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Home My WebLink About05-6701 .. ~ PAULA. ROUSH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. (J:)- G, 70 J Civil Term JANET E. ROUSH, : ACTION IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in CDurt. If YDU wish to defend against the claims set fDrth in the foUDwing pages, you must take prDmpt action. You are warned that if you fail tD do so, the case may proceed withDUt you and a decree Df divorce Dr annulment may be entered against you by the Court. A judgment may alSD be entered against YDU for any Dther claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to YDU, including custody or visitation Df your children. Where the grDund for the divorce is indignities or irretrievable breakdown Dfthe marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County CourthDuse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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. Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 . . PAUL A. ROUSH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. ND. 03,-. ~ 70 I Civil Term JANET E. ROUSH, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE I. Plaintiff is Paul A. RoushRDush, a competent adult individual, who has resided at 2 N. Hanover St., Apt 2F, Carlisle, Cumberland CDunty, Pennsylvania, 17013, since September 2005. 2. Defendant is Janet E. Roush, a competent adult individual, WhD resides at 246 E. North St., Carlisle, Cumberland CDunty, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the CommDnwealth fDr at least 6 mDnths immediately previous tD the filing Dfthis Complaint. 4. The Plaintiff and the Defendant were married on March 23,2001 in Cumberland CDunty, Pennsylvania. 5. There have been nD prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right tD request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children tDgether. 8. Plaintiff and Defendant are both citizens of the United States Df America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces Dfthe United States Df any Df its allies. .I ~ 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably brDken. WHEREFORE, Plaintiff requests 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. 94904 relating to unSWDffi falsification to authorities. /&( )~ Paul A. RDush, Plaintiff ,,;7/ ~~ Respectfully submitted, ""'. \ ell- \ ~ 0"'- ~ '?-v ~~ ~. .~c1 ", ~ ~ '0-' v'} -- -?; v r-' c? (:.:c' c.>~ c::, r~;"'1 <) ,,~ N V' co! C'- ,~ -(j a .'n .-1 :C-n Crtf" rT' C1 , C) , "'1', ,.< -'j :},t'; ~>,)('n .:.:\ ~o :..: iSi C) (.,.1 ..-----,.. ' --~.--------- PAUL A. ROUSH, vs. JANET E. ROUSH, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ND. 05 - 6701 Civil Term ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this January 27, 2006, I, Jane Adams, Esquire, hereby certifY that on January 21, 2006, a certified true copy Dfthe NOTICE TO DEFEND and COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: Janet E. Roush 246 E. North St. Carlisle, Pa. 17013 DEFENDANT I . Complete items 1, 2, end 3. Also complete Item 4 n Restricted Delivery Is desired. . Print your nerne and address on the reverse so that ~ can return the card to you. . Attach this card to the back of the ma/lplece, or on the front n space permits. 1. Article AddAlSSllCl to: COMPLETE 7 HIS ~~CTION ON DELIVERY ~~[~ \~ Cl Agent D Addressee B. Received by (Printed Name) C. Date of Delivery 1:...\_ ~f\";' \\~""D ~/-I D. Is delivery address different from Item 1 ;~zrdE.adiiJobeIOW!f SNr C!;,1?LI6Lf.. ~O/g -o(~~ ~~s~ ~ ~. ~~<;t-, ~ ,rA llb\~ ," 3. Servlco ~ . Cortlfled Mall Cl ExpJess Mall Cl Regrs"red Cl Retum Receipt for Merchandise Cllnsured Mall Cl C,D.D. 4, Restricted DelIvsty7 (Extra Fes) . Ves, 2. ArtlcleNumber ' 7003 1010 IJ004 7818 7074 (IIan- tlt>m S01Vfce IaJ>eI) Return Receipt 102595-02-M-1540 Res~:Q&~~ J e Adams, Esquire . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF g', = <:S" '- ~ r-:> ....J (') ~ -0\.';;"' ~eT- "'.- -" --;'"'f ~}'.:~. ~~.-~:_- 1-~_I--, ';r.-'~ :.2. """ ~ Q. ~:Q -uh' -,)9 .::JC) "A:;:,-: \...-;" ':.)f") 1'~rr< , ::::t ~ '-? "" -' PAULA. ROUSH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 6701 Civil Term JANET E. ROUSH, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on December 22,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also 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. (0 I"~~ lanet E. Roush, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) AND ~3301(d) OF THE DIVORCE CODE I. I consent to 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. S4904 relating to unsworn falsification to authorities. Date: S . 9 . (p C1L~ I~~ finet E. Roush, Defendant 0 ~ <::::;) ~ c <::::;) < CI" va:'; :J: ~:o nlr'( :>>- 2:1': -< ~S" 0 ~,lB ~ :~~ ?(-- -0 -- -r ~c: :J: 0- )>c~ z~ ~ ~ U1 ~ -' ... U1 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PAUL A. ROUSH, vs. : No. 05 - 6701 Civil Term JANET E. ROUSH, ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the recDrd, together with the fDllDwing infDrmatiDn tD the Court for entry Df a divorce decree: I. GrDund fDr divDrce: irretrievable breakdown under &330I(c) of the DivDrce CDde. 2. Date and manner Dfthe service Df the Complaint: Via certified mail, return-receipt requested, Dn: January 21, 2006. 3. Date Df executiDn Dfthe affidavit Df consent required by 3301(c) Dfthe DivDrce CDde: By Plaintiff: May 12, 2006. By Defendant: May 9, 2006. 4. Related claims pending: NDne. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the ProthDnotary: May 10, 2006. Date Plaintiff's Waiver DfNDtice in ~330I(c) DivDrce was filed with the ProthonDtary: May 15,2006. Date:!J}5)0G Adams, Esquire I . No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 AttDmey fDr Plaintiff 2 ~ -ace -r' 1".:; -~, .:;,..,~ -I -:1'(, oj':",. '. 2:~~ -<:.. ~I:; (~ /:::::. l_-' 'PC -~ ~ ~ :$ ~ - Cl"' q, ~:rJ ..,,~ :-'0 (.~ " '::r:'.~~ .(~O /-(1'\ S ~ ::<:. --0 -:s r:? o ...1 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PAUL A. ROUSH, vs. ND. 05 - 6701 Civil Term JANET E. ROUSH, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT I, A complaint in divorce under section 3301(c) of the Divorce Code was filed on December 22, 2005. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa,C,S. 4904, relating to unsworn falsification to authorities. Date: ~ I'd, · b ,751 A-~ Paul A, Roush, Plaintiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 6330Hd) OF THE DIVORCE CODE }, I consent to 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: ~'I;)" . ~ /:::t Ar P Paul A. Roush, Plaintiff '2 -- ~ .-o..\~.jt\ 07.- ~~\:. ;;;>"",. \.L<. 'JE'\Cl. 7~ .-i! q. ~ :::?:n -::Jt. f6;;:; yo: -0'';--' ;....<. :.9::., ",.,.... C~S:(:. Ci' ".;...... ..,"i ;"'~') .- A~ '--n -"V ...~~\ ~ 9- I':? ~ ~ :t: :t::t:+. :t: :t: . . . . . . . . . . . . . . . . . . . . . . . . . :t::+;;t;;t: . . . . . :+; :+;~:t:~~:+;~:+;~~~~:t:+:+;:+;~~~ + IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Paul A, Roush, Plaintiff PENNA. STATE OF ND. 05 - 6701 Civil Term . . . No. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VERSUS Janet E. Roush, Defendant DECREE IN DIVORCE fit 'Q }-S , ,ttIv., IT IS ORDERED AND AND NOW, Paul A. Roush DECREED THAT , PLAINTIFF, Janet E. Roush AND , 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, ATTEST~ . .a:~ r PROTHONOTARY . . . . Of + '" '+ '" Of. '+:to Of:+' :+;"':+'''''''' ++"'+'+'f. 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