The URL can be used to link to this page

Home My WebLink About96-05450 ). \I .~ ... .~ - -.1 CJ f . . ****~~-*-~--*~******~*.~***~.~-*~ ~. --~.---.-.......--------.-~,---,...--_...-...._'" ....- ......-.'-- ..........~...---....-.~ ,...-. ,~,........... - " - .. .- ._._~ .... ...-,--... ,..-........-. ......_-~-_.--~-~,--. ----.... .---- ---.\ ~ I.', (~ /. i~ )'0' ~:: '.'\ I ...' ~ ~! ',') , ~. ~ ~ ~' ~ ~ * ~ c. ~, ...J ~i , ~, ~.i ~( ~:: ~ ~, W ~.r !!!' ~,' ~ ~ Mi , , IN THE COURT OF COMMON PLEAS ;~ OF CUMBERLAND STATE OF ~~ ~ .....l/Q'; .-r COUNTY ~ v '.' PENNA. " ~ " ~ ~ " ~ NICOLE K CLIPPINGER, Plaintiff :\ II. 96-5450 Civil Term ;8 I. ~~ o. )~ /. I~ o. i. }~ l I~ ., \'1'1'..;j"; THEODORE B. CLIPPINGER, Defendant }l.. DECREE IN DIVORCE '8 .~ ~ ~ $ AND NOW. . August -.! 'J ~ 19 91. '. it is ordered and decreed that NiCQle K. Clippinger and . theodOre B. Clippinger ore divorced from the bonds of matrimony, '. plaintiff, defendant, M '. ~ ~ ~ ., ~l : ( ~! 1 ~l ~I ;,\ o ~) Ml Xl !I' . II !l , . ~ The court retains jurisdiction of the following claims which hove been raised of record in this action for which a final order has not yet been entered: ~ ~ ~ None. The Marriage Settlement Agreement dated July 11,1997, a redueed copy otwhich ~ is attached as Exhibit "A" is Incorporated heffln and t~ provisionJ thereol made a part ~ of this Decree. ~ ~ 1\ , .;~~t'/I'IL .' ,\tln" _"" ... . . ~ ,", j ~. ,.....,:;c. c- .:wiC~ /~:W... r ";~/~" .. ~ ~ 1.~..X"\...-7.-,. J .;' AJt:4 1It'>.thr_>>td~lf \' ~ ~ . . ... ". .... -.. .' .. :. ...: _.'.._ . ... _. it' .. ~ ..: . :.' " . MARRIAGE SETTLEMENT AGREEMENT \ \t.,\-- ~ THIS AGREEMENT made this day of ~ 1997, al Carlisle, Pennsylvania. between Nicole K. Clippinger, now Nicole Kelley. formerly of 1150 Crain's Gap Road, Carlisle, Pennsylvania 17013. now 01 1750 Powder Springs Road, Suite 190.303, Marielta, Georgia 30064. hereinafter relerred to as the 'Wife" and Theodore B. Clippinger, 011150 Crain's Gap Road. Carlisle, Pennsylvania 17013, hereinalter referred to as the 'Husband" ARTICLE STATUS OF PARTIES 1.01. Date of Marriage. The parties were married on July 11. 1992. in Carlisle. Pennsylvania. and ever since thai time have been, and are now, husband and wile. 1.02. Children. The parties have no issue resulting from this marriage, living or deceased. and have no adopted children. 1.03. Separation. Unhappy differences have arisen between the parties. and as a result they have lived separate since a date in the month 01 Septamber. 1996, It shall be lawful lor each party at all times hareafter to live separate and apart Irom the other at such place as he or she may Irom time to time choose or deem lit. The loregoing provision shall not be taken as admission on Ihe part 01 either party 01 lhe lawlulness or unlawfulness of the causes leadlOg 10 them living apart, 1.04. Legal Proceeding, A proceeding lor the divorce of the parties has been fried by the wife in the Court of Common Pleas in and for Cumberland County. Pennsylvania, to No, 96.5450 Civil Term. Husband ag,ees to consent 10 the entry 01 a Decree in Divorce and 10 sign all necessary waivers and allidavlls required for said Decree. including Ihe waiver 01 marriage counseling. This Section 1.04 shall be an express condition 01 this Agreemenl and any breech of thiS Section 1.04 shall Vf:st the nonbraaching party with all of Ihe rights and remedies herainafter described al Sec1ion 5,07(8). and any other ,ights or remedies available. which shall be cumulative and separable and anyone or all 01 which may be enlorced by the nonbreaching party. 1. OS. Other ProcMdlng. Nothing here.n contained shall be deemed to pravenl eithar 01 the parties lrom begmnm9 Of malOtallllng a suit lor absoluta dtvorce agaln't the othar 10 any JUnsd.clton based upon any past conduct of the othe,. nor to bar the olhe, lrom defendong any such su.t. In Iha avent any such acllon is .nsblutad or concluded. the pames shall be bound by all m. lerms of lI'lls Ag,eament. 1.0'. C,..,.,. of N_, Wife has already resumad he' "'Biden na.... and agrees to ,asurne her mai<Mn name --- -.... (~"".-..... (~ PHlln "A" "'->JIII \.\.-[~ . in full and satisfied contemporaneously with the signing of this Agreement. (2) Any student loans in Wife's name alone. (3) The loans allocated to Wife by Section 3.02 of this Agreement, which obligations shall be paid In full and satisfied contemporaneously with the signing of this Agreement. (4) The obligation to Brad and Lucy Gay having an approximate balance of $800.00 at the time of separation, for which Wife shall provide a release of Husband. (5) Any other loans in Wife's name alone. Wife agrees to Indemnify and save harmless Husband from any claim or liability that Husband may sulfer or may be required to pay on account of any such above.mentloned encumbrances, liens or loans. (b) Husband shall assume sol. liability for: (1) Any student loans In Husband's name alone. (2) The loans allocated to Husband by Sec1ion 3.02 or Section 3.04 of this Agreement. (3) The lollowing credit card debts, or other obligations, with their approximate separation balances: (i) Capilal One - $2.925.00; (ii) Chase Manhallan USA. $7,161.00; (Iii) Dauphin Deposit Bank and Trust Company . $790.00; (iv) First Bank 01 South Dakola (now evidently Rocky Mountain) - $3,566.00. (4) All credit card debt, bills, loans, or other obligations 01 the patTies while married and living together end not otherwise specifically allocated to Wile by lhe express terms 01 this Agreement. (5) Any other loans in Husband's name elone. Husband egrees 10 indemnify end save harmless Wife from any claim or liability that Wile may suffer or may be required to pay on account 01 any such above-mentioned encumbrances, liens or loans. 3.04. Am....y O"/e,,hlp. Husband shall receive as his sole and separate properly \he patTies' Amway Oealership and shall be IOlely responsible lor any loans, bills, amounts owed, or claims 01 third parties arising out of that dealership or the producls sold through It. Contemporaneously with the final uecution 01 this Agreement Wile shall deliver to Husband a duly e.aeuted Assignment 01 Ois1ribulorahip and Husband shall detiver to Wile a duly executed Acceptance of that ASSignment. 3.05. LIfe IIt,uralt" pollc/e.. Each parly shaft relain the hIe Insurence policy in their own name, Wiht has a Globe UIe and Accident Insurance Company policy wtlich slle shall relain as her sole and separate properly, Husband 114s a tile insurance policy purchaMd through Carlisle Stata Farm Ineurance agent H. Oavid WIer and which he iN. leta,n as his sole and "PArale properly. 3.0'. s.riftt. 811" Cllecllnt ACCOlIIIta. Eaeh parly shall ,.taln as \heir sole and separate ~rly any Iunds 111 any RYingS 01 --- --.. c..........~. t~ OHlin "A" ..... J \~. , ~..' both parties. 5.02. R.I.... of All Claim.. Each party hereto releases the other from all claims, Iiabilitias, debts, obligations. actions and causes of action of every kind that have been or will be Incurred relating to or arising from the marriage between the parties. However, neither party is relieved or discharged from any obligation under this Agreement or under any instrument or document executed pursuant to this Agreement. The parties agree that this Agreement is in lieu of all claims and rights under the Pennsylvania Divorce Reform Code. effective July 1, 1980. and specilically the equitable property distribution provisions therein and also any claims and rights under the divorce or property distribution statutes or law of any other jurisdiction. Each party further ag,ees never to assert any claim against properties listed herein as the sole and separate property of the other party nor properties otherwise owned by the other party Individually or with third persons, 5.03. Holding Other Party Fr.. and Harml.... (A) The Husband hereby represents and warrants to the Wife that he has not incurred (except as otherwise specified in this Agreement), and hereby agrees that he will not hereafter incur, any liability or obligation on which she is. or may be. liable. If any claim or action is initiated attempting to hold the Wife liable for any such liability or obligation. the Husband shall, at his sole expense, defend the Wife against any such claim or action. whether or not well.founded, and he shall hold her free and harmless therefrom. (8) The Wife represents and warrants to the Husband that she has nol incurred (except as otherwise specified in this Agreement). and hereby agrees that she will not hereafter incur, any lIablhty or obligation on which he is, or may be. liable. ff any claim or aclion is initiated attempting to hold the Husband liable for any such liability or obligation. lhe Wile shall, at her sole eapense, defend the Husband againsl eny such claim or action, whethe, or not well-founded, and she shall hold him free and harmless therefrom. 5.04. W.lv.r of Right. to Oth.r Pol"". Es'.'.. Husband and Wife each waive any and all right: (A) To inhenl or elect under any current or subsequenl statute or law any part of the estale 01 the other at his or her death. (8) To receive property from the tstate of the other by bequest or deVIse. axcepl uncler a will or codicil dated subsequently to the e/lective cUle ot this Agreement. (e) To act as the person&l represenlatlve 01 the estale 01 the other on Intestacy (unless nOmlnated by another party legally entllled 10 10 ad). (0) To ac1 as the personal representative under the _tll 01 the other, unle$l 10 nommafed by a will or codicll deted subsequently to the ...--- ..... ~... h...,.. I C......,.. ; 'HIli" 'W P"IJOI \\ .- . 'j( ,,,......._-' effective date 01 this Agreement. 5.05. Full DI.clo.ure. The Husband and the Wile each represent and warrant to the other that he or she has made a lull and complete disclosure to the other 01 all assets 01 any nature whatsoever in which such party has an interest, 01 the Sources and amount 01 the income 01 such party 01 every type whatsoever, and 01 all other lacts relating to the subject matter 01 this Agreement. 5.06. Freedom from Interference, Neither party shall harass, annoy or interfere with the other party in any way. Neither party shall interfere with the other's employment or other business activities, or with the use, ownership or disposition 01 any property now owned or herealter acquired by the other. 5.07. Sub.equent Divorce. (A) Nothing herein conlained shall be deemed to prevent either 01 the parties Irom maintaining a suit lor absolute divorce against the other in any juriSdiction based upon any past or lulure conduct 01 the other, nor to bar the other Irom dalanding any such suit. In the event any such action is instituted or concluded, lhe parties shall be bound by all the terms 01 this Agreement insolar as they relale to lhe equitable distribution 01 property, support, alimony. alimony pendente lile, counsel lees, cosls and expenses. (B) It is expressly agreed that as a condition lor the signing 01 this Agreement both parties agree to consent to the entry 01 a linal Decree divorcing the parties and lhat relusal by one party to consenl 10 said divorce shall. as in any other breach 01 this Agreement, vest the other party with the option to void, all or a part 01 this Agreement. Monetary damages, except lor legal lees and Costs shall not be available lor breach 01 lhis Section 5.07. 5.0'. Repr...ntatlon of Partl.. by Ind.".nd.nt Coun..'. each party has been rep,e.ented by an independent attomey, who was .elected by the party whom he represent., in the negotiation and preparation 01 this Agreement This Agreement ha. been fulty ellJllained to eech party by that party'. attorney. each party ha. carefully read this Agreement and is Completely aware. not only 01 ils eontenla. bul also 01 its legal elleel and acknowledges thai the Agreement is lair and equilable and thet .1 i. being entered into "oluntallly and that it I. not tha re.u1t 01 any duress or undue influence, 5.ot. Breach. II eIther party breaches any proviSlOn 01 thi. Agreement, the other party shall have the nght, at his Of her election, 10 sue lor damayes lor such breaCh, "Qf1j eU Ot a part 01 thIS Agreement. or ....... Such othet remedies or rehet I' ""'y be I"a.labla 10 him Of her, These remedla. shall be cumulatIVe and not on !he alamaliVe the party Mlehong thIS Agreement shan be responSible tor paY"*'t ot legal .... and coat. IfICImed by the otha, ItI enlOtCItIg their ng/Ita under lhia Agrument 5. ro. ModUIeallon (H Wehw. A modtl1callon or wal~r 01 --- ...... =e...,. - ~. ,............ j 'HIlJIT "4" ~... t . ,. NICOLE K. CLIPPINGER, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5'1'5'6 {~~ ~~" IN DIVORCE v. THEODORE B. CLIPPINGER, Defendant NOTICE TO DEFEND AND CLAIM OF 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 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: CUMBERLAND COUNTY COURTHOUSE CARLISLE. PENNSYLVANIA 17013 TELEPHONE: 24Q-6195 IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY. LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE m ANNULMENT IS GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO m TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR. FOURTH FLOOR CUMBERlAND COUNTY COURTHOUSE CARLISLE, PENNSYlVANIA 17013 TELEPHONE: (717) 240-6200 NICOLE K. CLIPPINGER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- :/'/1<: (I.,:.J' Ti-<.- THEODORE B. CLIPPINGER, Defendant IN DIVORCE COMPLAINT IN DIVORCE Section 3301 (c) 1. Plaintiff is Nicole K. Clippinger, an adult individual, who currently resides in the Borough of Carlisle, Cumberland County, Pennsylvania (mailing address: c/o Stephen D. Tiley, 5 South Hanover Street, Carlisle, PA 17013). 2. Defendant is Theodore B. Clippinger. an adult individual, who currently resides at 1150 Crain's Gap Road, Carlisle (North Middleton Township), Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. The Plaintiff and Defendant have been bona fide residents of Cumberland County for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on July 11, 1992 in Carlisle, Cumberland County, Pennsylvania. 5. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 6. The plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in counseling. 7. The marriage of the parties is irretrievably broken. 8. After ninety (90) days have elapsed from the date of the filing of thit Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Neither party it in the mlIitary seMc:e of the United Stetes Within the pI'OVi$lons of the Soldiers' & Sailors' Civil Relief Act of Congress of lIMO and its amendments. NICOLE K. CLIPPINGER, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96.ff>,~i> c.;....} "-.u.--' IN DIVORCE . . v. THEODORE B. CLIPPINGER, Defendant . . . . AFFIDAVIT OF NOTICE I, Nicole K. Clippinger, according to law, depose and say: (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 Domestic Relations 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 to a divorce decree being handed down by court. 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. Date: a \'O.-)l;l '2., \OPll.p ~"'-- . ~'J, " ~J:'" I '\t) ?i - ~- ~ i ....~.. 'k~"' ~ -;' .... f.,.-, <.:: ~~.'~).h" '~;J'" ~l"'; '..:.Ii.: p_ _'. ...."'\.s <d' ...., ''';4 "I ' ;~.' }:: '" ., f'} ,:,;. .' ,""..';J~. <.....1- "..-- " a _ .CJ tr{if ::: j . U .. .... J. ~J ~ l' ,"l ~ .~ ~.'~ 1\ .~~ e At .J !~ I IIlI !l; ~ :fAt 1IQc! 0 08 ! S 0 ~~ ~ ~ :5 ~~I~I tj~ >- ~ :;J1ll~ 0 01> 1IQ 0 as dUI 0 U::I..:l III :.i :I SBi .0 e! 8 ::I ....1 oa 0 8 !lOllo .:5 ~ S ... .. .. . . '. . NICOLE K. CLIPPINGER, : Plaintiff : IN TilE COURT OF COHHON PLEAS : . CUMBERLAND COUNTY, PENNSYLVANIA . : VS. : CIVIL DIVISION . . THEODORE B. CLIPPINGER, I NO. 96-5450 CIVIL TERM Defendant : PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Trans_it the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divoree: irretrievable breakdown under S330l(c) :l1Qc.WlOl~of the Divorce Code. (Strike out inapplicable section). 2. Date and _nner of service of the cOlllplaint: Acceptance of Service dated and CIIed October 11, 1996 by Edward W. Harker, Esquire. 3. Co.plete ei~her paraqraph (a) or (b). (a) Date of execution of the affidavit of consent required by SHOl(c) of the Divorce Code: by plaintiff Julv .1997 : by defendant .Iuly . 1997 ICDQl(U;nw'tiio'CUY~IaaC)6l[XtaliKU%Y"'''.JUX~H~IDIDCD(U >>X~~~.~~YXXXXXXXXXXXXXXXXXXXX~X"&K~~~~XXXX IKl6laJl~XJlK~~lllltiiMJ:K)U(UXIIliICJtiU(...-uJCXXXXXXXXXXXX 4. Related elabas pending: None. 5. eo.plete either (a) or (b). (al Date and _nner of service of the notice of 1ntention to fUe pracc1pe to tran..it record. a copy of which i. attachedl (bl Date plaintiff'. filed with the Prothonctary: Dete defendant'. rUed with the Prothonotary: Waiver of Notice in S3301(e) Divorce w.. A~t U. 1..1 Waiver of Notice in Sl101(cl Divorce wa. A_t U.1197 /lA. -.[.'.. ? ,,:L: A~Y for (Plalntlf(I~~ Stepht!fl D. TiI~y. Esquire NICOLE K. CLIPPINGER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- .s'Y..ro THEODORE B. CLIPPINGER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE, AND WAIVER OF MARRIAGE COUNSELING 1. A Complaint in divorce under Section 330 l(c) of the Divorce Code was filed on October 3.1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of ming and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce without notice. 4. I understand that I may lose rights concerning alimony. division of propeny. 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 Coun and that a copy of the decree will be sent to me immediately after it is ftIed with the prothonotary. 6. I have been advised of the availability of marriage counseling and understand that I may request that the coon require that my spouse and I participate in counseling. 7. I understand that the coun maintains a list of marriage counselors in the Domestic Relations OffICe. which list is available to me upon request. 8. Being so advised. I do not request that the coon require my spouse and I panicipate in counseling prior to a divorce decree being handed down by the coon. I verify that the statements made in this affidavit arc true and COnttt. I understand that false statements herein arc made subject to the penalties of 18 Pa.. C. S. 14904 relating to unsworn falsifICation to authorities. w.TE: tI-r..t 1::/,17?? \\.a.P~ '~Q~~A' ~ger ""' (f) ,. r~ f;~' ,. \..,.,. , , C , '- - ,- &.. .. r- .. . \"..1 a- .oj .. ,* . f' *.c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- sf'.5"'"() NICOLE K. CLIPPINGER, Plaintiff v. THEODORE B. CLIPPINGER, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE. AND WAIVER OF MARRIAGE COUNSELING \. A""""".... di'''''' ""'" """" 330U') ol "" Dom<< Cod< ... "'''''''' ~ 3. 1996. 2. Tb< _..,.f PI...... "'" ",r~ ;, .",,,,,,"'1, bro'" "'" "''''11 do" .... elapsed flOm the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 1 _""".... 1 ..., ""' ri.... """'..... 01'-" dI"'''' ol """"" ...,,,. fees. or expenses if I do not claim them before a divorce is granted. ,. ,.."',..... ....' .UI..... ..._ ....,. di'''''' ""'" .".."'" by ... Com' ......... """ ol" ""'" ,.;0" .... .... _I, "" ,. ;, r....'" .. ,...-.... 6. 1 .... """.."'" ol" ........'" ol _""""I'" .... """""""'....1 ..., request that the court require that my spouse and I participate in counseling. " ,_............ "..rt .......... . II. .f ......... ....".... .. .. """"'" RelationS offtce. which list is available to me upon request. .. ....... ......., 1 do.... "'l"'" ...... _ ........., .- ... '......... in counseling prior to a divorce decree being handed doW1\ by the court. , ",if'.... 1M ...-'" - .. thI. .....',. "' .... ... """" . \. """"""'" ... f""'''''-'''''''''''- _.............r" P.. c. S. .....,,-.....- falsifICation to authoritie$. MtE: ~ I~ 1997 ~ tfJ . '-=' -' ;J , , 'T . ~. '. (" " .. , .' ~. , r-.. t:, " 0 . ...... . .. - .-"'tt .. .. . NICOLE K. CLIPPINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . Vs. . CIVIL ACTION - LAW . . . THEOOORE B. CLIPPINGER, . NO. 96-5450 CIVIL TERM . Defendant : . IN DIVORCE . ACCBPTANCB OF SBRVICB I, Edward W. Harker, Esquire, attorney for the Defendant aceept service of the Oivorce Complaint on behalf of Theodore B. Clippinger and certify that I to Datel OCtober 11, 1996 7 E r W. Har er, Esqu1re A orney for the Defendant o e West High Street Carlisle, PA 17013 (117)243-1083 PA Supreme Court rD 06362 NICOLE K. CLIPPINGER, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA . . Vs. : CIVIL ACTION - LAW . . THEODORE B. CLIPPINGER, Defendant I NO. 96-5450 CIVIL TERM IN DIVORCE PRAECIPE Please enter my appearance on behalf of Theodore B. Clippinger the aforesaid Defendant. Datel October 11, 1996 ker, Esqu1re y for the Defendant st High Street Carli Ie, PA 17013 (717)243-1083 PA Supreme Court ID 06362