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HomeMy WebLinkAbout06-7286Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. ©(r,- '],'fig fo 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 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, 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. Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. CIVIL Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Brandy L. Ryhal, an adult individual, who resides at 444 First Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Jason S. Ryhal, an adult individual, who resides at 110 Fifth Avenue, Youngstown, Mahoning County, Ohio 44503. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 24, 2004 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: ' ~ /~ Respectfully submitted, ROMINGER & WHARF Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court LD. # 81924 Attorney for Plaintiff Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF pl.,;,,+;ff ~`T TT TRRp 7 A RT71 (`!1T TATTV pRT~TT~TC VT ~ 7 ~ TTT A V. CIVIL ACTION -LAW Jason S. Ryhal, 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 unsworn tatsitication to authorities. Date: ~ ~ -ao -Q ~~~/~'~` Brandy L. R al, Plaintiff Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION -LAW Jason S. Ryhal, No. CIVIL Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, 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: Jason S. Ryhal 110 Fifth Avenue Youngstown, OH 44503 Dated: 2~ ~' F Karma Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff r> ~' ~-. ~- ~.7 -,--. -rl ~ ~- ~,._ , i; r - r.~ i - -.~ r -. - - -~.~ - - .. ,. j l d' :'f ~, =:~ __ ~ ;,,G Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. ~(~ ' rf ~g(J CIVIL Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow, Brandy L. Ryhal, Plaintiff, to proceed in forma pauperis. I, Karl E. Rominger, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Date: ~ I ~~ (~ i~' Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Attorney Id No. 81924 C7 ra i~ :~:~ r~^. -~ - ~ R '' - • ~' ~ .i 4`. _ __ ......r _ ~,. . t,:- __ ~ Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. 06-7286 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 26, 2007. 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 unsworn falsification to authorities. Date:_ y- ~~~0`1 Bra y L. hal, Plaintiff C7 rv c ° o ?~ ~ ;- _ -~ _.... ~ ? a .. _ ' ~~ ~ __ i ~ '~ ~ ~.1 y ` ^ ..1 'l Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. 06-7286 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: ~I ' e~~'-O~] Brand . R al, Plaintiff cy ~ ~ '~T` V ^,~. "C ti7?? ; ~ .: { ; r-- ~ ~.,. • , %ti R7 ~ +/ w !'1 `' Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. 06-7286 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 27, 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 unsworn falsification to authorities. Date: .S~ /,~d 7 t ~~ `...1 Jason S. R ,Defendant o ~ _ ~~ ~ _.. ~„ ..,~ ft7 f s? `. ..... , rrt ~ ~~t _ T} ~~ ,: _ T~ ~ J * ~ ~ ~~,,~1 ~. ~ ~- (Jt ~.. ., ,.~ Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. 06-7286 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:S'"rC-p~ ~~ rte'/_ Jason S. R al, Defend t cn o .~= ~ o T,, :~ _ .~~` . „ ~ "'/ ' ~ ., i, i , C i l~, „ _ + r, ^1 ~... ' ~ ~ Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vi. ' CIVIL ACTION -LAW Jason S. Ryhal, No. 06-7286 CIVIL Defendant IN DIVORCE PROOF OF SERVICE ^ 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 on the front if space permits. Article Addressed to: ~n S . 2yha\ q 8$~ u~~a~~-, ~a A. Signature ~( ~ ^ Agent ~'O""` ^ Addressee B. Received by (Printed Name) C. Date of Delivery 5~so~ ~..~ ti ~ ~ D. Is delivery address different from item 1? ^ Yes It YES, enter delivery address below: 1~ (F, ,.,1 `„ ~ ~ ~ ~ ' ~ 3. Its 15rpe ~ `I l)~( `f-'V ~ ~ ifled Mail ^ F~cpress Mail / ~ ^ Registered ~Retum Receipt for Merchandise `-~ Gy ^ Insured Mail ^ C.O.D. 4. Restricted Deliveyl(Extra Fee) Yes i. Article"`M'bar 7006 2760 0002 74D..«.::. . (Fiansfer from sake ~ PS Form 3811, F - " Y 2004 Domestic Return Receipt ~025~-02-M-~5go n . ti ~ p: _ = ~ o _~ ,_ ~ rye r;.i?7 ~_ - 't`p IT; _ ~.~ T~ ~ ~ y;' +•r _ ~l ~- +_ Brandy L. Ryhal, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Jason S. Ryhal, No. 06-7286 CIVIL 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: December 27, 2007, was served on Defendant by certified Mail green card signed on January 20, 2007 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by § 3301(c) or The Divorce Code: by the Plaintiff, Apri121, 2007; by the Defendant, May 11, 2007. 4. Related claims pending: None. 5. Date Plaintiff s Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 14, 2007. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 14, 2007 Date: May 15, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 200198 C~ C N c ' ~ -..., rl ~; --r t j'f L ~ p-, _~ ~ 1~ i* J~ + ~ _.i3 . ~ "'~ I N T"H E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '~ PENNA. __ .. Brandy L. Ryhal -~'~' ~'~ Plaintiff No. 06-7286 VERSUS Jason S. Ryhal Defendant DECREE IN DIVORCE AND NOW, M~ -?3 , ~, IT iS ORDERED AND DECREED THAT Brandy L. Ryhal PLA1 NTI FF, AND Jason S . Ryhal 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 ~~~ ~ ~~ ~ _ .. y C-,Q° ~ ~ ~.~~ -~~ s