HomeMy WebLinkAbout06-3837Roderic Medling, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Sharon A. Medling, No. 0(e - 3a7 CIVIL
Defendant IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you fail
to do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
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 the Cumberland County Court House, High and Hanover Streets, Carlisle.
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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE..
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
(800) 990-9108
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.
Roderic Medling, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Sharon A. Medling, No. 06 • 3739 CIVIL
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Roderic Medling, an adult individual, who resides at HC 64 Box 4675
Marble Hill, Missouri 63764.
2. Defendant is Sharon A. Medling, an adult individual, who resides at 43 Big Spring Terrace,
Newville, Cumberland County, Pennsylvania 17241.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six
months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on May 10, 1986 in Carlisle, Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in this or
any other jurisdiction.
6. The marriage is irretrievably broken.
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. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
Date: b Lob
Respectfully submitted,
ROMINGER & WHARE
Leslie A. Tom eh, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court I.D. # 200198
Attorney for Plaintiff
Roderic Medling, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Sharon A. Medling, No. CIVIL
Defendant IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn
falsification to authorities.
Date:
L-3c) ?O 6,
Roderic Medling, Plainriff
Roderic Medling, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION- LAW
Sharon A. Medling, No. CIVIL
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a
copy of the within Motion upon the following by depositing same in the United States mail, postage
prepaid, at Carlisle, Pennsylvania, addressed as follows:
Sharon A. Medling
43 Big Spring Terrace
Newville, Pa 17241
Dated: 6 LO to
Les e A. Tome j, Esquire
Attorney for Plaintiff
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Roderic Medling, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Sharon A. Medling, No. 06-3837 CIVIL
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
July 6, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing 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. § 4904, relating to
unworn falsification to authorities.
Date:
Roderic Medling/Plaintiff
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Roderic Medling, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Sharon A. Medling, No. 06-3837 CIVIL
Defendant IN 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. §4904, relating to unsworn
falsification to authorities.
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Date: 6'e,&?- M )L,(,
Roderic Medling, Plaintiff
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Roderic Medling, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Sharon A. Medling, No. 06-3837 CIVIL
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
July 6, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing 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. § 4904, relating to
unworn falsification to authorities.
Date: / y /v -o CP
Sharon A. Medling/Def6iii ant
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Roderic Medling, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. :
CIVIL ACTION - LAW
Sharon A. Medling, No. 06-3837 CIVIL
Defendant IN 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. §4904, relating to unsworn
falsification to authorities.
Date: /d 2??,
Sharon A. Medling, Defendant
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RODERIC MEDLING,
Plaintiff
V.
SHARON A. MEDLING,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-3837 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
MOTION FOR LEAVE TO WITHDRAW AFFIDAVIT
OF CONSENT PURSUANT TO Pa.R.C.P. 1920.42 (c)
1. The Plaintiff is Roderic Medling who is represented by Leslie A. Tomeo,
Esquire.
2. Undersigned counsel was retained by the Defendant, Sharon A. Medling
on or about October 27, 2006.
3. Prior to undersigned counsel's involvement in this case, Defendant,
Sharon Medling signed an Affidavit Of Consent and Waiver Of Notice Of Intention To
Request Entry Of A Divorce Decree and sent those documents to Leslie Tomeo,
Esquire who filed them on October 18, 2006.
4. Defendant, Sharon Medling would like the opportunity to raise economic
issues in this case.
5. Defendant, Sharon Medling signed the Affidavit of Consent and Waiver of
Notice without the benefit of counsel and hereby requests leave of court to withdraw
them pending resolution of the economic issues.
6. Leslie Tomeo, Esquire, does concur with the relief requested in this
Motion.
WHEREFORE, Defendant, Sharon A. Medling respectfully requests this
Honorable Court grant her leave to withdraw her Affidavit of Consent.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Michae A. Scherer, Esquire
I.D. 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas.dirldomestic/mediing/withdrawconsent.mot
VERIFICATION
I verify that the statements made in the foregoing Motion For Leave To Withdraw
Affidavit Of Consent Pursuant To Pa.R.C.P. 1920.42 (c) are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to
authorities.
"Ad
Mic ael A. Scherer, Esquire
DATED: 10-010'
CERTIFICATE OF SERVICE
I hereby certify that on November I , 2006, I, Jennifer S. Lindsay, secretary to
Michael A. Scherer, did serve a copy of the Motion For Leave To Withdraw Affidavit Of
Consent Pursuant To Pa.R.C.P. 1920.42(c), by first class U.S. mail, postage prepaid, to
the party listed below, as follows:
Leslie A. Tomeo, Esquire
Rominger & Whare
155 South Hanover Street
Carlisle, Pennsylvania 17013
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RODERIC MEDLING,
Plaintiff
V.
SHARON A. MEDLING,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-3837 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance in the above-captioned action on behalf of the Defendant,
Sharon A. Medling.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Mic ael A. Scherer, Esquire
Supreme Court ID # 61974
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Defendant
Date: October 30, 2006
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NOV 1 3 2006
RODERIC MEDLING, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006-3837 CIVIL TERM
SHARON A. MEDLING, CIVIL ACTION-LAW
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this day of ???c,?1 Q( , 2006, upon
consideration of the within Motion, the Defendant, Sharon A. Medling is granted leave
to withdraw the Affidavit Of Consent she signed on October 10, 2006 and which was
filed on October 18, 2006.
BY THE COURT,
Michael A. Scherer, Esquire
O'Brien, Baric & Scherer
19 West South Street
Carlisle, Pennsylvania 17013
Leslie A. Tomeo, Esquire
Rominger & Whare
155 South Hanover Street
Carlisle, Pennsylvania 17013
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RODERIC MEDLING,
Plaintiff
V.
SHARON A. MEDLING,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-3837 CIVIL TERM
CIVIL ACTION-LAW
PLAINTIFF'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed
on July 6, 2006.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of a final decree in divorce without notice.
4. 1 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.
5. 1 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.
6. 1 have been advised of the availability of marriage counseling and understand
that I may request that the court require counseling. I do not request that the court require
counseling.
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.
2008
Sharon A. Medling
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RODERIC MEDLING,
Plaintiff
V.
SHARON A. MEDLING,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-3837 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
MARITAL SETTLMENT AGREEMENT
THIS AGREEMENT is made this 3 day oc , 2008, BY and
BETWEEN Sharon A. Medling, of Carlisle, Cumberland County, Pennsylvania,
hereinafter referred to as "Wife",
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Roderic Medling, of the County of Bollinger, State of Missouri, hereinafter referred to as
"Husband".
RECITALS
R.1: The Parties hereto are Wife and Husband, having been joined in marriage
on May 10, 1986; and,
R.2: Differences have arisen between the parties, in consequence of which the
parties intend to separate in the near future; and,
R.3: The Parties have resolved that it is not possible to continue the marital
relationship between them for reasons known to them, in consequence of which they
are living separate and apart; and,
R.4: Husband filed a Complaint for Divorce in the Court of Common Pleas of
Cumberland County in the Commonwealth of Pennsylvania, to above-captioned docket
number; and,
R.5: It is the desire and intention of the parties, to amicably adjust, compromise
and settle all property rights, and all rights in, to or against the property or estate of the
other, including property heretofore or subsequently acquired by either party, and to
settle aN disputes existing between them. including any claims or rights that they may
have under the provisions of the Pennsylvania Divorce Code, as amended; and,
R.6: Wife and Husband declare that each has had a full and fair opportunity to
obtain independent legal advice of counsel of their selection; that Wife has been
independently represented by Michael A. Scherer, Esquire and that Husband has been
represented by Leslie Tomeo, Esquire.
NOW THEREFORE, with the aforementioned recitals being hereinafter
incorporated by reference and deemed an essential part hereof and in consideration of
the covenants and promises hereinafter to be mutually kept and performed by each
party, as well as for other good and valuable consideration, receipt of which is hereby
acknowledged, and the parties, intending to be legally bound, hereby agree as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to
live separate and apart from the other party at such place or places as he or she from
time to time may choose or deem fit, free from any control, restraint or interference from
the other. Neither party shall disparage or discredit the other in any way, nor in any way
injure his or her reputation; nor shall either of them act or permit anyone else to act in
any way which might tend to create any disaffection or disloyalty or disrespect between
the members of the family of either party.
(2) DIVORCE: The parties acknowledge that the marriage is irretrievably
broken and that they will secure a mutual consent no-fault divorce decree in the above-
captioned divorce action. Simultaneous with the execution of this Agreement, the
parties shall execute the Affidavits of Consent and Waiver of Notice Forms necessary to
finalize said divorce. Said Affidavits and Waivers shall be immediately filed with the
Prothonotary's Office.
If either party. fails or refuses to execute anti:=file the foregoing documents, said
failure or refusal shall be considered a material breach of this Agreement and shall
entitle the other party at his or her option to terminate this Agreement.
(3) REAL PROPERTY: The parties own a mobile home which is located in a
mobile home park with and address of 43 Big Spring Terrace, Newville, PA 17241.
Presently the lien against the mobile home exceeds the fair market value of the mobile
home. Husband shall, concurrently with the execution of this agreement sign a limited
power of attorney in favor of Wife, allowing her to transfer title of the mobile home into
Wife's name alone. Wife agrees to assume the loan for the mobile home in her name
alone.
(4) DEBT: Aside from the foregoing, the marital debt consisted of a credit card
issued to the parties through PNC Bank with a balance of approximately $8,000.00 at
the time of separation. Wife has paid one-half of the balance of the credit card, and
Husband agrees to be solely liable for the remaining balance on the PNC credit card.
There is no other debt for which the parties are jointly liable. Each party shall be solely
liable for the debt in his or her name.
(5) MOTOR VEHICLES: The parties shall each own as their separate
property the motor vehicles which they presently possess.
(6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree
that they have effected a satisfactory division of the furniture, household furnishings,
appliances, tools and other household personal property between them, and they
mutually agree that each party shall from and after the date hereof be the sole and
separate owner of all such property presently in his or her possession whether said
property was heretofore owned jointly or individually by the parties.
The parties are the owners of two cemetery tots in Westminister Cemetery in
Carlisle. The parties shall convey the cemetery lots to their daughter, Sabrina Medling,
upon Sabrina's eighteenth birthday. The parties cannot transfer the cemetery lots to
Sabrina now because she must be eighteen years old to take title to them.
(7) INTANGIBLE PERSONAL PROPERTY: Each party hereto hereby
relinquishes any right, title or interest he or she may have in or to any intangible
personal property currently titled in the name of or in the possession of the other party,
including, but not limited to, stocks, bonds, insurance, bank accounts, individual
retirement accounts, employment benefits, including retirement accounts, savings
plans, pension plans, stock plans, 401 K plans, and the like.
(8) WAIVER of ALIMONY: The Parties acknowledge that each has income
and assets satisfactory to meet his and her own reasonable needs. Each Party waives
any claim he or she may have, one against the other, for alimony, spousal support or
alimony pendente lite.
(9) COMPLETE DISCLOSURE: Each of the Parties hereto acknowledges
that he or she is aware of his or her right to seek discovery including, but not limited to,
written interrogatories, motions for production of documents, the taking of oral
depositions, the filing of inventories and all other means of discovery permitted under the
Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each Party
further acknowledges that he or she has had the opportunity to discuss with counsel, if
desired, the concept of marital property under Pennsylvania law and each is aware of his
or her right to have the real and/or personal property, estate and assets, earnings and
income of the other assessed or evaluated by the courts of this Commonwealth or any
other court of competent jurisdiction. The Parties do hereby acknowledge that there has
been fun and fair disclosure to the other of his or her respective income, assets and
liabilities, whether such are held jointly, in the name of one party alone or in the name of
one of the parties and another individual or individuals. Each party agrees that any right
to further disclosure, valuation, appraisal or enumeration or statement thereof in this
Agreement is hereby specifically waived, and other than provided herein, the parties do
not wish to make or append hereto any further enumeration or statement. The Parties
hereby acknowledge and agree that the division of assets as set forth in this Agreement
is fair, reasonable and equitable, and is satisfactory to them. Each of the Parties hereto
further covenants and agrees for himself and herself and his or her heirs, executors,
administrators or assigns, that he or she will never at any time hereafter sue the other
Party or his or her heirs, executors, administrators or assigns in any action of contention,
direct or indirect, and allege therein that there was a denial of any rights to full
disclosure, or that there was any fraud, duress, undue influence or that there was a
failure to have available to him or her full, proper and independent representation by
legal counsel.
(10) RELEASE of ALL CLAIMS: Except as otherwise provided herein,
each Party releases and discharges completely and forever the other from any and all
right, title, interest or claim of past, present or future support, division of property,
including income of gain from property hereafter accruing, right of dower or curtesy, the
right to act as administrator or executor of the estate of the other, the right to a
distributive share of the other's estate, any right of exemption in the estate of the other,
or any other property rights, benefits or privileges accruing to either party by virtue of
their marriage relationship, or otherwise, whether the same are conferred by statutory or
common law of the Commonwealth of Pennsylvania, or any other state, or of the
statutory or common law of the united States of Ar*erica. Except as provided herein,
the Parties specifically waive any and all rights that they may have to equitable
distribution of marital property and/or alimony and counsel fees, except those counsel
fees sought in the event of a breach of this Agreement, or any other marital rights as
provided in the Pennsylvania Divorce Code, Act 26 of 1980 or any amendment thereto.
Each party further releases the other from any and all claims or demands up to
the date of execution hereof and any other claims either party could raise which arise
from the marriage, contract or otherwise.
(11) INCORPORATION into DIVORCE DECREE: The Parties agree that this
Agreement shall continue in full force and effect after such time as a final Decree in
Divorce may be entered with respect to the parties. Upon entry of the Decree, the
provisions of this Agreement may be incorporated by reference or in substance, but they
shall not be deemed merged into such Decree. The Agreement shall survive any such
Decree in Divorce, shall be independent thereof, and the Parties intend that all
obligations contained in this Agreement shall retain their contractual nature in any
enforcement proceedings, whether enforcement is sought in an action on the contact
itself at law or in equity, or in any enforcement action filed in a Divorce action.
(12) BREACH: It is expressly stipulated that in the event that either party
breaches any provision of this Agreement, he or she shall be responsible for any and all
costs incurred to enforce the Agreement, including, but not limited to, court cost and
counsel fees of the other party. In the event of breach, the other party shall have the
right, at his or her election; to sue for damages for such breach or to seek such other
and additional remedies as may be available to him or her.
(? 3) ENTIRE UNDERS- ANDING: This Agreement eontAikes the entire
understanding between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature whatsoever, other than
those herein contained.
(14) AGREEMENT BINDING on PARTIES and HEIRS: It is understood and
agreed that not only the Parties hereto, but also their heirs, administrators, executors
and assigns, shall be bound by all the terms, conditions and clauses of this Agreement.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound
hereby, have hereunto set their hands and seals to this Agreement the day and year first
above written.
WITNESS:
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Roderic Medling
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Sharon A. Medling
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RODERIC MEDLING,
Plaintiff
V.
SHARON A. MEDLING,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-3837 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
AND NOW, this 10th day of July, 2006, I, Sharon A. Medling, Defendant above,
hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1930
(d) and acknowledge receipt of a true and attested copy of said Complaint.
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Sharon A. Medling
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RODERIC MEDLING,
Plaintiff
V.
SHARON A. MEDLING,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-3837 CIVIL TERM
CIVIL ACTION-LAW
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. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Defendant signed an Acceptance of
Service form on July 10, 2006.
3. (complete either paragraph (a) or (b).)
A. Date of execution of the affidavit of consent required by Section 3301(c) of
the Divorce Code: by Plaintiff on October 11, 2006; and Defendant on April 1, 2008.
B. (1) date of execution of the 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
4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce
Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
1&4 61.,
Michael cher, r, Esquire
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
RODERIC MEDLING,
Plaintiff
NO. 2006-3837 Civil
VERSUS
Defendant
DECREE IN
DIVORCE
AND NOW, IT IS ORDERED AND
DECREED THAT RODERIC MEDLING , PLAINTIFF,
AND SHARON A. MEDLING DEFENDANT,
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;
The parties Marital Settlement Agreement dated ARrdl 3. 2008 is
BY THE COURT:
ATTEST: J.
?.? PROTHONOTARY
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