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HomeMy WebLinkAbout02-4268 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION) LYNETTEJ. RIDER, Plaintiff Vs. DIVORCE ACTION CHARLES L. RIDER, Defendant No. c1:< - t./;;t> '1 Type of Pleading: Complaint in Divorce IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION) LYNETTE J. RIDER, Plaintiff Vs. DIVORCE ACTION CHARLES L. RIDER, Defendant No. NOTICE TO DEFEND 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 judgement may 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, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ .\ l2.iD'"~ Plaintiff Vs File No. __ :J..fJrJ;) -l!J~~ f!lVl/ IN DIVURCE ~d..Q.s (..l2.to~e Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] ~rior to the entry of a Final Decree in Divorce, or ' ~ after the entry of a Final Decree, in Divorce dated hereby elects to resume the prior surname of 1/1 ~~Q written notice avowing his I her intention pursuant to he provisions 0 Date~-lo..~ffi~ i; 101XOij, , and gives this COMMONW%-LTH 9F PJ?NNSYL VANIA COUNTYOF~d On the /.Q~ day of q u.1L( , 200S, before me, the Prothonotary or the notary public, personally appeared the above affiant !mown to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. CJ{YlIrfJ~ .~~ Prothonotary or Notary Public NOTARIAl. SE.'l. ClAUDIA A. BREWBAKER. NOTARY PUBlIC Canisle Boro CumIle\IIIlId ColIllly My Cornn1iSSIOO ElCIJires'~ 4. 2009 ~ ~, ~ bor- ~ ~ V') I::> :t:. --"::;, <;} S::L ("') c .;:" ""Di~' r;~l,('. ;;3:-..- ;?- 1~_ ,!)" r: ;~ /- *.'t? j7.~ :z ~ 'i\1? ~ 1 0" ~ ~..... rn~ j1t;:' 0.6 """, :l:..,~ o~'- z~ 6 -., ~ -0 :::li: .r:- c:> N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION) LYNETTEJ. RlDER, Plaintiff C:j'v I I -- / er/'l'- Vs. DIVORCE ACTION CHARLES L. RlDER, Defendant No. () J- - tj,), b t COMPLAINT OF DIVORCE COUNT I 3301 (c) I. Plaintiff is Lynette J. Rider, who currently resides at 118 Cherry Ln, Dillsburg, Pennsylvania. 2. Defendant is Charles L. Rider, who currently resides at 480 Mt. Airy Rd, Lewisberry, Pennsylvania 3. Plaintiff and Defendant have been residents ofthe Commonwealth of Pennsylvania, for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married in September, 200 I, in Wellsville, Pennsylvania. 5. Plaintiff affIrmS that neither she nor Defendant are currently in the military service on the United States or its allies as defined by the Soldiers' and Sailors' Relief Act of 1940, as amended. 6. There have been no prior actions of divorce or for annulment between parties. 7, The marriage is irretrievably broken, 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter an Order dissolving the Marriage between Plaintiff and Defendant. ~!i2b ~5a$Xl2 VERIFICATION I hereby verifY that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904, relating to Unsworn Falsification to Authorities. c# Lynette J. Rider, Plaintiff Vs. Charles L. Rider, Defendant COURT OF COMMON PLEAS (CIVIL DlVISlON) DlVORCE ACTION No. 0:1- ~;2&>~ The complaint was hand delivered to Charles Rider on SERVICE OF COMPLAINT Signed: ~~~~ (') c ;:;~~ ~ .:' =t :...> '-"/ :......) r~ " ::n ,-" --<'0 , c") :l;,~, , ' -', :b -< LYNffiE J. RIDER V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES L. RIDER NO. 2002-4268 CIVIL TERM ORDER OF COURT AND NOW, this 20TH day of NOVEMBER, 2003, it appearing to the Court that the Plaintiff's Affidavit of Consent and Waiver of Notice were not filed within thirty (30) days of the date they were signed as required by the Pa. Rules of Civil Procedure, the request for the entry of a divorce decree is denied without prejudice. We will reconsider this matter upon the filing of an updated Affidavit of Consent and Waiver of Notice by Plaintiff. 4ette ~arIes Edward E. Guido, J. Rider Rider ;> . ~d. :sld II . 20 . cr.:, IJ'iIW^1.~SNN3d U~J(Yi'" (;',,",r]'-:~rjIMn"" ' "-.-'., "-.-",. YI{ v ;c;:t: '.1 O? CO Ci IN THE COURT OF COMMON PLEAS OFGll\ 1\":{ \ k\\d ClLlllh,/ PENNSYL V AN/A (CIVIL DIVISION) J L'1rl?Jrt<2 ~ ~QdEr- Plaintiff DIVORCE ACTION C~~'D dccs l_~\c~r No. dCO::). - C~cl.c6 Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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! 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 Waiver 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:/J ~ ~m~ I I 4ndt.'t>7>fd ---" C") 0 0 ~ c.> -11 0 :.::/j "'U 0:; ,.." !pm C"') '~-Ji;n :tl , -8'" ~~' CO -,1' "'~ '" ." :,;::~, -0 '):-+1 ~Q :Jl: 'J(') c iSm .:sc ,""" ~ .c- ~ IN THE COURT OF COMMON PLEAS OFCLIII\\X:'llcilcl (llilll~' , PENNSYLVANIA (CIVIL DIVISION) l\.\t~-He-~) ~\cl(:y Plaintiff DIVORCE ACTION vs. ()--.,u,\es L 1=<1<.1('(' No. JCCU -ct~8 Defendant AFFlDA VlT OF CONSENT UNDER SECTION 3301~ I. A complaint in divorce under Section 330 I (c) of the Divorce Code was filed on 01 -(p -~Co'""" 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date ofthe filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that r may lose rights conceming alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and a correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: /d IR A{)')"3 ( '/ 0 0 (j c W ~l'1 s:: <::1 --I "1Jm ,-., ~' 52rr. C'") h't:; Xi I '--rJrTl 655; CO ';)7 ~..: ,-J,o ::::::C~;; -0 Tji ~c ::x ~-'CJ 0 Lrn >>c () '-i ~ 55 .. -< COURT OF COMMON PLEAS (CIVIL DlVISION) Lynette J. Rider, Plaintiff Vs. DlVORCE ACTION No. J..DO'd.- oya(o~ Charles L. Rider, Defendant SERVICE OF COMPLAINT The complaint was hand delivered to Charles Rider on -1dpr? i I .~; ?m2.. Signed; G?'XJC ___ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION) LYNETTE J. RIDER, Plaintiff Vs. DIVORCE ACTION CHARLES L. RIDER, Defendant No. Type of Pleading: Complaint in Divorce IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION) LYNETTE J. RIDER, Plaintiff Vs, DIVORCE ACTION No. ,JOO!) - D1 JMs CHARLES L. RIDER, Defendant NOTICE TO DEFEND 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 jUdgement may 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. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 HA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DlVISI0N) Vs. DIVORCE ACTION No. &~ - o~2/pB LYNETTE J. RIDER, plaintiff CHARLES L. RIDER, Defendant 1. Plaintiffis Lynette J. Rider, who currently resi,ies at 118 Cherry Ln, Dillsburg, Pennsylvania. 2. Defendant is Charles L. Rider, who currently resides at 480 Mt. Airy Rd, Lewisberry, Pennsylvania COMPLAINT OF DIVORCE COUNT I 3301 (c) 3. Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania, for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married in September, 2001, in Wellsville, Pennsylvania. 5. Plaintiffaffmns that neither she nor Defendant are currently in the military service on the United States or its allies as defined by the Soldiers' and Sailors' Relief Act of 1940, as amended. 6. There have been no prior actions of divorce 01' for annulment between parties. 7. The marriage is irretrievably broken, 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter an Order dissolving the Marriage between Plaintiff and Defendant. VERIFICA TION I hereby verilY that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904, relating to Unsworn Falsification to Authorities. ~' ( ~ ~ uJ~~ c;-2t>l li: :Y~ C)t: 2:,,' ~~:;,:j 1': u_ o t ("') (<", N :;r.: a- N ::> Cl % ("') o -- c_ Z ,:?' ,0;; ~-~!,~ >. r-:)...J 7~ ~ if) ";:2 ,r.: :2 ;,lluJ ,):.)n.. -:: ... ::::> u IN THE COURT OF COMMON PLEAS OF Cki:erhr'd CU.\\l13 PENNSYLVANIA (CIVIL DIVISION) ~I'~ S. ~'\de:1- Plaintiff DIVORCE ACTION vs. c.,ro\'\Q.S L ,Q~ cQY'" No. 61~ -OLJ-dGB Defendant AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) 1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on CA - (){a - d-..oO ~ 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and a correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: I; /~ / JeN ( / ~t'm-vt~o7 2 ",.. -otf' n-lfi, Z::r Z" <n~> -c ~c. :E;:C"' A!"C;t~; :i>c' "7 ::=, -< o w z C) c.c; o " ., ,'hfl:} ,'TI "~b , I ~;o -~.- "T, ':'~) :a ,0 ::;1"Tl ---1 )> ~ N .., ::II: r::> w (...> IN THE COURT OF COMMON PLEAS OFCumoo-lcu"'(l Cb.ut~PENNSYL VANIA (CIVIL DIVISION) ~~~. ~\dex-- Plaintiff DIVORCE ACTION vs. No.dCibl- o'ta196 ~hQ\\.es L, \<\ cky Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I, 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 in 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 Waiver 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:fd/~ I '/ ~~~^ (") co (") c: W "Tl s: ~ -o(~ c:::> "j; ~[ ..,:: ;-:: ::1 d' &;5.-, .:r---' l'.' ..:-..,... -<~ ~:~j ~~f. kC -0 ' -d ~C ::!l: ~~)- -:,..,0 :x;C ~ c5m c ~ z w =< Co) -< IN THE COURT OF COMMON PLEAS oFCLnIOCdQrcl CtuJlu, PENNSYLVANIA (CIVIL DIVISION) , J L~re~ 2). ~\~ Plaintiff DIVORCE ACTION vs. No, ct~ -ot'.Jl.98 D,ar\es L. ~\de\ Defendant AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) 1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on m -(0 -d.CO~ 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date ofthe filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 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. I verify that the statements made in this affidavit are true and a correct. I understand that false statements hcrein arc made subject to the penalties of 18 Pa.C.S. ;j4904 relating 10 unsworn falsification to authorities. Date: (I III /03 I '/ Crr/ '~ ---- 2 <" -of;' 929, ZC; (j) .' ~", '<'- ~(~ ""C, .YC, ~ ~- -j -~ o CA Z o <: o ..,., ,-.-l ~.4~~ -"q ;.~)() 1~~ :c~~M ~ .5:) '< ", -n ::JC ~ W W IN THE COURT OF COMMON PLEAS OFG.lI\I~~ a.eel Cbu.ntu PENNSYLVANIA (CIVIL DIVISION) 'J Ll..\iC~ ~. ~\dey Plaintiff DIVORCE ACTION ~6"D L ~\dcy' No. C1CQ9. - ()1-~B Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted. 3. 1 understand that 1 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 Waiver 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:~~ _a-~ (') <::> ~ c: w <;- ;;e :~~i :'OD" ';::) !.;2n .'<;: '~ ::.:.:.,' ", &if;' - ~ 1 , , ~:.- I',J ,~.:, crJ ;::$r' '-1f:J ~. :it -~ I, ~Q :~C?J5 SC '::> C5fr, c ~ w :ig (.-.) -< L~~ -S ~d~, IN TIlE COURT OF CCMMON PLEAS OF CUMBERLAND CCXJNTY, PENNSYLVANIA NO. m-46l.&8 CIVIL 19 vs. Cna r-\e5 L ,K id ef 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: i=etrievable breakdown under Section 3301 (c) J~~- ... PI of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: Pard de[lvew nn A-pn' \ 30) &COJ- 3. Canplete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff 1d-[5 - 03 by the defendant / / - / J - 0.3 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (Vt 1/ _~I (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: non~ 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code o&~d,;.~~ ../ ..." ~~ c.'""::} -=- ..." P"l co N _J o -n -l ~ fi1:Q ,-- "TJ rn :':JO ~'). I ,=-0 -,:loTi ~~ '" ::~ -< -r) N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO, 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 93301 (c) 3~)(1) of the Divorce Code, (Strike out inapplicable section). Date and rnqnner of service of the complaint: -'do. c0 _ o\e1 ~ \Jf'~ on ~~\l~_~_~ 2, 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff I:), = (Q - Q{(X:b). ; by defendant II -It -03 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: 11- 11- Os (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 'll:- I 2 - D 3 ---------~--~ 4, Related claims pending: ~nf' , 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 93301 (c) Divorce was filed with the Prothonotary: _ \ \ - \-:2- -C) '3 Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: ~- \. '2 - 0"3 AlIorney for Plaintiff / Defendanl (") 0 0 c (.J "T1 ;;: % c~j -on (.;:) .~.:, :n SP ~<::: 'C- 1,1, Zt.. ._',r'1 en, N :)~'S .-< ~, kC' 1..,- -0 '. -T1 ::<> .. ::::i' (.'>'0 zt. 'C r;:> ")m :;>- c .-1 k, c:- ~ =<' (Jl -< . .. . . . . . .. . . . . . IN THE COURT OF COMMON PLEAS . . . OFCUMBERLANDCOUNTY . STATE OF PENNA. . . . . . . 1jn~ ,~. h'\del NO.~ - ot.%8 . . . . VERSUS Lbar\~ L hi&r . . . . . . . . DECREE IN DIVORCE . . . /It~{ dob> , , . AND NOW, IT IS ORDERED AND . . . . DECREED THAT J .\ ~f\e.M-e, -S. C bad~ L "R'\del DEFENDANT, ~'br- PLAINTIFF, . . 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; . . . . . . noY"€.. . . . . . . . . . ATTC"T~~ J. . PROTHONOTARY . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '~:e~ ~u, Ar7 r-Z ~ ~ ~>Y ~c7 ~ ftt? c> - c.