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Home My WebLink About02-1596ROBERT J. HERRMANN, Plaintiff Vo REBECCA T. HERRMANN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Oa- CIVIL ACTIO - t AW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Rebecca T. Hemnann 88 Rhein Stmusse 55413 Niederheimbach, Germany 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. 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, One Courthouse Square, Carlisle, Pennsylvania 17013-3387. 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. IFYOU 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, PA 17013 (717)249-3166 800-990-9108 Document #: 229755.1 ROBERT J. HERRMANN, : Plaintiff : V. : REBECCA T. HERRMANN, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER 3301(c) OR 3301(d) OF TI-IE~ DIVORCE CODE 1. Plaintiff is Robert J. He, ill,ann, who currently resides at 709 Hanover Manor, Apt. E203, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Rebecca T. Henmann, who currently resides at 88 Rhein Strausse, 55413 Niederheimbach, Gexmany. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 11, 2000, in Warwick, Orange County, New York. The parties separated on September 12, 2001. 5. There have been no prior actions of Divome or for annulment between the parties. 6. One child was bom out of wedlock, Raquel I. Rantanen, D.O.B. 10/18/98. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Plaintiffrequests the court to enter a decree of divorce. Document #: 229755.1 WHEREFORE, Plaintiff, requests the Court to enter a Decree in Divorce and such other orders as may be just and appropriate. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Melissa L. Van Eck, Esquire Attorney I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Dated: Attorney for Plaintiff Document #: 229755.1 VERIFICATION I, Robert J. He~mann, hereby certify that the facts set forth in the foregoing Complaint Under Section 3301(c) or 3301(d) of the Divorce Code are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. {}4904 relating to unswom falsification to authorities. Date : ~O/Y/tt~' O& Document #: 229755.1 ROBERT J. HERRMANN, : : Plaintiff : .. V. .. REBECCA T. HERRMANN, : _, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-1596 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed on April 2, 2002, and served upon Defendant on April 12, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaim. 3. I consent to the entry ora 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: ~1~'1(3~.~t~~t '~ Document #: 239207.1 ROBERT J. HERRMANN, Plaintiff V. REBECCA T. ItERRMANN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 02-1596 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 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 conceming alimony, division of property, lawyer's fees or expenses ifI 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date:~__ Document #: 239207.1 DIVORCE INFORMATION SHEET PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1, 2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: DATE OF MARRIAGE: Sentemher 11. ROBERT J. HERRMANN, : Plaintiff : V. _, REBECCA T. HERRMANN, : _. Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-1596 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed on April 2, 2002, and served upon Defendant on April 12, 2002. 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 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. RI~BECCA T. HERRMAN Document t4: 239207.1 ROBERT J. HERRMANN, Plaintiff V. REBECCA T. ItERRMANN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-1596 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 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 conceming alimony, division of property, lawyer's fees or expenses ifI 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Document #: 239205.1 ROBERT J. HERRMANN, Plaintiff REBECCA T. HERRMANN, Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - DIVORCE : : NO. 02-1596 CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under §3301 (c) of the Divorce Code. Date and manner of service of Complaint: A Complaint in Divorce was filed on April 2, 2002, and the Defendant accepted service on April 12, 2002. An Affidavit of Service was filed May 6, 2002. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301 (c) of the Divorce Code: Plaintiff- August 5, 2002, and filed August 6, 2002. Defendant - August 29, 2002, and filed September 3, 2002. (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of service of the Plaintiffs affidavit upon the defendant: N/A Document/4: 226820.1 o Complete the appropriate paragraphs: (a) Related claims pending: None (b) (c) Claims withdrawn: None Claims settled by agreement of the parties: N/A (d) State whether any written agreement is to be incorporated into the Divorce Decree. No. (a) Date and manner of service of the Notice of Intention to File Praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 (d)(1)(i) of the Divorce Code: N/A (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: August 6, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 3, 2002. Date: September. { { , 2002 METZGER, WICKERSHAM, KNAUSS & ERB Melissa L. Van Eck, Esquire Attorney Id. 85869 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Robert J. Herrmann Document#:241998.1 ROBERT & HERRMANN, Plaintiff REBECCA T. HERRMANN, Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA _. : CIVIL ACTION - DIVORCE : : NO. 02-1596 CIVIL TERM CERTIFICATE OF SERVICE AND NOW, this / ~day of September, 2002, I, Melissa L. Van Eck, Esquire, of Metzger, Wickersham, Knauss & Erb, attorneys for Plaintiff, Monique y. Doleman-Campbell, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Rebecca T. Hemnann 88 Rhein Strausse 55413 Niederheimbach, Germany Defendant METZGER, WICKERSHAM, KNAUSS & ERB Melissa L. Van Eck, Esquire Attorney Id. 85869 3211 North From Street PO Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Robert J. Herrmann) Date: September_[ ( ,2002 Document #: 241998.1 ROBERT J. HERRMANN INTHE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF ~~ PENNA. VERSUS REBECCA T. HERRMANN NO. 02 - 1596 DECREE IN DIVORCE AND NOW,~ --~ DECREED THAT AND Rebecca T. Herrmann ARE DIVORCED FROM THE BONDS OF MATRIMONY. .. , IT IS OrDErED AND , PLAINTIFF, , DEFENDANT, 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; BY T~g~i~u rt~ ~ ~PROTHONOTArY