The URL can be used to link to this page

Home My WebLink About02-1182 ROSE E. BADSTUEBNER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO.: 2002 ~It p~ ~~ l KENNETH A. BADSTUEBNER, CIVIL ACTION - LAW IN DIVORCE Defendant 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 ROSE E. BADSTUEBNER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 2002 -IIP~ Co'lll~ CIVIL ACTION - LAW IN DIVORCE NO.: KENNETH A. BADSTUEBNER, Defendant COMPLAINT AND NOW, comes Plaintiff, Rose E. Badstuebner, by her attorney, Richard C. Rupp, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, Rose E. Badstuebner, is an adult individual residing at 1489 Lincoln Highway, Schellsburg, Bedford County, Pennsylvania 15559. 2. Defendant, Kenneth A. Badstuebner, is an adult individual residing at 225 S. Coover Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 10, 1995, in Manns Choice, Bedford County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the Parties. 6. Plaintiff and Defendant are both citizens of the United States of America. 7. Neither Plaintiff nor Defendant are a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff avers that there is one child, Erin, of the Parties under the age of 18. 10. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the Parties participate in counseling. 11. Plaintiff and Defendant separated on October 24,2000. 12. Plaintiff asks the Court to enter a Decree in Divorce, WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. Respectfully submitted, Ric ard C. Rupp Sup. Court I.D. No,: 34832 355 North 21st Street, Suite 205 Camp Hill, PA 17011 (717) 761-3459 Attorney for Plaintiff 2 VERIFICATION I, ROSE 1; BADSTUEBNER, verify that the statements in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. R~ t:.. ~~cu;Q <:.--k.u ~v-fI. \I ROSE.A: BADSTUEBNER e. Date: c:L '-\ o.;t. i-~~ ~ "'J 6t ~ ....... Vv o\)~ ~~-V'O " ~ V ~1'i (") c.:: z '"Om n'lP' Z:J..i zr" r.IJ:;ro: --. ,..::. c:::c:' ~o --0 :P-c -? :z o N :z. 'J:"> -;;0 I Q) Cl .n -0 ::r,; ~ ,~....., \0 -n ",t;~ ),\ ' '~.;l... .-~ -'1- "'i,' "T1 ~ L ~ -..- .J...) _;,0 om -=-l ~ ACCEPTANCE OF SERVICE ::Y'. I, KENNETH A. BADSTUEBNER, the Defendant in the above referenced Divorce Action, do hereby accept service of the Complaint in Divorce filed by my wife. jJiw~ ~ ~ /J-: KENNETH A. BADSTUEBNER, Defendant 0t'; DATE: %/0.#) d-.-%' ...2~ , (') <:::: J=: 115 <If.}'! ~-~, <:.r"'- C") '\~ ;:$' :; , ~c-.:" ;EC"'I "~:C5 <:::: <:: ::J , ~ .'l'.lo 't;l =:0 '" <.r; o <'1 :s? -<.: .'-1 T , ,j::!] r-- "'701 ';0 .~) L --~ ( ) i3fi$ ,,:-_(.) Gff, ?J -..;: :::-- '. :::> - "I/~"~ ,,- '. ~ LAW OFFICES RUPP AND MEIKLE A PROFESSIONAL CORPORATION 365 NORTH 21ST STREET, SUITE 205 CAMP HILL, PA 17011 ROSE E. BADSTUEBNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 02-1182 CIVIL TERM KENNETH A. BADSTUEBNER, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 8,2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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: ~ J.JS"Jo ~ ~ ~ ~o....c.~., 1\ 'V.......,-- ROSE E. BADSTUBNER, Plaintiff --~~~~~..:..- cy;("-~ - -- (") C -..-'" -ofB me:: z~, :Z:C (J)~:.. "< " ;;:c ;E"; C~: Z," 5>'-' c z ~ o 1',) c- c: .- o -1'1 --< i_-n ;i:'j -en' -;;9 --:',,0 ,- 'I ?~~ ~:~:.rn ,~ -I ,> ::0 -< o -0 -,;;-,. ~ ~-'li"T ~ LAW OFFICES RUPP AND MEIKLE A PROFESSIONAL CORPORATION 355 NORTH 21ST STREET, SUITE 205 CAMP HILL, PA 17011 .;.,....._-----'<11 ROSE E. BADSTUEBNER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO.: 02-1182 CIVIL TERM KENNETH A. BADSTUEBNER, CIVIL ACTION - LAW IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330' (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 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 if it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. 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: ~ ).;lS b 2..- _~ ~ 6~..,.~ ROSE A. BADSTUEBNER, Plaintiff ~,... ~ -.-----..,.~:~~.-..___::_--.".,......._..-,___..".."--,,..,..'_::_____O-_T.._.._____..._..._.'""""".=.~-.~:....---- <c...dI" s-,.J o ~ -ufo o:!rrl z:::, :z: r;: Cj)d7 Cc: '- ~j;."r' 1f (~:~ Pc: ~.~;I' ~ o N c..... c:: r- c::> -0 :;l: o ~-11 .-1 1~:n 'or- .-:',jrn. )0 'J L :c-::j9 " _'--n ';0 orn -, ..,.. :5J -< ,~ ~r:- LAW OFFICES RUPP AND MEIKLE A PROFESSIONAL CORPORATION 366 NORTH 21ST STREET, SUITE 205 CAMP HILL, PA 17011 R.OSE E. BAI)STU~BN~R, IN TH~ eOURT OF eOMMON PLI;AS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO.: 02-1182 CIVIL TERM KENNETH A. BADSTUEBNER, CIVIL ACTION - LAW IN DIVORCE Defendant COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling, 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, 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 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: 2. J.,..~ L t&~~ ll~ ROSE E. BADSTUEBNER, Plaintiff ..._~ ~ ~ ~ ~ n c <';.0" -om 92L:; :zt' ~~. r:: \....... ~- pr--\ zC) :Pc: :z ~ o t'~ '- c::: r- o --n o ,-; -~:, ::J '"\-- _,...,pl ':!\6 -r, ;1.5 i,)IT' ::::.. 'h 5::! "< -0 ~ j;"" .::- ROSE E. BADSTUEBNER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO.: 02-1182 CIVIL TERM KENNETH A. BADSTUEBNER, CIVIL ACTION - LAW IN DIVORCE Defendant . . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 8, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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' J"j. ::J. ~6..) ~~~i/!, ~ Q- KENNETH A. BADSTUEBNER, Defenaant ~, '- "- ~~~~ ::j -, c c :::) ::"') ....{ r'-.J ,":J !'., en 55 -< ROSE E. BADSTUEBNER, PlaintiH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 02-1182 CIVIL TERM KENNETH A. BADSTUEBNER, 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 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 if 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 Po. C.S. Section 4904 relating to unsworn falsification to authorities. Date: J~'.::l / ' ..l.:x:::.c=J ~4~#J. ~ Jl KENNETH A. BADSTUEBNER, Defendant ... (") Cl ;:) c: i''': .. ~ ::> L! G' ("') ,-n \" ,-I ,-- 7. r'",) i" L~ , '-' (j) ,~ , ;:::; c) '.--. _.~. "] , - ") --I~ :~ C) c N ':5 , n p. c;; ~,-\ -.,.. .t:':.- ~, :<: (J'\ =< ROSE E. BADSTUEBNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 02-1182 CIVIL TERM KENNETH A. BADSTUEBNER, Defendant CIVIL ACTION - LAW IN DIVORCE COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, 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 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: J (\ ~;. )no...:J %~#. &~ {) KENNETH A. BADSTttEBNER, Defendant tI () 0 ~~ C r~ ;....:- ,::::> "'0 I.):. n ;g ITl I' -I -,... ~-J ....~. r'..) ?; \.:i ~- 1..0 ~' ~~ -, "' ......' ,"", C " (~ '? ,~ (=) N 1',1 s;.~ -) c: ...... -/ ~:; -::=t " m =< -, ROSE E. BADSTUEBNER, PlaintiH IN THE lCOURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 02,.1182 CIVIL TERM KENNETH A. BADSTUEBNER, Defendant CIVIL AC:TION - LAW IN DIVO'RCE 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 undler (X) Section 3301 (c) ( ) Section 3301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: 03/28/02 Acceptance of Service 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff, 06/25/02 by defendant, 10/21 /02 (b)(l) Date of execution of plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (b)(2) Date of service of plaintiff's affidavit upon Ric ard C, Rupp, Es Ru p & Meikle, P.C. Attorney J.D. #34832 355 North :21 st Street, Suite 205 Camp Hill, PA 17011 (717) 7 61-~J459 Counsel for Plaintiff 4. Related claims pending: Date: December 19, 2002 -C1 [1.:] ..t:~>o Z en r:2: :.~":: --. ::::;'t .1 L.-C', j;c:: Z ~ '-::I , ~~1 ~"? :'V CJ ":~~l ::;; C) "i", )~~'~ ~ :b -< cn ~~ ~ ~ ~~~~ ~~ ~~ ~~~~ ~ ~~~ ~ ~~ ~~~~~~ ~ ~ ~ ~~ ~~~~~~ ~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROSE E. BADSTUEBNER, Plaintiff No. 2002-1182 VERSUS KENNETH A. BADSTUEBNER, Defendant AND NOW, DECREE IN DIVORCE n~ 2$ , 7c.o2-;rT;s ORDERED AND ~ ~ ~ ROSE E. BADSTUEBNER DECREED THAT , PLAI NTI FF, AND KENNETH A. BADSTUEBNER , 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 .A-P D -r H ~i PA /l1"".z:e ~ ' "'?/' J. ~ PROTHONOTARY ~ ~ ~~ ~ ~ ~ ~ ~~ ~~~~ ~ ~ ~ <: ~ 2- ~ ~ Y'OE'(' e/ ~-P~~ ~-~ ~V'-rc-'-el , . ,