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HomeMy WebLinkAbout06-3173 f " Cindy S. Conley, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, P A 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Heidi B. Roeder IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO TY, PENNSYLVANIA Plaintiff ) ) ) ) ) ) ) NO. 2006- CIVIL TERM HEIDI B. ROEDER, v. RUSSELL K. ROEDER, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND C AIM RIG TS You have been sued in court. If you wish to defend against th claims set forth in the following pages, you must take prompt action. You are warned that i you fail to do so, the case may proceed without you and a decree of divorce or annulment may e entered against you by the court. A judgment may also be entered against you for any other c1ai or relief requested in these papers by the Plaintiff. You may lose money or property or oth r rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable bre down of the marriage, you may request marriage counseling. A list of marriage counselors i available in the Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Squ e, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISI N OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR A ULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER T ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO 0 TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN ET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street, Carlisle, P A 1701 Telephone: (717) 249-3166 RI ANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is require by law to comply with the Americans with Disabilities Act of 1990. For information about a cessible facilities and reasonable accommodations available to disabled individuals having b siness before the court, please contact our office. All arrangements must be made at least 72 ours prior to any hearing or business before the court. You must attend the scheduled conferen e or hearing. " i I I , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND C~UNTY, PENNSYLVANIA I Plaintiff ) ) ) ) ) ) ) NO. 2006- CIVIL TERM HEIDI B. ROEDER, v. RUSSELL K. ROEDER, Defendant CIVIL ACTIO - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Heidi B. Roeder, by and throug her counsel, Howett, Kissinger, Conley & Holst, P.C., who states the following in support of the within Complaint: I. Plaintiff is Heidi B. Roeder, an adult individu I who currently resides at 464 Woodcrest Drive, Mechanicsburg, Cumberland County, Pennsy vania, 17050. 2. Defendant is Russell K. Roeder, an adult indi . dual who currently resides 3. Both the Plaintiff and the Defendant have bee bona fide residents in the at 4122 Nantucket Court, Mechanicsburg, Cumberland County, Pe ylvania, 17050. Commonwealth of Pennsylvania for a period of at least six (6) mon immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on Augu t 8, 1981 in Boston, Massachusetts. 5. Neither Plaintiff nor Defendant is in the mili or naval service of the United States or its allies within the provisions of the Servicemember Civil Relief Act. 6. There have been no prior actions for divorce or annulment of the marriage instituted by either of the parties in this or any other jurisdiction. , 7. Plaintiff has been advised that counseling is a ailable and that Plaintiff may have the right to request that the Court require the parties to p icipate in counseling. 8. The marriage of the parties is irretrievably bro en. 9. The parties have lived separate and apart sinc on or about June 2002. 10. Plaintiff requests the court to enter a decree 0 divorce. Respectfully submitted, Date: ro ----I -ofo Cindy S. Conie, squi e HOWETT, KISSINGER, ONLEY & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, P A 17108 Telephone: (717) 234-2 16 Counsel for Plaintiff He di B. Roeder . , , >> VERIFICATION I, Heidi B. Roeder, hereby swear and affirm that the facts cont 'ned in the foregoing Complaint in Divorce are true and correct to the best of my knowledg , information and belief and are made subject to the penalties of 18 Pa.C.S. ~4904 relating to sworn falsification to authorities. Date: Cr/I~() fc, mu8 Heidi B. Roeder 1-~ G w ~ - ...:t ~ ~ C> -.t: ;q.. - -a C B ~ :e +- -....t:.. -'.""', L'" ~i::\ ~ q, ~. ~ ~~ ~~; 4.'"'lm "",,,.... ....1:'10 \ .~ ')l C:~ ('oJ ;?~'::';-\ -c ;,,"26 :::::: ~-rn '2, ;;;- ::.. ~ ::" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEIDI B. ROEDER, Plaintiff ) ) ) ) ) ) ) NO. 2006-3173 CIVIL TERM v. RUSSELL K. ROEDER, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Ann V. Levin, Esquire, accept service of the Complaint in Divorce on behalf of Russell K. Roeder, Defendant in the above-captioned action, and certifY that I am authorized to do so. Ll/6 Aiill V. Levin, Esquire SMIGEL ANDERSON & SACKS River Chase Office Center 4431 North Front Street Harrisburg, P A 1711 0 Telephone: (717) 234-2401 Counsel for Defendant Russell K. Roeder Date: (P , 7 - oCo '" 6 CJ"~ o .," ..... :r:..,., rnE :r!l~:t , , L. C. 0:-.) -0 -:,-> .,5(.''') <~n;l ~~ '-< '::) CD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEIDI B. ROEDER, Plaintiff ) ) ) ) ) ) ) NO. 2006-3173 CIVIL TERM v. RUSSELL K. ROEDER, Defendant CIVIL ACTION - LA W IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under 93301(c) of the Divorce Code was filed on June 2, 2006. 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 in divorce after service of notice of intention to request entry of the decree. 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! 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 above 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: CJ 1'7/2000 cf1' .~~ ~. Heidi B. Roeder, Plaintiff ~ ~ ~ ~h.1 'Z.-f"\ %c <:n .;:;. ~....~. l- \cC -' :r:;..Q ~o yC~ ~ ~ ~~ --orrn~ - :Qo u:> .:.::.\""', -;:r:-n ~ %fA t"f! :.A v:> ~ C" ~ ~ ~ :..0 .' ~ .-4,. . . . Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HEIDI B. ROEDER, v. DOCKET No. 2006-3173 RUSSELL K. ROEDER, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under *3301(c) of the Divorce Code was filed on June 2, 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 ofa 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. 94904 relating to unsworn falsification to authorities. Date: fJ;~6 o C -:-;; ~~ ......;^.~.. vc~. n1ri. ~,!:;~' ~ !< ~~ z ~ r--:l = = cT' (.I) rT1 -0 N c.n ~ -4 :I:,-n ne -om ~-J c::; ::S6 :::;;;\-'1 5::D z~ ~ ~ -0 3 't: C) Q) I A VUsmmllSeptember 6, 2006 1:59 PM .. .. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HEIDI B. ROEDER, V. DOCKET No. 2006-3173 RUSSELL K. ROEDER, Defendant CIVIL ACTION - DIVORCE 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. 94904 relating to unsworn falsification to authorities. Da,e: ~~6 -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HEIDI B. ROEDER, Plaintiff ) ) ) ) ) ) ) NO. 2006-3173 CIVIL TERM v. RUSSELL K. ROEDER, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the fOllOwing infonnation, to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under *3301(e) of the Divorce Code. 2. Date and manner of service of the complaint: Service accepted by Ann V. Levin, Esquire on June 7, 2006; Acceptance of Service filed on June 13, 2006. 3. Date of execution of the affidavit of consent required by *3301(e) of the Divorce Code: by plaintiff, September 7, 2006; by defendant, September 14,2006. 4. Related claims pending: No related claims pending. 5. Date plainti fi's Waiver of Notice in *330 I (c) Divorce was filed with the prothonotary: September 19, 2006; date defendant's Waiver of Notice in *330 I (c) Divorce Was filed with the prothonotary: September 25, 2006. Date: ~ ~~..1:as Cindy S. Conle squi HOWETT, SINGER, CONLEY 130 Walnut Street, P. O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Heidi B. Roeder Q s~; ~:;, -Of' t)) ~ ^~ ~ C'~ \;':~\- .>,- . ~--./. ":- :S' \.._. :~;'. c..:~ ~. r-:J = c:'J ct.... '--';. .-~ if) \-.-, -0 f'.) \..P (') .en -I :T..., rn r.~~ -nC., ::!"?~) .:.~';..:: -'..: '..;i::_ ~:.>~ ~'\ ....,. "'.0 ::.<: - - o .j:""" .",. q ~; "'- ~!tJ~" rnn, '--7 "J 2i~, (f). ".' 2t' ~ :2:.( , ~.O ')..:"'c :2. 2 r--:> g Cl"' (/) Cd rV c.J1 -0 :;: o 41 ::;1 ..>_-r1 rn--' t;; -Co ~~~~, ~;~, S~ ,-) . :::--\ :lp :;.( tf! o cJj ~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. HEIDI B. ROEDER, Plaintiff No. 2006-3173 CIVIL TERM VERSUS RUSSELL K. ROEDER, Defendant DECREE IN DIVORCE AND NOW, ~~~ .A /tJ:1.( J. At/If. 2006 IT IS ORDERED AND , DECREED THAT HEIDI B. ROEDER , PLAI NTI FF, RUSSELL K. ROEDER AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY. 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. y ,. ,. PROTHONOTARY ATTEST: J. ~~~~~~~ ~ ~~ ~~~~~~ ~~~~~~~ ~~~~~~~~~~~~ ~ ~E ~~~ '7d-JI-c1/ ~ p~~j~rl-/'P w- 1/0/ . "...... -4 ":.. t.... .