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HomeMy WebLinkAbout06-1644 CHRISTOPHER A. ROELKE, Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW TONIA M. ROELKE, Defendant NO. 01,;> - / /..e,YLf {JIUI tT 9L~ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR AUMONY , 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, P A 17013 Telephone: (717) 249-3166 L II ~ vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER A. ROELKE, Plaintiff CIVIL ACTION - LAW NO. uC- -Ii. '1'1 TONIA M. ROELKE, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County_ This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. AU necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. II '40 I I vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER A. ROELKE, Plaintiff CIVIL ACTION - LAW NO. c)!. /VI Y TONIA M. ROELKE, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, CHRISTOPHER A. ROELKE, by his attorney, Samuel 1. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is CHRISTOPHER A. ROELKE, an adult individual who currently resides at 102 Sycamore Drive in Mt. Holly Springs, Cumberland County, Permsylvania. 2. The Defendant is TONIA M. ROELKE, an adult individual who currently resides at 102 Sycamore Drive in Mt. Holly Springs, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 17 October 1998 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. II ... COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. '1 .~~Q~Jj~ _, .J Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II 1 verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Fa. C.S. 4904 (unsworn falsification to authorities). Date: 11...( \0 acc6 ~~ CHK PHtKA.ROELKE '12 w -6g.. C) -n IS --- ~ :~ ~ t- \) ~'..J .~ - , "':' ~ 1'0 ~ I\- C} :!:-. C> ( " ~ fI/ -_../ .. '-. y --- -I :-D \\v G\ .-< r-- :r~ -f.--. -z- II CHRISTOPHER A. ROELKE, ) IN THE COURT OF COMMON PLAINTIFF ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 06-1644 CIVIL TERM TONIA M. ROELKE, ) DEFENDANT ) IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint in this matter and acknowledge receipt of a copy of the Cornplaint this day. Date:\foa ~,dDOLo ~IC\ 1/1 TONIA M. ROELKE 102 Sycamore Drive Mt. Holly Springs, P A r......) r::-/~" -. -,;;x;---- . .::!.L.' ) -..-.-....... 17065 ~~) ''''-(I -. " ,>-; -- -u:- /------- II I CHRISTOPHER A. ROELKE, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 06-1644 CML TERM TONIA M. ROELKE, ) Defendant ) IN DIVORCE AFFlDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301( c) of the Divorce Code was filed on 22 March 2006 and served upon the Defendant on 28 March 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301rc) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. Section 4904 relating to unsworn falsification to authorities. ~ (p/ {lOOu UltedO ~mKA.ROELKE --=------ c") c '-,~ c::: ---! F::; r..,.:: ( c. ~ II CHRISTOPHER A. ROELKE, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA ) vs. ) CML ACTION - LAW ) ) NO. 06-1644 CML TERM TONIA M. ROELKE, ) Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 22 March 2006 and served upon the Defendant on 28 March 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330Hcl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 med 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. Section 4904 relating to unsworn falsification to authorities. -a:;~ U/ ,9./)t)b Da d: r'~ --0 c II 1 ,- CHRISTOPHER A. ROELKE, Plaintiff vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW NO. 2006-1644 CML TERM TONIA M. ROELKE. Defendant IN DIVORCE 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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filed bv Plaintiffs counsel indicatinlZ service on or about 28 March 2006. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Mfidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 6 Tulv 2006 By Defendant: 6 Tuly 2006 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs Mfidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b): (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 Section 3301 (c) Divorce was filed with the Prothonotary: Dated 6 Tulv 2006 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was fIled with the Prothonotary: Dated 6 Tulv 2006 and filed contemporaneously herewith. Date: 6 July 2006 BY~.~~ muel ~des Attorney for Plaintiff \. ~. ""_.\ , ::.:::1 N c< IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF CHRISTOPHER A.. ROELKE, Plaintiff . VERSUS TONIA M. ROELKE, Defendant . PENNA. No. 2006-1644 . DECREE IN DIVORCE j/{.'O)AA. 2006 , IT IS ORDERED AND AND NOW, :r~ t~ CHRISTOPHER A. ROELKE DECREED THAT , PLAINTIFF, TONIA M. ROELKE , DEFENDANT, AND 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: J. . R OTHONOTARY .LA ~ 1O.fe-L. .""Z, t :::= 4vrl ~. tr:.t. ~~ -7fV fJ _ .' , ... W .. " ,,'" '" ~. ' .' ., .' .