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Home My WebLink About06-7281NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WANDA D. ROSE, : NO. 06 - I CIVIL TERM Defendant : IN DIVORCE N TI E 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 roamed that if you fail to do so, the case may proceed without you and a decree in 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, Carlisle, Pennsylvania 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WANDA D. ROSE, : NO. 06 - U151 CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Robert C. Rose, 241 West Baltimore Street, Carlisle, Pennsylvania, Cumberland County, Pennsylvania 17013. 2. The defendant is Wanda D. Rose, 470 Crossroad School Road, West Pennsboro Township, Cumberland County, Pennsylvania 17015. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on May 4, 1992, in Newville, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said parry has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. Section 4904, relating to unworn falsification to authorities. 2006 2006 ROBERT C. ROS , Plaintiff NAIJ" C. WOLF, ESQUIRE S r e %urt ID #87380 'xoPtfi est H h Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff a? 00 3?- ? J v sea C..1 :i -ri NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WANDA D. ROSE, : NO. 06 - 7 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotarys Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. CS. Section 4904 relating to unworn falsification to authorities. 2006 Robert C. Rose, Plaintiff NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW WANDA D. ROSE, : NO. 06 - 7281 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint of Divorce in the above-referenced matter pursuant. Attached is a copy of the Complaint of Divorce to reinstate. Respectfiilly submitted, WOLF & WOLF March , 2008 NAT . WOLF, ESQUIRE Sum Court ID #87380 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff MC ry `-7 -va? SIC --1 21 NATHAN C. WOLF, ESQ. SUPREME COURT ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 717-2414436 ATTORNEY FOR PLAINTIFF ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WANDA D. ROSE, : NO. 2006 - 7281 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA RCP RULE NO 1920.4 (a)(11(i) NOW, Nathan C. Wolf, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about December 30, 2006, by certified mail addressed to the defendant at 470 Crossroad School Road, Carlisle, Pennsylvania 17015, and was accepted as indicated by the attached copy of the return receipt. 3. That a copy of the complaint was also mailed regular mail on or about December 29, 2006 and has not been returned within 15 days pursuant to Pa. R.C.P. Rule No. 1930.4 (c)(1). I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. claa r J1 L, 2008 WOLF Plaintiff A. Sig X 13 Agent ? Addressee B.,gCQive{i by (Flint d ? ( ( 5W'-C C. Date of Delivery D. Iss delivery address diffe rent from item 1? ? Yes H YES, enter delivery address below: ? No 3. S?erv ce Type J IWCedtW Mail ? Express Mall ? Registered 6Ai um Receipt for Merchandise ? Insured Mali ? C.O.D. 4. Restricted Delivery? (Forte Fee) ? Yes s.. Article Number from" i ? kft# 7004 1350 -0003 7288 0396___,' (rfa?rsfer from service Ps Form 3811; February 2004 Domestic Return Receipt 102595-02-M-IM ¦ Complete items 1, 2, and 3. Also 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 mailpiece, or onthe front if space permits. 1. Article Addressed to: Wandq D• ROS W Gross rogd S ?I?wol Cgrlrsl? PA t?oiS-q??S C') C "? ?"` ?:: ? ? -3 ?` tic ? '? t ,? ?^"" , ?. g .>- 1. _. [`'+.j ?._} T, ?? ? .ham `-- "?° . - . ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 06-7281 WANDA D. ROSE, Defendant : IN DIVORCE PRAEC11PE TO ENTER APPEARANCE TO THE PROTHONOTARY Please enter my appearance on behalf of the Defendant, Wanda D. Rose, in the above- captioned matter. Date: 2L, I ?o?- Mark F. Bayley, Es ysfe Bayley & Manganl 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Defendant ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 06-7281 WANDA D. ROSE, : Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the within Praecipe upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Nathan C. Wolf, Esquire 10 West High Street Carlisle, PA 17013 Dated: 'O? ? q ___ 0 1?r Mark F. Bayley, Attorney for Dej C? ` <?- ? r? r -- r "L? -' .. _ .. ?_' f"7" ._:l M~ _ _. ? .r.... ROBERT C. ROSE, Plaintiff V. WANDA D. ROSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006 - 4704 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO : Wanda D. Rose, Defendant c/o Mark F. Bayley, Esquire 17 South West Street Carlisle, PA 17013 Robert C. Rose, Plaintiff, intends to file with the court the attached Praecipe to Transmit Record on or after January 9, 2012 requesting that a final decree in divorce be entered. WOLF & WgLF, Attorneys at Law Dated: December, 2011 BY: NAT WOLF, ESQUIRE Attorn for Plaintiff NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ROBERT C. ROSE, Plaintiff V. WANDA D. ROSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2006 - 4704 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE I, Nathan C. Wolf, Esquire, attorney for Plaintiff, do hereby swear or affirm subject to the penalties of perjury that on December 19, 2011, I caused to be mailed a copy of the foregoing Notice oflntent to Seek a Divorce Decree upon the following person, by United States Mail, addressed as follows: Mark F. Bayley, Esquire BAYLEY & MANGAN 17 West South Street Carlisle, PA 17013 Respectfully submitted, WOLF & WOLF Date: March 27, 2012 By: Nathan 'C- W 10 Wes H,Esquire ' Street Carli sl , A 17013 (717) 241-4436 Supreme Court I.D. No. 87380 Attorney for Plaintiff NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 f: ILL- (11 "P,0 7-1 'Q!? MAR 27 Ply 2: 5 I ATTORNEY FOR PLAINTIFF C L' M 5 E R L A N D U I{-, A NNSY1 VAJAIA ROBERT C. ROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WANDA D. ROSE, : NO. 2006 - 47ft4 CIVIL TERM Defendant : 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: On or about September 15, 2011, defendant's counsel was served with a copy of the divorce complaint via regular mail, addressed to the defendant's counsel. (See Acceptance of Service previously filed, September 19, 2011.) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: n/a; By the defendant: n/a (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: October 17, 2011 (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: October 17, 2011 - service upon Defendant's counsel. 4. Related claims pending: None 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: December 19, 2011, by regular mail addressed to Defendant's counsel. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: n/a Date defendant's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: n/a Marche , 2012 NAT OLF A e or Plaintiff IN THE COURT OF COMMON PLEAS OF Robert C. Rose : CUMBERLAND COUNTY, PENNSYLVANIA V. Wanda D. Rose NO. 2006 - 7281 DIVORCE DECREE AND NOW, ,,7 /, _,it is ordered and decreed that Robert . Rose , plaintiff, and Wanda D. Rose bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, y a.012- eerl. opry g, f r,e i cry mot"d fo ILLL 41491P