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Home My WebLink About06-6261LOYETTA CATHERINE CRIDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVII. ACTION -LAW GARY LAMAR ROHRBAUGH, Defendant 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 maybe 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 grounds 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. 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. 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 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 726 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. C~ (o ~- f~ o~ (o ~ C d ~ ~ ( -te rµ. IN DIVORCE COMPLAINT IN DIVORCE UNDER, SECTION 3301~c) OR 3301(4) OF THE DIVORCE CODE COUNT I -IRRETRIEVABLE BREAI~OWN AND NOW, comes the above named Plaintiff, Loyetta Catherine Crider, by and through her attorneys, Weigle & Associates, P.C., and Jerry A. Weigle, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Loyetta Catherine Crider, is an adult individual presently residing at 5169 East Trindle Road #16, Mechanicsburg, Cumberland County, Pennsylvania 17050, since October 1, 2005. 2. Defendant, Gary Lamar Rohrbaugh, is an adult individual presently residing at 281 Valley Road, Jacobis, York County, Pennsylvania 17407, since August 26, 2006. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on July 29, 2006, in Glenville, York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since August 26, 2006. 9. The Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. Respectfully submitted, GLE & ASSOCIA S, ] ~, J A. Weigle, Esquire Attorney for Petitioner Attorney ID No. 01624 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-7397 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. ~ Dated: Loyett Catherine Crider, Plaintiff WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 1Z6 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 r-a ~t r`~ ~- . ~ Lx~ x~ ~ r~ C t '1~ Y ~ C1 ~ Q ~ _r~ ` t r t; 4 ^_ "'r] ",(~ ` ~,~ C. ~ t `3 _ t ~ ~. . ~ c~"Y_--~ ~' {` V (' ~. ~,.,., ~. W ~J ~" -.-5. ~~ ~G M ~_ s LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. pjf,-~aGvl IN DIVORCE AFFIDAVIT OF SERVICE I, the undersigned adult individual, having been duly sworn according to law, deposes and says that on November 7, 2006, a true and attested copy of Notice to Defend with Complaint in Divorce was served upon the Defendant, Gary L. Rohrbaugh. Manner of service: by mailing the same postage paid, certified mail, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Gary L. Rorhbaugh 2821 Valley Road Jacobus, PA 17407 The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto as Exhibit A. Dated:__~~~ Subscribed and sworn to before me the undersigned No Public on the ~ day of , 2006. ~-, Rhonda R. Wolford, Notary Public Shlppensburg Borc, Cumberland County My Commissir~n Expires Jan. 20, 2009 Br e L. Naug e WEIGLE & ASSOCIATES. P.C. -ATTORNEYS AT LAW - 1Z6 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 4 `I i ~ ^ Complete Rams 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address an the reverse so that we can return the card to you. ^ Attach this card'the back of the mailpiece, or on the front 'If space permits. 1. Article Addressed to: Gary L. Rohrbaugh 2821 Valley Road Jacobus, PA17407 a AS~M B. ReceivdA ~f ( n~f /Yams) ~ C. Date of Delivery K~i~rb1~~~, 1(")-06 D. Is delNery address dkrerent from kern 11 es ft YES, enter delivery address P.17 ~ a,~! 1~~l1cy `..~, _; ; ,~~, i ~+ ~y ~ ` 3 Certified Mail ^ f~Ma~fl ~ 'J ^ Registered Return R' erchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) Y~ 2. Article Number _ (r~ar,~-aon,,.n~o„t~g 7DD5 182D DDDS 6338 4583 PS Form 3811, FebnHry 2004 Dont•stic RNurn RsoNpt, to~a.aa-r.1ta~ Exhibit A W EIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 _ ~~~~ ~. ~~. ~ , LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW :NO. ao6G-G~~~ l :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on October 26, 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. § 4904 relating to unsworn falsification to authorities. Dated: ~ " " oye Catherine Crider Plaintiff WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW 126 EAST KING STREET - SHIPPENSB URG, PA 17257-1397 ~ ~_ ~ °°, ~~ ~~ ~ F ~~ `, t ,1~,,,1A//N// ~, LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW :NO. ~ _~a~l :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under §3301(c} of the Divorce Code was filed on October 26~', 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 in divorce without notice. 4. 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. 5. 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. 6. I 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. Dated: ~' oye a Catherine Crider Plaintiff WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 E-., ~ v~n ,~~ . ~ rn' f' _,,,_ `_ ~ , _< - --~ :~ '~ ~. : ~ r~`i ~:, ~; .. ~`~. .;: ::,~ ~, LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on October 26, 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. § 4904 relating to unsworn falsification to authorities. Dated: .~ ` ~ ~ nee >~ Gary L Rohrbaugh Defendant WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 7 7 2 57-13 9 7 ~? ~-~ ;-z --~: _~ ~--~ (:`;~ '" 7 ?c r-r, ~~~ ~ ~ <~ ~ ~~. LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW :IN DNORCE WAVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(cl OF THE DIVORCE CODE 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on October 26~, 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 in divorce without notice. 4. 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. 5. 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. 6. I 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. Dated: ~~ vZ ~ ~ O (9 'J ~~tt/~-acv ~T Gary L ar Rohrbaugh Defendant WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 1Z6 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~> ~ a .-a , ; r -- '~ - _ ~~`~ , F ---a y - c~ -~~ LOYETTA CATHERINE CRIDER, Plaintiff v. GARY LAMAR ROHRBAUGH, Defendant :IN THE COURT OF COMMON PLEA5 OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW :NO. 2006-6261 :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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: November 7, 2006, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff, Apri130, 2007; by Defendant, Apri124, 2007. 4. Related claims pending: None 5. Date of filing of the Plaintiff's Waiver of Notice required by § 3301(c) of the Divorce Code was filed with the prothonotary: Plaintiffs, May 11, 2007 Date of filing of the Defendant's Waiver of Notice required by § 3301(c) of the Divorce Code was filed with the prothonotary: Defendant's, May 11, 2007 WEIGLE & ASSOCIATES, P.C. ~,,, ~ J J A. igle, Esquire - Attorney fo Plaintiff Attorney ID # Ol 624 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - i26 EAST KING STREET - SHIPPENSBURG, PA 77257-1397 ~+ y ._.. -_ ._... T C.j3 ~":e ~~3 t ~i .~ ~- I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '~ PENNA. =;~~ LOYETTA CATHERINE CRIDER Plaintiff VERSUS N O. 2006 6261 GARY LAMAR ROHRBAIIGH DECREE IN DIVORCE AND NOW, ~l~ ~d~ , ~, IT IS ORDERED AND DECREED THAT LOYETTA CATHERINE CRIDER PLAINTIFF , AND GARY LAMAR ROHRBAIIGH 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; NONE