HomeMy WebLinkAbout02-1907RONNIE L. ROTZ,
TAMIM. ROTZ,
Plaintiff, :
:
:
Defendant. :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COMPLAINT IN DIVORCE
/407
NOTICE TO DEFEND AND CLAIM RIGHTS
TO:
TAMI M. ROTZ
1576 Pin Oak Drive
Chambersburg, PA 17201
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 wthout 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 irrportant 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.
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 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
or (800) 990-9108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Date:
By:
And~ite~v ~.. Spears, E'~quire
Attorney I.D. No. 87737
3211 North Front Street, P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Document ti: 226501.1
RONNIE L. ROTZ,
TAMI M. ROTZ,
Plaintiff,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COMPLAINT IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff Ronnie L. Rotz is an adult individual residing at 31 Gutshall Road, Shippensburg,
Cumberland County, Pennsylvania, 17257.
2. Defendant Tami M. Rotz is an adult individual residing at 1576 Pinoak Drive, Chambersburg,
Franklin County, Pennsylvania, 17201.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 27, 1998 in Shippensburg, Cumberland County,
Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies
within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments.
Plaintiffs Social Security number is 211-66-5159, and Defendant's Social Security number is
unknown.
7.
8.
There have been no prior actions of divorce or for annulment between the parties.
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.
Document #: 226501.1
9. There were two children bom of this marriage, Brittany Michelle Rotz (d.o.b. 9/17/90) and
Desirae Nichole Rotz (d.o.b. 3/1/97).
10. The marriage is irretrievably broken.
11. The parties have been living separate and apart since August 8, 2000.
12. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and Defendant.
WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and any such other orders as
are appropriate and just.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Date:
By:
Andrew C. Spears, Esquire
Attorney I.D. No. 87737
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Document #: 226501.1
VERIFICATION
I, Ronnie L Rotz, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree 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.
rote: 7-/7-09..
Ronnie L. Rotz
RONNIE L. ROTZ,
Plaintiff
TAMI M. ROTZ,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
NO. 2002-1907 CIVIL TERM
IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
To Curtis R. Long, Prothonotary:
Please enter my appearance on behalf of the defendant, TAMI M. ROTZ, in the above
captioned case.
By:
Respectfully ~¢l~itted,
A. McK~ig'ht, ~II, Esquire
Mar~us
60 West Pomfret Sxtree~/
Carlisle, Pennsylva_hiff17013
(717) 249-2353
Attorney for defendant
Date: May 3, 2002
RONNIE L. ROTZ,
Pla'mtiff
TAMI M. ROTZ,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
NO. 2002-1907 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe for
Entry of Appearance was served upon the following by depositing a tree and correct copy of the
same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date
referenced below and addressed as follows:
Andrew C. Spears, Esquire
Metzger Wickersham
3211 North Front Street
P. O. Box 5300
Harrisburg, PA 17110-0300
By:
IRWIN, McKNIGHT & HUGHES
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: May 3, 2002
RONNIE L. ROTZ,
TAMI M. ROTZ,
Plaintiff,
Defendant.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 2002-1907
:
: DIVORCE ACTION
AFFIDAVIT OF SERVICE
I, Andrew C. Spears, Esquire, counsel for PlaintiffRounie L. Rotz, in the above-
captioned divorce action, hereby certify that a tree and correct copy of the Complaint in Divorce
was served upon Defendant on April 27, 2002. Attached hereto, marked as Exhibit A, and
incorporated herein by reference is the signed Return Receipt.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Date:
By:
Andrew C. Spears, Esquire
Attomey I.D. No. 87737
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Exhibit A
· Complete items 1, 2, and 3. Abm complete
item 4 if Restricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the
o~ on the front if space p~mits.
1. Article Addressed to:
psrForm~'l'l"~st 20~1 Domestic Ret~.~m
[3 ~eent
B. Received by (
D. Isde~eddmesdlffem~fromitem I? I-lyes
If YES, enter delivery address below: [] No
ail [] Expme, s Mall
[] Return Receipt for Memhandtee
I r'l C.O.D.
4b.'~es~cte~Nery? (Extra Fee) [] Yea
102595-01 -M-2509