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Home My WebLink About06-2627 6. STEPHANIE J. ROBERTS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE OCr ~;J-7 NO. CIVIL TERM CHRISTOPHER ROBERTS, 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 or divorce or annulment may be entered against you by the court. A judgment may also be entered against you for other claims 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 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. STEPHANIE J. ROBERTS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW IN DIVORCE ~l. OltJ..-7 NO. CIVIL TERM CHRISTOPHER ROBERTS, Defendant The plaintiff, Stephanie J. Roberts, by her attorneys, the Family Law Clinic, sets forth the following cause of action for divorce: COMPLAINT UNDER 23 Pa.C.S. ~~ 3301 (c) and (d) OF THE DIVORCE CODE I. Plaintiff is Stephanie J. Roberts, who is currently resides at 9 West Factory Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since December 1,2005. 2. Defendant is Christopher Roberts, who currently resides at 801 Queen Street, Steelton, Dauphin County, Pennsylvania, 17113, since March 2005. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November I, 2001 in, New Cumberland, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since March 17,2005. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Respectfully Submitted, Date r% ~ 2ffJ0b J:LJ1.1'1~ Kathleen N. McKeown . Certified Legal Intern /'...." -cD UCY J TON-WALSH ROBE RAINS ANNE MACDONALD-FOX THOMAS M. PLACE WILLIAM G. MARTIN Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2368 VERIFICATION I verify that the statements made in the foregoing Complaint for Divorce are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. ~904, relating to unsworn falsification to authorities. Date: ~ ~j ,...,,\ ~ ., ? ~~ -{"TCI": d:rz' ~-;1'. "\, "'.~, .. 2~l. ({),\ "" ;;: ~~~ 7- ....-:1 -< ~ ~ ::Jt ~ 1 CO ~ =' ('\~~ ~% :r! J;\ 0'- ;?A ::o.t ~ ." :::s: CJJ ., (./'l ...J STEPHANIE 1. ROBERTS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE OG~XJ.-7 NO. CIVIL TERM v. CHRISTOPHER ROBERTS, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Stephanie Roberts, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date r1J ~ Q.~(, ) ~c~!~ Certified Legal Intern ~~ HO . PLACE ROBE TRAINS ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 Fax: 717-243-3639 () Q. <;-4 ~ ..-0"(,6 \"1'\\:' .. "" ,( '2'.c t:3c> r:~c L. qC:'. ~(".,) ')7C ~ ~, :.<. ~ 'i:? ~ :...:. , 0:> q. ~~' :9.~ ':J:.~ ~ ~~ t? :::-I _rt ~ ~ - -- .....- STEPHANIE ROBERTS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE CHRISTOPHER ROBERTS, Defendant NO. 06 - 2627 CIVIL TERM CERTIFICATE OF SERVICE I, Gillian Woodward, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Mr. Christopher Roberts, residing at 801 Queen Street, Steelton, P A 17113, by depositing a copy ofthe same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Christopher Roberts, on the 25th day of May, 2006 as evidenced by the attached green card. 0Jk~W Gillian Woodward C itied Legal Intern ~ ucy J on-Walsh, Esq. Superv ing Attorney FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 "41t . Ptlnt)lOlil' 80 __ . AtIMtltNt or on thlldlf 1. Article to: Ch rV/:CS-lt>phe r /( ober16 -gD! GUe.en ~ul- Shtllon, P4 /7//$ . !MIll 0....... M8II O'~."lUIlild OFllilumAlloelpt for ~ C~.. CC.O.D. 4. Re8b1cted DIlIvery? I&fnt Fee) Yes 7005 0390 0003 2632 6468 'Saf1'M}~1 ,...,.",~.. PSForm' ,'.. ... . .. ........ 1025ll5-99-M.1789 f'o..:) \::::.:> = 0'" :zr: ~.111 -< W Cl o -11 ~~ rll ...w r- -om ~~~ ..~:' i1 , )-- -'70 om --I ~ -< -r:) ::;, N .. U1 of Stephanie Roberts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE Christopher Roberts, Defendant : NO. 06 - 2627 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S9 3301(c) of the Divorce Code was filed on May 8, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. s4904, relating to unswom falsitication to authorities. Dale~ f-.:l c::=> ~ (j) 11'1 -0 f'V --l y' -- "";;JIto. ~ ~""'j 01 r: -'00; ~7~ ~?, (~}~ djj :~ - - s:- (...) Stephanie Roberts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Christopher Roberts, Defendant : NO. 06 - 2627 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CO~~ 1. I consent to the entry of a ftnal 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 ftled 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 falsiftcation to authorities. ~. . f Date /.p W .__._ ~1. ~- yJ~ jL~ _ _ .m 0 '--uYJtjI V,) StephanIe R berts, Pain ff o ~ -rJ i:f; rr~ r r' ~~._~ ."~;,,. (/':'. ;. ~~. \.~:" .~, ~ c.? <7' (/) ~ ~ -~~ It:} "'t..., (' ,~. ",""" -..,- -7- :;;.\ .....( ~ :i!..... f11 r: am :hq <~~ ~~fj 'o~~ f, "ce- \ ('\ .:3 .~ ::<, -e :.>>- - - .~ v:> Stephanie Roberts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Christopher Roberts, Defendant : NO. 06 - 2627 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce undeI 99 3301(c) of the Divorce Code was filed on May 8, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of fIling and service of the Complaint. 3. I consent to the entry of a fmal 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. 94904, relating to unsworn falsitication to authorities. Date :!I.) Au:) 2txJb o f'~ "f":.",. ;'-:i -<. ,....;) = c;;:.? CT' <./? r:1 v N -J o " -4 :J:""t1 rr1~ FTi -0) c:; :;: L qu ~~~1 .,- rn o --4 .~~ ~ ~ Z .x::- ..;:;- Stephanie Roberts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Christopher Roberts, Defendant : NO. 06 - 2627 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE 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 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 30 Ikj 2 OtJ " ~ c;:J cJ'" if> rn -.:; N -l V' :;J: o -n :1..,., rnc -.-;f'D -6 t:J '21 ~!l ,_.1\ ~2 (') ;'~rn ...,,/, ~ ~ - - .- ~. .';- Stephanie Roberts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY Christopher Roberts, Defendant : No. 06 - 2627 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 93301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Christopher Roberts, 5/25/06. 3. Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by Plaintiff- September 6, 2006; by Defendant- August 30, 2006 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: September 27,2006 Date Defendant's Waiver of Notice was filed with the Prothonotary: September 27, Date Krista Ann Freego Certified Legal lnte /0 /Ff/ O~ I ~~~ ~4<<~j/~ ROB . T E. RAINS ' THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, P A 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff (-) (.:: r-) C..:l c..;.::.:; ,,;:;-.. o ("" -,{ ~ f'J C.') ,.;'f. ili ili ili ili ili ili ili 'Ii 'Ii ili 'Ii 'Ii ili 'Ii 'Ii ili ili ili 'Ii 'Ii 'Ii 'Ii 'f. 'Ii 'Ii ili ili ili ili ili ili ili iliili ili ili ili ili ili ili iliiliili iliili 'liiliiliiliili 'liili iliiliiliiliiliili iliiliili ili iliiliiliili IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. STEPHANIE ROBERTS, No. 2627 2006 Plajntiff VERSUS C-HRISTOPHRR RORRRTS, Df>ff>ndant DECREE IN DIVORCE AND NOW, {)ch b<<. 2- ~~ , zooc:" ., IT IS ORDERED AN D DECREED THAT STEPHANIE ROBERTS , PLAINTIFF, AND C-HRTSTOPHRR RORRRTS , DEFEN DANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; Nn1\1p. By THE cou;j 'Ii if. if. if. if. if. if. if. if. if. if. 'Ii if. if. if. if. if. if. if. if. if. ili'liiliif. if.iliif.";'f. "':'- '7 ~- Arrmt~ C PROTHONOTARY 'Ii'li iliiliiliili iliiliiliiliili iliiliiliiliiliiliiliili if.iliiliili iliiliiliiliili iliili iliili'li 'Ii'li'li'li'li'li 'Ii 'Ii 'Ii 'Ii 'Ii 'Ii 'Ii 'Ii 'Ii 'Ii 'liif.if.'f.'liif. iliif.iliifi if. if. if. if. if. if. ili if. if. if. J. . * .5 ~ ~ t.J(J. '?e'o/ '7 ;:I .~ ~ 4w ~ ~t?, ?-eo,/'/ ., ... ",'