HomeMy WebLinkAbout02-5102IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY HOWARD BISHOP
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
CIVIL ACTION - LAW IN DIVORCE
NOTICE TO DEFEND AND CLAIM 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 1N 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 COURTHOUSE, 1 COURTHOUSE
SQUARE, CARLISLE, PA 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 LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
JEFFREY HOWARDS BISHOP,
Plaintiff,
CYNTHIA ANN BISHOP,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOCKET NO. 02-5102
IN CUSTODY
PETITION TO MODIFY CUSTODY
AND NOW, this 16th day of July, 2004, comes the Petitioner/Plaintiff Jeffrey Howard
Bishop, by and through his attorney, Andrew C. Spears, Esquire:, and the law firm of Metzger,
Wickersham, Knauss & Erb, P.C., and files the within Petition of which the following is a
statement:
1.
Petitioner is Plaintiff Jeffrey Howard Bishop (hereinafter "Father"), natural father
of the Minor Child, Alex Jacob Bishop, dob: 3/3/1999 (hereinafter "the Minor Child"), who
currently resides at 813 Upland Street, Mechanicsburg, Cumberland County, Pennsylvania,
17055.
2. Respondent is Defendant Cynthia Ann Bishop (hereinafter "Mother"), natural
mother of the Minor Child, who currently resides at 3915 Rosernont Avenue, Camp Hill,
Cumberland County, Pennsylvania, 17011.
3. On or about January 14, 2003, a Stipulated Custody Order was entered by this
Honorable Court following agreement reached at a Custody Conciliation.
308421-1
4. The Custody Order dated January 14, 2003 is attached as Exhibit A and
incorporated herein by reference and provides, inter alia, that the custody of the Minor Child
shall be exercised between the parties as follows:
a. The parties shall share legal custody of the Minor Child;
b. Mother shall have primary physical custody of the Minor Child; and
c. Commencing on January 17, 2003, Father shall have periods of partial
custody on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m.,
as well as every Tuesday and Thursday evening from 5:30 until 8:30 p.m.
5. Since the entry of the January 14, 2003 Order Mother has continually refused to
allow Father to have his Court-ordered visitation, commencing on Friday evenings at 6:00 p.m.
through Sunday at 6:00 p.m. Instead, she has been forcing Father to exercise visitation only
during the day on Saturday and during the day on Sunday on his alternating weekends. The
Tuesday and Thursday evening visitation has gone on as ordered.
6. Further, Father is now concerned about Mother's attempts to alienate the Minor
Child from Father and Father's family.
7. In addition, Father would like a more detailed custody schedule, as well as a more
detailed holiday schedule since the parties have been unable to work out shared time by
agreement.
8. Father feels that it is in the best interest of the Minor Child if this Honorable
Court will modify the aforementioned Custody Order confirming shared legal custody of the
Minor Child to both parents and granting Father's request for modification of the physical
custody arrangement.
308421q
WHEREFORE, Petitioner/Plaintiff Jeffrey Howard Bishop respectfully requests that this
Honorable Court grant the modification to the Custody Order as set forth above.
METZGER, WlCKERSHAM, KNAUSS & ERB, P.C.
Andrew C. Spears, Esquire
Attorney I.D. No. 87737
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff/Petitioner
308421-1
VERIFICATION
I, Jeffrey Howard Bishop, do hereby verify that the facts set forth in the foregoing
Petition to Modify Custody Order are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities.
CERTIFICATE OF SERVICE
I, Andrew C. Spears, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of the Petition to Modify Custody Order
with reference to the foregoing action by first class mail, postage prepaid, this I~ day of
July, 2004, on the following:
Joanne Harrison Clough
Reager & Adler, P.C.
2331 Market Street
Camp Hill, PA 17011
Andrew C. Spears
CD
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY HOWARD BISHOP
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
NO.
CIVIL ACTION - LAW IN DIVORCE
AVISO PARA DEFENDER Y RECLAMAR DERECIIOS
USTED HA SIDO DENIANDADO EN LA CORTE. Si desea defenderse de las que. ias expuestas en las
paginas signientes. Debe tomar accion con prontitud. Se Ie avisa que Si nose defiende, el caso puede proceder sin usted
y decreto de divorcio o anniamiento paede ser emitido en su contra por la Corte. Una decision puede tambien ser
emitida en su contra por cuaiquier otra queja o compensacion reclamados por el demandante. Usted puede perder
dinero, o propicdades u otros derechos importantes para usted.
· Cuando la base para el divorcio es indignidades 0 rompimiento in'parable del matrimonio, usted puede solicitar
consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la
CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013.
SI USTED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL, HONORARIOS DE
ABOGADO U OTROS GASTOS ANTES DE QLE EL DECRETO FINAL DE DIVORCJO O ANULAMIENTO
SEA EMITIDO. USTED PUEDE PERDER EL DERCHO A RECLAMAR CUALQUERA DL ELLOS.
USTED DEBE LUEVAR ESTE PAPEL A LN ABOGADO DL INMEDIATO. SI NO TIENE O NO PL£DE
PAGAR UN ABOGADO. VAYA O LLAME A LA OFICINA 1NDICADA ABAJO PARA AVERIGUAR DONDE
PUEDE OBTENER ASISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY HOWARD BISHOP
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
NO. (C)A - _5~/Q ~.~
CIVIL ACTION - LAW IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
or 3301(d) OF THE DIVORCE CODE
COUNT !
AND NOW, comes Jeffrey Howard Bishop, by and through her attorney Christine J. Taylor, Esquire
of Wiley, Lenox, Colgan & Marzzacco, P.C., and files the instant Complaint in Divorce and in support
thereof, avers as follows:
1. The Plaintiff is Jeffrey Howard Bishop, who currently resides at 1139 Ranaville Avenue,
Cumberland County, Pennsylvania, since August, 2001.
2. The Defendant is Cynthia Ann Bishop, who currently resides at 3915 Rosemont Avenue, Camp
Hill, Cumberland County, Pennsylvania, 17011 since 1999.
3. There is one minor child of the parties: Alex Jacob Bishop, bom March 3, 1999.
4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
5. The Plaintiff and Defendant were married April 25, 1998 in Camp Hill, Pennsylvania.
6. There have been no prior actions of divorce or annulment between the parties.
7. Neither party is presently a member of the Armed Forces on active duty.
8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and
property division.
9. 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. Being so advised, Plaintiff does not
request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued
by the Court.
10. The cause of action and sections of Divorce Code under which Plaintiff is proceeding are:
(a) §3301(a)(6). Defendant has offered such indignities to Plaintiff, the innocent and
injured spouse, as to render his condition intolerable and life burdensome.
(b) § 3301 (c). The marriage of the parties is irretrievably broken.
11. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the Court enter an Order dissolving the marriage between
Plaintiff and Defendant
COUNT II
REOUEST FOR EOUITABLE DISTRIBUTION OF MARITAI~
PROPERTY UNDER §3502(a} OF THE DIVORCE CODE
12. Paragraphs 1 through 11 are incorporated herein by reference as though set forth in full
13. Plaintiff and Defendant have individually or jointly acquired property, both real and personal,
during the marriage, in which they individually or jointly have legal or equitable interest, which marital
property is subject to equitable distribution.
WHEREFORE, Plaintiff requests the Court to determine and equitably distribute, divide or
assign said marital property, pursuant to §3502(a) of the Divorce Code.
COUNT III -- CUSTODY
14. Paragraphs 1 through 13 incorporated herein by reference as though set forth in full.
15. Plaintiff is Jeffrey Howard Bishop, residing at 1139 Ranaville Avenue, Camp Hill,
Pennsylvania since August, 2001.
16. Defendant is Cynthia Ann Bishop, residing at 3915 Rosemont Avenue, Camp Hill,
Pennsylvania, 17011 since 1999.
17. Plaintiff seeks custody cf the following child: Alex Jacob Bishop, date of birth, March 3,
1999. The child was bom during the marriage.
18. The child is presently in the custody of Defendant, Cynthia Ann Bishop, who resides at 3915
Rosemont Avenue, Camp Hill, Cumberland County, Pennsylvania 17011.
19. Since the minor child's birth, the child has resided at the following locations and with the
following persons:
A. 3915 Rosemont Avenue, Camp Hill, Cumberland County, Pennsylvania with Plaintiff
and Defendant from birth until August, 2001.
B. 3915 Rosemont Avenue, Camp Hill, Cumberland County, Pennsylvania with
Defendant from August, 2001 until present.
20. The relationship of Plaintiff to the child is father.
21. The relationship of Defendant to the child is mother.
22. Plaintiff has not participated as a party or witness or in any other capacity in other litigation
concerning the custody of the child in this or another court.
23. Plaintiff has no information of a custody proceeding concerning the child pending in a court
of this Commonwealth.
24. Plaintiff does not know of a person not a party to the proceedings who has physical custody
of the child or claims to have custody or visitation rights with respect to the child.
Dated:
25. The best interests and permanent welfare of the child will be served by granting the relief
requested.
26. Each parent whose parental rights of the child have not been terminated and the person who
has physical custody of the child has been named as party to this action.
WHEREFORE, the Plaintiff requests this Honorable Court to grant custody of the minor child.
Respectfully submitted,
WILEY, LENOX, COLGAN & MARZZACCO, P.C.
C[~i~istine J. Taylor, ,~E~q~'r/e~/~'
1 South Baltimore Street C~'
Dillsburg, PA 17019
(717) 432-9666
I.D. # 82204
VERIFICATION
I, Jeffrey Howard Bishop, verify that the statements made in this document are true and correct to
the best of my knowledge, information, and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. {}4904, relating to unsworn falsification to authorities.
BISHOP
JEF~FIr3~D
Plaintiff
JEFFREY HOWARD BISHOP
PLAINTIFF
CYNTHIA ANN BISHOP
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
: 02-5102 CIVIL ACTION LAW
:
1N CUSTODY
_,
ORDER OF COURT
AND NOW, Wednesday, October 23, 2002 _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West 1Maln Street, Mechanicsbur$, PA 17055 on Tuesday, November 12, 2002 at 10:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Is/
Dawn S. Sunday. Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY HOWARD BISHOP
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
NO. 02-5102
CIVIL ACTION - LAW IN DIVORCE
AFFIDAVIT OF SERVICE
I, Sherry A. Fitzkee, being duly sworn, deposes and says that she is an adult and that she served the
within Complaint on the Defendant, at the Defendant's last known address as follows: 3915 Rosemont
Avenue, Camp Hill, PA 17011 by certified mail, restricted delivery, return receipt requested on the 2nd day
of November, 2002. The Certified Mail Receipt and PS Form 38111 are attached hereto, marked Exhibit "A"
and made a part hereof by reference thereto.
Date: November 13, 2002
COMMONWEALTH OF PENNSYLVANIA:
: SS
COUNTY OF YORK :
WILEY, LENOX, COLGAN
& MARZZACCQ? P.C.~/'~?
"--;~r~ ~f'itzkee ~J
On this, the 13th day of November, 2002, before me, a notary public, personally appeared Sherry A.
Fitzkee known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and
acknowledged that she executed the same for the purposes therein corttained.
WITNESS, my hand and notarial seal the day and year aforesaid.
Notarial Seal
S. Dawn Gladfelter, Notary Public
Dillsbu~ Bom, York County
My Commissmn Expires May 17, 2005
Member, PennsylvaniaAsaocialton ot Notafles
'~'I~TA'~'-Y PUBLIC /~"-- .... '"-'
My Commission Expires: v
· Complete items 1,2, and 3. Aisc complete
item 4, if. Restr. jcted 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.
1. Article Addressed to: -
2. Artic 7001 2510 0008 0707 6554
(Trer
A. Signature
X /~ ; ,~ [ ~, [] Agent
B. Recked by ( PriMed Name) I C. Date of Delivery
D. Is delivery a~ress different f~m item 17 []
f YES, enter ¢ e ivery address below: [~'~o
3. Service Type
%~"-eertified Mai}
L.J Registered
[] Insured Mail
[] Express Mail
[] Return Receipt for Merchandise
[] C.O.D.
4. Restricted Del;vew? (Extra Fee)
PS Form 3811, August 2001
Domestic Retum Receipt
102595-02-M-1035
nj
EXHIBIT "A"
JEFFREY HOWARD BISHOP,
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-5102 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this [ ~/2~ day of ,VZ-~ ~ ") , 2003,
upon consideration of the attached Custody Conciliation RepOrt, it is ordered and directed as follows:
1. The Father, Jeffrey Howard Bishop, and the Mother, Cynthia Ann Bishop, shall have
shared legal custody of Alex Jacob Bishop, bom March 3, 1999. Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding his health, education
and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
2. The Mother shall have primary physical custody of the Child.
3. After a period of transition for the Child, the Father shall have partial physical custody on
alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. and every Tuesday and
Thursday evening from 5:30 p.m. until 8:30 p.m.
4. The parties agree to cooperate in gradually increasing the Father's periods of weekend partial
custody to ensure a healthy adjustment for the Child. To that end, the parties agree that the Father's
first period of custody shall take place on Thursday, January 9, 2003, when the Father shall spend
some time with the Child at the Mother's residence, take the Child to McDonald's to eat and play and
introduce the Child to the Father's new residence for a short period of time. Thereafter, the Father's
regular weekday evening periods of custody beginning on Tuesday, January 14, 2003 shall be
unrestricted. The parties agree that during the Father's first weekend period of custody (January 17
through 19, 2003), the Father shall have custody of the Child on Saturday from 10:00 a.m. until 5:00
p.m. and on Sunday from 10:00 a.m. until 5:00 p.m. Thereafter, the parties shall cooperate in
gradually increasing the Father's custodial time on weekends to reach the goal of an alternating
weekend period as provided in paragraph 3 of this Order.
5. In the event the Father has to work during his regular weekend period of custody, the
Mother shall have custody of the Child during the time when the Father is unavailable.
6. The parties shall share having custody of the Child on holidays as arranged by agreement.
7. Each party shall be entitled to have extended periods of custody with the Child during the
summer as an'anged by agreement.
8. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
CCi
Bradley A. Winnick, Esquire - Counsel for Father
Joanne H. Clough, Esquire - Counsel for Mother
JEFFREY HOWARD BISHOP, :
Plaintiff :
vs. : 02-5102
:
CYNTHIA ANN BISHOP, :
Defendant : IN CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
Alex Jacob Bishop
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
March 3, 1999 Mother
2. A Conciliation Conference was held on January 7, 2003, with the following individuals in
attendance: The Father, Jeffrey Howard Bishop, with his counsel, Bradley A. Winnick, Esquire, and
the Mother, Cynthia Ann Bishop, with her counsel, Joanne H. Clough, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
Dawn S. Sunday, Esquire !
Custody Conciliator
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY HOWARD BISHOP
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
NO. 02-5102
CIVIL ACTION - LAW
IN DIVORCE
2002.
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on October
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce aRer 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification to authorities.
Date
Jeffrey ~.~Bishop
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY HOWARD BISHOP
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
NO. 02-5102
CIVIL ACTION - LAW
IN DIVORCE
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 ora 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification
to authorities.
Date
Jeffrey~w.~ Bishop
Plaintiff
JEFFREY HOWARD BISHOP,
Plaintiff
VS.
CYNTHIA ANN BISHOP,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
No. 02-5102 Civil
CIVIL ACTION ~ LAW IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on October 21,
2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to
unswom falsification to authorities.
Date
JEFFREq~ O~A~,D'~ ~p
Plaintiff
JEFFREY HOWARD BISHOP,
Plaintiff
CYNTHIA ANN BISHOP,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
No. 02-5102 Civil
CIVIL ACTION - LAW IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUES£
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry ora final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses ifI 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 made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn
falsification to authorities.
Date
Plaintiff
JEFFREY HOWARD BISHOP,
Plaintiff
CYNTHIA ANN BISHOP,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: 02-5102
:
: CIVIL ACTION - LAW
: IN CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301.(c) of the Divorce Code was
filed on October 21, 2002.
2. The marriage of Plaintiff and Defendant is i~Tetrievably broken, and ninety
(90) days have elapsed from the date of the filing and service of 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. Section 4904
relating to unsworn falsification to authorities.
CYNTHIA ANN BI~HOP~
JEFFREY HOWARD BISHOP,
Plaintiff
CYNTHIA ANN BISHOP,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-5102
CIVIL ACTION - LAW
IN CUSTODY
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(C) OF TIlE 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 afler it is filed with the Prothonotary.
I verify that the statements made in this affidavit m:e true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
JEFFREY HOWARD BISHOP,
Plaintiff
CYNTHIA ANN BISHOP,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: 02-5102
:
: CIVIL ACTION - LAW
: 1N CUSTODY
AFFIDAVIT OF CONSENT_
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on October 21, 2002.
2. The marriage of Plaintiff and Defendant is inretrievably broken, and ninety
(90) days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of diw~rce 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. Section 4904
relating to unsworn falsification to authorities.
JEFFREY htl~I) BISH~OP ' 4' {o- C~
JEFFREY HOWARD BISHOP,
Plaintiff
CYNTHIA ANN BISHOP,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-5102
CIVIL ACTION - LAW
IN CUSTODY
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 ora final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
>r 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. ~. S § 4904 relating to unsworn falsification
to authorities.
Dated:
JEFF1LEYkl~W~ RD BISHOP' 4"/°-Oq
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this
day offS, 2003, by and between Cynthia
Ann Bishop (hereinafter "WIFE") and Jeffery Howard Bishop, (hereinafter "HUSBAND");
WI TN E S S E T H:
WHEREAS, the parties hereto were married on April 25, 1998, in Camp Hill,
Cumberland County; and separated on or about September of 2001; and
WHEREAS, the parties have one child of this marriage, namely Alex Jacob Bishop born
March 3, 1999; and
WHEREAS, difficulties have arisen between the parties and it is therefore their
intention to live separate and apart for the rest of their lives and the parties are desirous of
settling completely the economic and other rights and obligations between each other,
including, but not limited to: the equitable distribution of the marital property; past, present
and future support; alimony, ahmony pendente lite; and, in general, any and all other claims
and possible claims by one against the other or against their respective estates; and
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
kept and performed by each party and intending to be legally bound hereby, the parties do
hereby agree as follows:
1. ADVICE OF COUNSEL.
The provisions of this Agreement and their legal effect have been fully explained to the
parties by their respective counsel. WIFE is represented by Jolnane Harrison Clough,, Esquire
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of REAGER & ADLER, PC. HUSBAND is represented by Bradley A. Wirmick, Esquire, of The
Wiley Group.
The parties further declare that each is executing the Agreement freely and voluntarily
having either obtained sufficient knowledge and disclosure of their respective legal rights and
obligations, or if counsel has not been consulted, expressly waiving the right to obtain such
knowledge. The parties each acknowledge that this Agreement is fair and equitable and is not
the result of any fraud, coercion, duress, undue influence or' collusion.
2. DIVORCE ACTION.
The parties acknowledge that their marriage is irretrievably broken and that they shall
secure a mutual consent no fault divorce pttrsuant to § 3301(c) of the Divorce Code. A divorce
action was filed by Husband with the Court of Common Pleas of Cumberland County,
Pennsylvania at Civil Action No. 02-5102 on October 21, 2002. The parties agree to execute
Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a
Divorce Decree concurrently with the execution of this Agreement.
This Agreement shah remain fir full force and effect after such time as a final decree in
divorce may be entered with respect to the parties. The parties agree that the terms of this
Agreement shall be incorporated into any Divorce Decree which may be entered with respect
to them and specifically referenced in the Divorce Decree. This Agreement shall not merge
with the divorce decree, but shall continue to have independent contractual sigmficance.
3. DATE OF EXECUTION.
The "date of execution" and "execution date" of this Al~eement shall be defined as the
date upon which it is executed by the parties if they have each executed the Agreement on the
same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be
defined as the date of execution by the party last executing this Agreement.
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4. MUTUAL RELEASES.
Each party absolutely and unconditionally release the other and the estate of the other
from any and all rights and obligations which either may have for past, present, or future
obligations, arising out of the marital relationship or otherwise, including all rights and
benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described
herein.
Each party absolutely and unconditionally releases the other and his or her heirs,
executors, and estate from any claims arising by virtue of the tnarital relationship of the par t~es.
The above release shall be effective whether such claims arise by way of widow's or widower's
rights, family exemption, or under the intestate laws, or the right to take against the spouse's
will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights
of a surviving spouse to participate in a deceased spouse's estate, whether arising under t-he
laws of Pennsylvania, any state, Commonwealth, or territory of the United States, or any other
country.
Except for any cause of action for divorce which either iparty may have or claim to have,
each party gives to the other by the execution of this Agreement an absolute and unconditional
release from all claims whatsoever, in law or in equity which either party now has against the
other.
5. FINANCIAL AND PROCEDURAL DISCLOSURE.
The parties confirm that each has relied on the accuracy of the financial disclosure of
the other as an inducement to the execution of this Agreement. Each party understands tlqat
he/she had the right to obtain from the other party a complete, inventory or list of all property
that either or both parties owned at the time of separation or currently and that each party lqad
the right to have all such property valued by means of appraisals or otherwise. Both parties
understand that they have right to have a court hold hearings and make decisions on the
matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is
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fair and equitable, and that the terms adequately provide for his or her interests, and that this
Agreement is not a result of fraud, duress or undue influenc, e exercised by either party upon
the other or by any person or persons upon either party.
6. SEPARATION/NON-INTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart.
They shall be free from any interference, direct or indirect, by the other in all respects as fully
as ff they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on
and engage in any business, occupation, profession or employment which to him or her may
seem advisable. WIFE and HUSBAND shall not harass, disl~rb, or malign each other or the
respective families of each other.
7. REAL PROPERTY.
The parties are the joint owners of real property located at 3915 Rosemont Avenue,
Camp Hill, Cumberland County, PA. In consideration of the other promises and property
transfers set forth in this Agreement, HUSBAND agrees to trarbsfer any and all right, title, claim
and interest in the residence to WIFE. WIFE agrees to apply for a loan to attempt to refiance
the mortgage with Countywide removing HUSBAND as an obligor if WIFE is approved for
refinancing. WIFE agrees to assume sole responsibility for and to indemnify and hold
HUSBAND harmless as an obligor on the home equity loan with American General Finance.
WIFE agrees to indemnify and hold HUSBAND harmless on the first mortgage with County
Wide in the event she is not able to refinance said obligation in to her name. In the event IWFE
is not able to refinance the 1st mortgage emd home equity lomas in to her sole name, then she
shall continue to indemnify HUSBAND and hold him harmless thereon and WIFE shall be
solely responsible for the timely payment of said obligations.
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8. DEBTS.
Except as otherwise set forth in this Agreement if a party has acquired debt, the part/es
agree that each shall assume full and complete responsibility for his or her own debts.
HUSBAND represents and warrants to WIFE that since the separation he has not, and
in the future he will not, contract or incur any debt or liability for which WIFE or her estate
might be responsible, and he shall indemnify and save WIFE harmless from any and all claims
or demands made against her by reason of such debts or obligations incurred by him since the
date of said separation, except as otherwise set forth herein.
WIFE represents and warrants to HUSBAND that since the separation she has not, and
in the future she will not, contract or incur any debt or liability for which HUSBAND or bis
estate might be responsible, and he shall indemnify and saw~ HUSBAND harmless from any
and all claims or demands made against him by reason of such debts or obligations incurred
by her since the date of said separation, except as otherwise set forth herein.
9. RETIREMENT BENEFITS.
HUSBAND hereby waives his right, title and interest to any pension and/or retirement
and any and all other retirement benefits otherwise of WIFE. WIFE hereby waives her right,
title and interest to any pension and/or retirement and any and all other retirement benefits
otherwise disclosed of HUSBAND.
The parties specifically waive any and all other retirement benefits obtained by the
parties pre-marriage, during marriage, and post-separation. The individual who holds said
benefits shall own the property solely and individually. Each party waives their right to title
and interest to the other party's benefit.
10. BANK ACCOUNTS.
The parties acknowledge that they have divided the marital bank accounts to their
satisfaction. The bank accounts held solely in individual names shall become the sole and
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separate property of the party in whose name it is registered. Each party does hereby
specifically waive and release his/her right, tire and interest in the other party's respective
accounts.
A. PIONEER FUND: HUSBAND agrees to waive any right, rifle, claim and
interest to WIFE's Pioneer Fund which was funded with :monies WIFE's parents gifted to
WIFE.
11. PERSONAL PROPERTY.
Except as set forth here below, the parties hereto mutually agree that they have divided
all furniture, household furnishings and personal property between them in a manner
agreeable to both parties. The parties mutually agree that each party shall from and after the
date of this Agreement be the sole and separate owner of all tangible personal property in his
or her possession.
12. CHILD SUPPORT.
HUSBAND and WIFE specifically agree that HUSBAND shall tender to WIFE the sum
of TWO HUNDRED DOLLARS ($200.00) bi weekly for support of the parties' minor child.
This support obligation can be modified by agreement of the parties or by Court Order.
13. VEHICLES.
WIFE shall receive as her sole and separate properl.y the 1995 Oldsmobile Cutlass.
HUSBAND shall retain as his sole and separate property the 1985 VW Golf and the 1999
Toyota pickup truck.
14. BANKRUPTCY OR REORGANIZATION PROCEEDINGS.
In the event that either party becomes a debtor in any bankruptcy or financial
reorganizarion proceedings of any kind while any obligations remain to be performed by that
party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor
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spouse hereby waives, releases and relinquishes any right to claim any exemption (whether
granted under State or Federal law) to any property remaining in the debtor as a defense to any
claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney
fees and costs incurred in the enforcement of this paragraph or any other provision of this
Agreement. No obligation created by this Agreement shall be discharged or dischargeable,
regardless of Federal or State law to the contrary, and each party waives any and all right to
assert that obligation hereunder is discharged or dischargeable.
The parties mutually agree that in the event of bankruptcy or financial reorganization
proceedings by either party in the future, any monies to be paid to the other party, or to a third
party, pursuant to the terms of this Agreement shall constitute support and maintenance and
shall not be discharged in bankruptcy.
15. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE.
The parties hereby expressly waive, release, discharge and give up any and all rights
or claims which either may now or hereafter have for spousal support, alimony pendente lite,
alimony, or maintenance. The parties further release any rights that they may have to seek
modification of the terms of this Agreement in a court of law or equity, with the understanding
that this Agreement constitutes a final determination for all hme of either party's obligations
to contribute to the support or maintenance of the other.
16. ATTORNEY FEES, COURT COSTS.
Each party hereby agrees to be solely responsible for his or her own counsel fees, costs
and expenses. Neither shall seek any contribution thereto from the other except as otherwise
expressly provided herein.
17. ATTORNEYS' FEES FOR ENFORCEMENT.
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In the event that either party breaches any provision of this Agreement and the other
party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all
reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if
applicable) which are incurred by the other party in enforcing the Agreement, whether
enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific
Agreement and intent of the parties that a breaching or wrongdoing party shall bear the
obligation of any and all costs, expenses and reasonable counsel fees incurred by the
nonbreaching party in protecting and enforcing his or her rights under this Agreement.
18. WAIVER OF RIGHTS.
Both parties hereby waive the following procedural rights:
(a.) The right to obtain an inventory and th{: appraisement of all marital and
non-marital property;
(b.) The right to obtain an income and exp~mse statement of either party;
(c.) The right to have all property identified and appraised;
(d.) The right to discovery as provided by the Pennsylvania Rules of Civil
Procedure; and
(e.) The right to have the court make all determinations regarding marital
and non-marital property, equitable distribution, spousal support,
alimony pendente lite, alimony, counsel fees and costs and expenses.
19. MUTUAL COOPERATION.
WIFE and HUSBAND shall mutually cooperate with each other in order to carry
through the terms of this Agreement, including but not limited to, the signing of documents.
20. VOID CLAUSES.
If any term, condition, clause or provision of this Agreement shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition, clause or
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provision shall be stricken from this Agreement, and in all other respects this Agreement shall
be valid and continue in full force, effect and operation.
21. APPLICABLE LAW.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
22. ENTIRE AGREEMENT.
This Agreement contains the entire understanding of the parties, and there are no
representations, warranties, covenants or undertakings other than those expressly set forth
herein.
23. CONTRACT INTERPRETATION.
For purposes of contract interpretation and for the purpose in resolving any ambiguity
herein, the parties agree that this Agreement was prepared jointly by the parties.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day
first above written.
This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND
acknowledge the receipt of a duly executed copy hereof.
Cynthia A. Bishop
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Wime leff~y ~'~Sp
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~3Cbd_/k~(l~ SS.
On the ~-~ day of. ~~t-6/k _, 2003, before me, a Notary
Public in and for the Commonwealth of Pennsylvania, the undesigned officer, personally
appeared CYNTHIA A. BISHOP, known to me (or satisfactory proven) to be one of the parties
executing the foregoing instrument, and she acknowledges the foregoing insttument to be her
free act and deed.
IN WITNESS WHEREOF, I have hereunto set my band and notarial seal the day and
year first above written.
~ Camp Hill 8oro Cumberland County .
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF ~ ' :SS.
On theday of , before me, a Notary
Public in and for the Commonwealth of Pennsylvania, the tmdesigned officer, personally
appeared JEFFERY H. BISHOP, known to me (or satisfactory proven) to be on of the parties
executing the foregoing instrument, and he acknowledges thi: foregoing instrument to be his
free act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
My Commission Expires:
LMMy ~~ Notaria~l Seal
S. Dawn Gladfeller, Notary Public
D/llsburg Boro, York C~u
/
Corrlrnis.s,!on Expires May ~7/~, 2005[
Member, PennsFIvanla Association ot Nota~e~
Page 11 of 11
ADDENDUM TO MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this ~ day of November, 2003, by and between Cynthia
Ann Bishop (ber¢inaf~er "WIFE") and J¢t~ey Howard Bishop (hereinafter "HUSBAND");
WITNESSETH:
WHEREAS, the parties hereto are, contemporaneously with the execution of This
Addendum, entering into a Marital Settlemem Agreement intended to fully and finally settle all
economic and other rights between them as HUSBAND and WIFE; and
WHEREAS, the parties have consulted with their respective counsel, Joanne Harrison
Clough, Esquire, counsel for WIFE, and Bradley A. Winuick, Esquire, counsel for HUSBAND,
and acknowledge their full understanding of the provisions ofl~>th the Martial Settlement
Agreement and This Addendum thereto; and
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
kept and performed by each party, including those contained in the Marital Settlemem Agreemem,
and intending to be legally bound thereby, the parties do hereby agree as follows:
1. PERSONAL PROPERTY:
It is agreed by the parties that, within thirty (30) days of' the date of execution of the
Marital Settlement Agreement, HUSBAND shall receive the following items of personal property
fi.om the former marital residence, which items shall remain his sole and exclusive property and to
which WIFE hereby waives any claim or interest therein:
a) Dresser in basemem which belonged to HUSI:IAND's grandmother;
b) Lawn equipment in the shed, including the lawn mower and weed eater;
c) Two (2) storage sheds purchased by HUSBANI)'s parents;
d) Two (2) of four (4) rocking chairs;
e) HUSBAND's clothes;
f) HUSBAND's wedding ring;
g) Compact discs and accompanying case;
h) Tool box; and
i) Barbecue grill.
Except as provided herein, the parties hereto mutually agree that they have divided all
furniture, household furnishings and personal property between them in a manner agreeable to
both parties. The parties mutually agree that each party shall fi.om and after the date of This
Agreement be the sole and separate owner of all tangible personal property in his or her
possession.
2. HOME EQUITY LOAN:
It is agreed that WIFE shall immediately make any and all payments necessary to bring the
Home Equity Loan with American General Finance current. In consideration thereof;
HUSBAND shall pay the amount of $208.28 directly to WIFE on or before December 15, 2003.
All other terms and conditions of the Marital Settlement Agreement relating to the home equity
loan or the marital residence shall remain in full force and effect.
3. INCORPORATION OF MARITAL SETTLEMENT AGREEMENT:
The parties agree that This Addendum is part and parcel of the Marital Settlement
Agreement between the parties, and that all provisions of said Marital Settlement Agreement shall
remain binding upon the parties.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day
Cynl'llfa Ax. Bishop
Jeflfi'ey ~ ~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~,4q4~d~,tC~
Onthis, q~'- dayof.~L~_22didff-J.4_
:SS
,2003, beibre me, a Notary Public,
personally appeared Cynthia A. Bishop, known to me to be the person whose name is subscribed
to the within Marriage Settlement Agreement and acknowledged that she executed the same for
the purposes therein comained.
~ ~SS ~OF, I hereunto set my ~d and offic~ se~.
CASSANDRA T. ROSENBAUM, Notary ~ot~ Public
Camp Hill Bm, Cum~danO ~un~ 1
My Commission Expires December 4, 2004_ ]
COMMONWEALTH OF PENNSYLVANIA :
'SS
. -
On this, t~e /~ay of AJ/)X~/3~ ~le~, 2003, before me, a Notary Public, personally
appeared Jeffrey H. Bishop, known to me to be the person wl~tose name is subscribed to the
within Marriage Settlement Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN ~SS ~OF, I hereunto set my ~d ad offic~ se~.
Not~ Pubic // --
Notadal Seal
S. Dawn Gladfelter, Notary Pubiic
Dillsburg Boro, York County
My Commission Expires May 17, 2005
Member, Pennsylvama Association of Notaries
JEFFREY HOWARD BISHOP,
Plaintiff
CYNTHIA ANN BISHOP,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-5102
CIVIL ACTION - LAW
IN CUSTODY
PRAECIPE TO TRANSMIT P~;CORD
TO THE PROTHONOTARY:
Transmit the record, together with the following infommtion, to the Court for entry of a
divorce decree:
1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Service was accepted by the
Defendant on the 2~a day of November, 2002, by certified n~l, return receipt requested, receipt
number 7001 2510 0008 0707 6554. Affidavit of Service was fried with the Court November 19,
2002.
3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce
Code: by Jeffrey Howard Bishop, Plaintiff, on April 6, 2004; by Cynthia Ann Bishop, Defendant,
on March 8, 2004.
4. Related claims pending: Settled by Marital Settlement Agreement dated
November 13, 2003.
Prothonotary:
Prothonotary:
Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the
April 8, 2004
Date Defendant's Waiver of Notice in § 3301(c) Divorce was fried with the
April 1, 2004
DATED:
Respectfully subrrfitted,
REAGER_ & ADLiER, PC
I.D. No. 36461 [~
2331 Market Str~e}/
Camp Hill, PA 17011
(717) 763-1383
Attorneys for Defendant
1N THE COURT Of COMMON PLEAS
OF CUMBERLAND COUlXITY
STATE OF PENNA.
JEFFREYHOWARD BISHOP
0:!-5102
VERSUS
CYNTHIA ANN BISHOP
DECREE IN
DIVORCE
AND NOW, ~ ~:5i
DECREED THAT
CYNTHIA ANN BISHOP
AND
, 7~E)LL IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
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;
The terms of the parties' Marital Settlement Agreement dated November 13, 2003
and attached hereto are incorporated herein but not merged herewith.
JEFFREY HowARDS BISHOP :
PLAINTIFF :
cYNTHIA ANN BISHOP :
DEFENDANT :
IN THE CouRT OF COMMON PLEAS OF
CUMBERLAND cOUNTY, PENNSYLVANIA
02-5102 CIVIL ACTION LAW
IN CUSTODY
~RDER OFCOURT
AND NOW, Thursday, Jul_y__22, 2004 __, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before ~lDawn S. Sunda , Es . , the conciliator,
39 West Main Street, Mechanicsburg, PA 170~55 on Sa~turda_Y, August 21, 2004 at _12:00 PM
at
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to apl>ear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Is~
Custody Conciliator
mhc
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about access:[ble 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 e,r business before the court. You must
attend the scheduled conference or hearing.
IF YOU DO NOT
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. SET
HAVE AN ATTORNEY OR cANNOT Al'FORD ONE, GO TO OR TELEPHONE THE OFFICE
FOR'IH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ItELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 1 '70 l 3
Telephone (717) 249-3166