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Home My WebLink About06-7303 Rhonda L. Schoffstall, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. William L. Schoffstall Sr., Defendant CIVIL ACTION - LAW No. O(p - '1303 CIVIL 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 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 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. 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, 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. 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. Rhonda L. Schoffstall, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VI. CIVIL ACTION - LA W No. CIVIL IN DIVORCE William L. Schoffstall Sr., Defendant COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Rhonda L. Schoffstall, an adult individual, who resides at 4513 Linden Avenue, Apt. B, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is William L. Schoffstall, Sr., an adult individual, who resides at Lot 3-A Juniata Haven, Port Royal, Pennsylvania 17082. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 13, 1995 in Middletown, Dauphin 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, and the parties separated on April 2004. 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. Respectfully submitted, ROMINGER & WHARE Dare: r~(tk )- k~l E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court J.D. # 81924 Attorney for Plaintiff Rhonda L. Schoffstall, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W No. CIVIL IN DIVORCE William L. Schoffstall Sr., Defendant 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. S4904, relating to unsworn falsification to authorities. Dale: /{}. !t/~ I Rhonda L. Schoffstall, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW No. CIVIL IN DIVORCE William L. Schoffstall Sr., Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, Rhonda L. Schoffstall, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: William L. Schoffstall Lot 3-A Juniata Haven Port Royal, Pa 17082 /2(1?t\ ~- Date: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Court Id. No. 81924 Attorney for Plaintiff ~:~:-,; :!3 '- o c ........" -.I::~ - ..- f'-..) '::':J. ~-J c~ t::::J r'l () N Co o -q =::! ;-il:rJ r- ---0 ,'f'I ~'}C) (~,~; fl., -., -c " " -) .-:-:..- ;:~j't1 ::,,: :0 --< Rhonda L. Schoffstall, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. William L. Schoffstall Sr., Defendant CIVIL ACTION - LAW No. CJp-'1303 CIVIL IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow, Rhonda L. Schoffstall, 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: 17 ~ k / Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Attorney Id No. 81924 o ~ <.: ,.....;) = c:;:.::> 0' CJ ''1 n N CO o -n --t I-n n1p fT' ]~\ IT,,': (-...J :;.: ~'.l t~ ~~~ ,--. -,.7.'Jo :~~ ~D --' =< -( ()1 Rhonda L. Schoffstall, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. William L. Schoffstall Sr., Defendant CIVIL ACTION - LAW No. {)(p -1E:;{)'?> CIVIL IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 2004, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. S 4904 relating to unsworn falsification to authorities. Date: 171706 /fL,~ :/. ~~ Rhonda L. Schoffstall, Plaintiff CJi r--.;, C::> = 0'"\ o P"I CJ N CO o -n ~ r f1 ;:n -arn -,c'G j~:::: ,,-':j~) -.-"c) :0::' r1-': ?~ ~i::J -< u Rhonda L. Schoffstall, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. William L. Schoffstall Sr., Defendant CIVIL ACTION - LAW No. DIP - 75D3 CIVIL IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. Date: William L. Schoffstall, Defendant ,...., = = 0-' o rq C-:;, o ." :1! In f1J -ocr:: ~r--r I,..""', 1.1~ ii .-<: r" CO en Rhonda L. Schoffstall, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. William L. Schoffstall Sr., Defendant CIVIL ACTION - LAW No. 06-7303 CIVIL IN DIVORCE ACCEPT ANCE OF SERVICE I, William L. Schoffstall, Sr., hereby accept service of the Complaint in Divorce, Affidavit signed by Plaintiff, Defendant's Counter-affidavit, and Notice of Intention in the above-captioned action and I certify that I am authorized to do so. DATE: JYJ.4-ecH ~ 2007 ~ By:~ William L. Sc stall, Sr. / Defendant g ;g: -0 l'P 0;Jq: :t7 f: ~~~-..- r::.C <'- Y.: C' b i.:::; 'P'C Z -~ -< ~ :Jt p. ';0 N N ~ ~--n fli P' -om ~nO r~b :L;~ -0 (:) . =' z~ _ S ;- ~ c.n Rhonda L. Schoffstall, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. William L. Schoffstall Sr., Defendant CIVIL ACTION - LAW No. 06-7303 CIVIL 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 g 3301(d) of the Divorce Code. 2. Date and manner of service ofthe Complaint: December 28, 2006, First Class Mail, acceptance of service signed on March 2, 2007, Proof of Service attached. 3. Related claims pending: None 4. (1) Date of execution ofthe Plaintiff's Affidavit required by g3301 (d) of the Divorce Code: December 17,2006 (2) Date of filing and service ofthe Plaintiff's Affidavit upon the Respondent: Filed December 28, 2006, Served March 2,2007. 4. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree was Served on Defendant by First Class Mail signed acceptance of service on March 2, 2007 Proof of Service attached. , Date: March 22, 2007 ~.) ~~ ----..- Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 () c:: ~, -U lJJ mp, ~-;--i z( UJ. "', ~.,: !<C "!-'" "-', Z;'..:} ~C: ~ -... ,..;) = = -...t ~ ~ m~ -otS :Pi 00 :rJ,,; ?S:D ,. (") ::;..;: rn ~ ~ ::!It :;po ::.xl N N -0 :% - .. .:;:" cJl if. if. IN THE COURT OF COMMON PLEAS if. OFCUMBERLANDCOUNTY Of. PENNA. if. if. STATE OF if. if. if. Of. RhomE L. Schoffstall'! No. 06-7303 if. if. Plaintiff if. VERSUS if. Willi~m L. Schoffstall, Sr. J)pfpnn;:mr DECREE IN DIVORCE ~ /6..t(3A,A. }6/J I IT IS ORDERED AND AND NOW, m~;1 DECREED THAT Rhonda L. Schoffstall , PLAI NTI FF, William L. Schoffstall, Sr. , DEFENDANT, AND 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. if. PROTHONOTARY if. if. if. if. if. if. if. if. if. if. :of. Of. if. ATTEST(!~ ~ if. if. Of", ft; if. if. if. 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