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HomeMy WebLinkAbout06-5467~, ~n i inn ~~ laintiff v, ~nalc~ ~h~rJ`~ Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 06- ~~ `7 CIVIL TERM IN DIVORCE 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 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, 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, 1 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 a Plamhff v. Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA No. 06- ~'~ ~IVIL TERM IN DIVORCE COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ~~11" ~ ,who currently resides at ~~ ~at~,~- ~~~-, C~n~p Ohl ~ ~ ~t~ ~~ ~~ Cumberland County, Pennsylvania. ~pr~, '~) 2. Defendant is . ~a~d ~.J 1~L1~ --~`f' ,who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. ~,r 4. Plaintiff and Defendant were married on ~ ~~ V ~ 1/~ ~~ ~ at ll~l~ L ~~~i(~1.~.5 ~1~1(Y1~' ~ ~Oh~ ~~Ir~, ~1, ISIS 91 ~ ~~~ 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date 1 muff, ro S I, `~~~-~I-- i~ ~~r~ ,verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: r / 1 ./1 Vintiff,(~'ro S~' O Assisted by: Hannah Herman-Snyder, Esquire Griffie & Associates 200 P1. Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5551 Plainliff v. &C~nU Yl ~~ ~efendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. NO. 06- ~ `f~ .7 CIVIL TERM DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jennifer L, Rehrer ,Plaintiff, to proceed in forma ap uperis. I, Hannah Herman-Snyder, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the P~Y• Hannah Herman-Snyder, Esqui~e Attorney for Plaintiff 200 N. Hanover Street Carlisle, PA 17013 (717) 243-5551 L= 6._ - ,+- JENNIFER REHRER, Plaintiff v. DONALD REHRER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 06-5467 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, on the day of ~~tc,l~,-- , 2006 comes Hannah Herman-Snyder, Esquire, and states that she mailed a certified and true copy of a Complaint in Divorce and Notice to Defend and Claim Rights to the Defendant, Donald Rehrer, III, at his address of 341 West Third Street, Williamsport, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on October 2, 2006. Hannah Herman-Snyder, Esqui Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to befor e this ~_ day of , 2006 NOTARY P>~LIC NOTARIAL SEAL ROBM 1. ~OSNORN, NOTARP PUBLIC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES APRiI 17 2001 Cs t:~ ;.~ cr __-! ~€ '- 3 rZl-= i e _ .. (-~ . ~ ~ } ~, `- ~. _ ~ ,_..... .~. y~fl ta.'Y . + ~ 4 '~-r ~.~ i ~~ ~~.. -~ wy e r- .~ o Iv - ~ ~ o '' ~ ..- -. m ~ ~ ,~. ~O R'1 , Postage $ ~ t'^ ; ~.-} ~ O p Cert'rfied Fee * `. _ ,~,(~~ ~`_ ~ ~ Return Receipt Fee (Endorsement Required) ~' rOBII^ -' ,l Here '; D ~ Restricted Relive Fee (Endorsement Required) ~',Q ti 1 ~ ~ ~ ~-~' t~ ~r7 ~ Total Postage $ Fees ,$ ~ , ~ ~~ A,'~Y ~ + p p r~ M To h /~.y~ ~j ..G.~~~[S.l _ ... ~!ls~i~~ ------ - ~iiset'a r N ------- - p J . o.;~~ J - -------------- 1~1/illi~ is-r~.~n,~--~- DA i~~ni ~- ^ Complete items 1, 2, and 3. Also complete item 4 'rf 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 mailpiece, ;,Qr on the front if space permits. 1 icle Addressed to: Dar~Gclo/ ~ehrer,.-~ 3~ / y/esf Th ~`rt7~ ~r~ ~1/i!/i~z/Y1S~Jor~ ~.~ ~7?D/ a ^ Agent C. Date of Delivery D. Is delive~ 1 ~ ^ Yes !f YES, d ery a s ow: ^ No 3. Service Type ~i Certified Mall D Express Mail ^ Registered `~ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ~Y~ 2. Article Number 7pp~ 257.0 000 3803 ~62CI (Transfer from senricre PS Form 3811, February 2004 Domestic Return Receipt to25sso2-M•isao ~'! NJ r~ C~ ^ . _ Ci ~ ~~ "" C ~ ;ll } _~.Y - tt7 4~ r, ~ --~, ~~ ~ r , ^=.~ ~ -C". - f :~ S"t ~~} 4 c7,- -.`-: 4 •-~. JENNIFER LYNN REHRER, Plaintiff v. DONALD REHRER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 06-5467 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was fried on September 19, 2006, and service was made on October 2, 2006 as indicated by restricted delivery, certified mail. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARF. MAnF. SUBJF,CT TO THE PENALTIES OF 18 Pa.C.S. ;4944 RELAT~jG TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ~ .,~ .. ~ _~ JE IFER L ER, Plaintiff ~, C") ~ C) ~ m -_ ~ ~ t ~ "~ ~ i _ ~ V . .....- , ' ~L _ _,. T ... ~ ;'i 1 ...{ JENNIFER LYNN REHRER, Plaintiff v. DONALD REHRER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 06-5467 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I 'J~v"DERSTAi~1D THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ~~ I I 1 1 ~ -~ - / ~ ~ i ' ff E IFER RER, Pla nti rv CF. ~ a~ - ~-~ -~.:! - -n -~, t~ ~..~ .... '" ~ 4... _ , ~ ~ -T~ . ~~ . . ~ ..;;. ~ .x=` ~ ~.~ JENNIFER LYNN REHRER, Plaintiff v. DONALD REHRER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 06-5467 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 19, 2006, and service was made on October 2, 2006 as indicated by restricted delivery, certified mail. 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 1N THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I LTIDFRSTAND THAT FAI,SF. STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. .-~ DATE: LI ' ~"O ~ ~ ~/I-J~ DONALD REHRER, III, Defendant ~. a ~ ~ ~ ~ -~. ~ ^s w.~ r>~ ~~ s ,...- - e-~ '. w ,` ~~ ~ . ~ ~ ~ r^- M,~ y~,:t ..~ JENNIFER LYNN REHRER, Plaintiff v. DONALD REHRER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 06-5467 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AI~'i~ C-ORRECT. I uvL'ERS T AND THAT FALSE STATE1vIEi~'TS IzEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ~ ' S _ ~ 7 ~~ D ALD REHRER, III, Defendant ~+ T ~, - ~ -,-x T ' ;-r+ ,-t-~ . - ~ ....+j~J ~ -- r } ,, ~,.. i - , r {n ^, ~ JENNIFER LYNN REHRER, Plaintiff v. DONALD REHRER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-5467 CIVIL TERM 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 §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by restricted delivery, certified mail on October 2, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: 04/5/07 by Defendant: 04/05/07 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: April 11, 2007 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: April 11, 2007 Hannah Herman-Snyder, E uire GRIFFIE & ASSOCIATES Attorney for Plaintiff ~~ ~ -._.s ,~ t ~- 1 4~- ~. ~ ~r '^} ~~ ~ l _ .~ t ~ ~~ yq, y i 'V """\. I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. ~ ~ ~. ,. -; ~> - . Plaintiff Jennifer Lvnn Rehrer VERSUS Donald Rehrer, III Defendant No. 06-5467 DECREE IN DIVORCE ~~~~~` ~~ ~f~O~? IT IS ORDERED AND AND NOW, DECREED THAT Jennifer Lynn Rehrer PLAINTIFF, AND Donald Rehrer, III ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; None. BY THE COURT: PROTHONOTARY p 4 T- L-~ E• ! S_ ~,~" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Jennifer Lynn Rehrer Plaintiff : File No. 06-5467 vs. . • . IN DIVORCE Donald Rehrer, III • • Defendant .• NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, (select one by marking"X"). prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated April 17, 2007 hereby elects to resume the prior surname of Jennifer Lynn Stackpole , and gives this written notice avowing his/ her intention pursuant to the provisions of 54 P.S. §704. Date: /( j q /Zv ( 3 A �.! L12 ' ..4' _I'A / SignatureA Sign; ure of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF 01A(11 her)a, )d On the i 0h day of �CC f- , ZO'3 , before me, the Prothonotary or a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that te—/ she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. A_• - J , 1/ i A.�i ( Pro' onot.ry or Notary Public vkiMONWEALTH OF PENNSYLVANIA I. Notarial Seal Dolly M.Hockenberry,Notary Public Carlisle Boro,Cumberland County My Commission Expires Sept.24,2014 Member.Pennsylvania Association of Notaries A"0 u I 9 F4 PENS Y LVA NI /3• /0(1 c‘i/5-6* 2