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Home My WebLink About06-0822ABRAHAM LAW OFFICES 2157 Market Street, Camp Hill, PA 17011 17171763-1700 RALPH F. STROUSE, SR. Plaintiff V. MARY JANE STROUSE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. U(o - CIVIL ACTION - LAW DIVORCE NOTICE a jt-C? 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 in 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 Court Administrator, 4"' Floor, 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: Court Administrator 4`n Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 RALPH F. STROUSE, SR. Plaintiff V. MARY JANE STROUSE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O(o - Pua-?- l?lc?i?? l CIVIL ACTION - LAW DIVORCE COMPLAINT AND NOW, comes Plaintiff, Ralph F. Strouse, Sr., by and through his attorney, James W. Abraham, Esquire, Abraham Law Offices, Camp Hill, Pennsylvania, 17011, and files the following: COUNT I - DIVORCE (Pursuant to 23 Pa.C.S.A. Section 3301(c)) 1. Plaintiff, Ralph F. Strouse, Sr., is an adult individual who currently resides at 1740 York Road, Dover, Pennsylvania. 2. Defendant, Mary Jane Strouse, is an adult individual who currently resides at 1 B Richland Lane, Apt. 107, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 29, 1983 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are not members of the Armed Forces of the United States. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. DATE: 2/9/06 Respectfully submitted: c- James W. Abraham, Esq. Abraham Law Offices 2157 Market St. Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff, Ralph F. Strouse, Jr. VERIFICATION I, U4,4 -? STnO U? fi(. , the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements made therein are true and correct to the best of my knowledge, information and belief. I hereby further understand that any false statements made therein are subject to the penalties of Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. DATE: -? - -7 - D (c 'R w' o f T rn<?--Z9 , CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, upon the following person at the following address on the date stated herein: Mary Jane Strouse 1 B Richland Lane, Apt. 107 Camp Hill, PA 17011 DATE: 2/9/06 James W. Abraham, Esquire {4 (? ._ J ?, i? ?? i ? G ?' ' ?" ? ? ? ?., ? ? ,....? ?" =,. . ?? ,., , ?? ?. ? ? G=' - . RALPH F. STROUSE, SR. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06 - 822 CIVIL TERM MARY JANE STROUSE CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 9, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 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.A. Section 4904, relating to the unsworn falsification to authorities. DATE: /'7r.? d y, 4 yoi. 9 ca. M RALPH IF. STROUSE, SR. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SETION 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 it is filed with the Prothonotary. 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.A. Section 4904, relating to the unworn falsification to authorities. DATE: .2 2 oo RALPH V? STR__OUSE, SR. C7 N TI C-?_ ,--1 ` t.? '? T i ?.S' ....- 'C1 YC1 - --- rl ?' -?l --, tX3 Curtis R. Long Prothonotary Office of the Protbonotarp Cumberlantl uCountp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor t?)lD - 19 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 - (717) 240-6195 • Fax (717) 240-6573