1:; h 0..)
S I ;t] Hd 91 HVH 9002
AtlV10i'-jUH1.0dd 3HJ. .:10
:rJl:J.;h]....(]31H
Paul J. Esposito, Esquire
1.0. '25454
GOLDBERG KATZMAN, P.C.
320 Marke1 Street
P. O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161; (717) 234-4161 (facsimile)
COWIlIet for Plaintiff
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5524 Civil Term
ERIN N. ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under 9 330 I (c) of the Divorce Code was filed on
October 24, 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 fmal 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 Pa.C.S. S ionJ904, relating to
unsworn falsification to authorities. /
e
8-2/
,2006
/
Date:
-'
()
c::.
:z:
-ot~f
n~.
"
:~ .
-.:1" ,-
';::...,'
, <'0-
=--;;-
~'"
-j:>- .'
"1::;' (::~
):> c:.
~
-<
,~
.,',1
,I
"'J,",;o
~
=
"'"
~
N
U1
';1-":'
~
--
~
~-n
n'\=rj
::gO
00
~""i
,'5 :D
,~0
:'--rn
o
--I
~
o
-
c.w
Paul J. Espotito, Esquire
1.0. #25454
GOLDBERG, KATZMAN & SHIPMAN, p.e.
no Market Street
P. O. Box 1268
Harrisburg, PA 17108~1268
(717) 234....161; (717) 234-4161 (fAcsimile)
Counsel for Plaintiff
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5524 Civil Term
ERIN N. ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(\:) 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 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 unsworn
falsification to authorities.
Date:'
g-Zl
,2006
(')
c
~
~-.,..,
-ocr
mj';,
'~~(
r::L
}~~ ~-,~ ,-
J?c
~
. -,'f'~.
,
,
\
\
~
,~
....,
=
~
"""
c::
C')
N
U1
-0
:::r:
<:?
~
~~
;By
'?3~
_l_ -r1
(J,~
Ofli
~,,-l
~
w
Paul 1. Esposito, &quire
1.0. #2S4S4
GOLDBERG, KATZMAN &; SHIPMAN, P.c.
320 Market Street
P. O. Box 126&
Harrilburg, PA 17108-1268
(717) 234-4161; (717) 2344161 (facsimile)
COII1Uel fOT Plaintiff
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5524 Civil Term
ERIN N. ROSENCRANCE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING
L A Complaint in Divorce under ~ 330I(c) of the Divorce Code was filed on
October 24, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree in divorce after service of notice of
intention to request entry of the decree.
4. I have been advised of the availability of marriage counseling and I understand
that I may request that the Court require that my spouse and I participate in counseling. I
understand that the Court maintains a list of marriage counselors, which list is available to me
upon request. Being so advised, I do not request that the Court require my spouse and I to
participate in counseling prior to a divorce being handed down by the Court.
5. I acknowledge that I received a copy of the Complaint in Divorce on or about
October 27,2005, via Certified Mail, Restricted Delivery. .
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.
Date: '0/1 I
,2006
d~
/I~4l /~
GRIN N. ROSENC NCE .
I (/y~ (pc.( - ~ ') s-L(
.~":''''>':: r,\"i,"
, 'l~,:':"-
, ":";'-:'
(')
c;;.
~.
""Jb._:
r:i l,~.
.'
~---.
~)-
r:;:
""-.
't~~/
:2
."
;:'It'.
~
g;
~
G)
N
(j\
.""Q
"""l'>'
~..
9.
~:;J;1
-ohj
-"t{
;-~~) ( '"
?~i-f,
.",-n
(./I''>
Zrn
o
""
~
<.?
-
v.:>
Paul J. Esposito, Esquire
1.0. #25454
GOLDBERG, KATZMAN & SHIPMAN, P.C.
320 MaBet Street
P. Q. Box 1268
Harrisburg, PA 17108~1268
(717) 234-4161; (717) 234-4161 (facsimile)
COfInHI for Plaintiff
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5524 Civil Term
ERIN N. ROSEN CRANCE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) 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 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. ~4904 relating to unsworn
falsifIcation to authorities.
Date:
q, II (
(
,2006
/ /J .-;7
6 ~ "
/f/~ f'. ~.I~#A(t
ERIN N. RO ENCRANCE
I if ~- 0: L( - ~ ') S~
o
~
<-:.,...
"'1:J i': ,
rY' ~.' .
~~. j
t,~
.;:;g
-a;
".
c:
G>
{'oJ
U'I
:s
...;.'.~
~
:r!""
rl1p:
-om
.09
(::")0
-,,~~ -'---i
~t -1l
(,.::l'c')
Zrn
o
....
~
'-?
-
w
JOSHUA N. ROSENCRANCE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5524 Civil Term
ERIN N, ROSENCRANCE,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, (0 the Court for entry of a divorce
decree:
1. Ground for divorce: irretrievable breakdown under 9330I(c) of the Divorce Code.
2. Date and manner of service of the Complaint: October 26. 2005. bv way of Certified
Mail- Restricted Delivery; si!!:ned for bv Defendant on October 27.2005.
3.
(a)
Date of execution ofthe affidavit of consent required by 9 3301(c) of the
Divorce Code: by Plaintiff on AUl!:ust 21. 2006 ; by Defendant on
AUl!:ust 11.2006
(b)(1 )
Date of execution of the Affidavit required by 9 330 I (d) of the Divorce
Code:
(2)
Date of filing and service of Plaintiffs Affidavit upon the Defendant:
4, Related claims pending:
5.
(a)
Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached:
(b) Date Plaintiffs Waiver of Notice in 9 3301(c) Divorce was filed with the
prothonotary: AUl!:ust 25. 2006
Att
)
Date Defendant's Waiver of Notice in
prothonotary: Au ust 25 2006
~::~ i:,
(,t'
.>-.
o
c
......,
'.:.':}
C;;:~)
0....
C)
-n
--1
,
.
,'.
l,_'
W
~---,
r--)
<-..
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
.
PENNA.
.
JOSHUA N. ROSENCRANCE,
Plaintiff
.
.
.
.
.
VERSUS
ERIN N. ROSENCRANCE.
.
No.
05-5524
Civil
.
Defendant
.
.
.
.
AND NOW,
.
.
DECREED THAT
JOSHUA N. ROSENCRANCE
, PLAINTIFF,
DECREE IN
DIVORCE
S t.9tt.w\ 'at,\"'
8
').00("
IT IS ORDERED AND
.
AND
ERIN N. ROSENCRANCE
, 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;
.
.
.
.
.
.
J,
PROTHONOTARY \
,~ .?? 't?'~"" ~ '7(/. $'V
~c/' r~~~-rp 'It?'QP
'.. ...': ',.
1 ' " ..
"'It .' .. 'is''L