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Home My WebLink About00-00061 .. ~~~< >~~~.', ';~::~;: ~I ~ ~~~ ~ ~.; ~ i t~; ~~~ ~ 'i'''~ ~ l~ ~ ~ ...J : 'o'~ ~ _.a:(':,~::">;::'.~3)~'~'::{.~~'~~~.$>:~~':;~$.:;q~~,:>{C~l"~-::..~:::..:~::..::~::)~::;;::~~~~<:;-(.}. :'~::+::~~>~}:~>~~:::',~~.::!;~1i~;{.Z~{+i?E~~1e~:<4t!t~,+::+}~ ~;!.:{>:.<tl3![::~{.::.<<(~::~~,: I ~.~ l'J r~ ;.'~ ~ k~ ~ f.'S II ~~~ ~'S ~ ':-" ~ ~.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ,', l~ ~ M ~.~ (~ l~ n.~ ('." (~ I"; ,,"s ~ ,",; ~.~ ~ i (~ i>:.~ ~( t::l ~( w( ~.~ ( ...... ...... Ed.war.d...W.... .Mack. ...... ........ ........... ........-... I I 'I II II ,. ~ ~~ :-~' (r.! (~ l;.; (~ (',.." )~ 1;.1 \~ .,j ~ :) ~ h; ~ ~.~ ,'S ~ ?' ~ @ ,. ~ li.,<, ~.~ ~ ;..~ ~ .' 00-61 No......................... ..................19 ...... ...-.... ... ...... ......... P.l a.in.ti.f.j; ..-..... ............ ....... .... Versus Debra D. Mack t ~~ ~ ~.~ if'; ~ ~.~ .... ...m ......m...De.f lii'.ndQ.ni<. ~ ~.~ DeCREE IN DIVORCE . ~ 'i:~ "".,.. AND NOW,..... .~.. ..lY.......... H .200{}. it is ordered and decreed that ............. E.dwQ.rd .W.. Mack. . . . . . . . . . . . . . . . . . " plaintiff, and...................... .1?i?P.r.,\ .P... .11?-91<:.................., defendant, are divorced from the bonds of matrimony. ~ ~..~ f.'~ ~ ~ ,. "'.l ;..: $I ~~ ~ k.~ ~ ~ ~ ~ r.~ ~ ~ III (~ ~ .," The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ "". ~( r< ~ R ~,.... ,. ".~ ~ ~.~ t ~.~ ,< ~ ~ ~ ~ ~. .:'~<''';'.>~:'...~. - '~~~~;:~.~~.~-~:~:,~.~.~~.~~~:~:~';~~ l~.. ~ ~.." l~ \~ II~ ~.~ ~ ('.~ ~: ( ~i 10', ~~ --.-------------......-..-- ~ '::.:~'..'::.;" "::-0-::.'''.::.;..:,.:::"", ............. _;.;..:.:.None...................................................., By Attest: /? ... ......... ~~. J. Prothonotary If- /$'.00 ~'/ff.t?ttP <. .,~O ... ,"'. : tbf.~~ -d-~~ '-7__ _7'- /1. ~ ~ ~o-~ ~~ tT' < < EDWARD W. MACK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK Defendant NO. 00-61 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under g (3301(c) of the DivoIce Code. 2. Date and manner of service of the Complaint: January 6, 2000, certified, deliver to addressee only, return receipt requested. " ~. (a) Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce Code; by Plaintiff: April 12, 2000; by the Defendant: April 13, 2000. 4. Related claims pending: None. 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: N/ A (b) Date plaintiff's Waiver of Notice in g 3301(c) Divorce was filed with the Prothonotary: April 17, 2000. Date defendant's Waiver of Notice in g 3310(c) Divorce was filed with the Prothonotary: April 17, 2000. LAW OFFICE OF EDWARD L. SCHORPP Date: -,/-P-Oc> BY:~~~ Edward L. Schorpp, Esquire Attorney for Plaintiff ~~-------- /j; If) ~ is .. =>~ }uQ - - 8~ y~, :x: u-~- .." 0::1 'L~: -'>-- ~C ;--. ~~ L:~ u.Jf'__ fu ~l.:' 0:; :L 0... ron.. t--~ """ .~ LL. 0 :5 0 0 U --------------- , EDWARD W. MACK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK Defendant : NO. 00-61 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) AND NOW, this i l t.l day of ,\ 0-<"\-l..t!>..A-u ...) , 2000, I, Edward L. Schorpp, Esquire, attorney for Edward W. Mack, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce in the above-captioned matter, with Notice to Defend and Claim Rights, upon Debra D. Mack, the Defendant, at her residence at 310 West Dauphin Street, Enola, Pennsylvania 17025, by depositing same in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy ofthe return receipt card signed by the Defendant on January 6, 2000, indicating service was effected, is marked Exhibit "A," attached hereto and made a part hereof. ~ - ~ . B~~P/ Edward L. Schorpp, Esquire Attorney for Plaintiff Sworn ahd subscribed to before me this tl tR. day of J a.n.~ ;I/n-~) II, 1Z:rf Nl~ Notary Public rlOTAm.'J~ SEAL UUiJ~l?;. A. no;.:!';\ tmTARY PUSUC 'CAZ'.lUJLE !::G:10,. cm;Dr::RW~!) co., PA !litV cO:a.J!!ss!m~ sep,RIES JULV 21. 2GZJ3 ,2000 .~~~:.- ~~{ -- ~.f~ _ ,--~ ~ ::..r;:o::.- :.~ j:-S~ -::~:;#i-'~~/ ,..,-~ ~ \.0 '" S2 9 ~ ~ ~b 0>J c: 0.. \.J.-,U1 % ~ ..:t ....., ~ 0 0-. T - ..!!. ^. .g SENDER: Ui-" Complete items 1 and/or 2 for additional services. ll:l .. Complete items 3, and 4a & b. r::: . Print your name and address on the reverse of this form so that we can Q) return this card to you. ~ .. Anach this form to the front of the mail piece, or on the back if space >-- does not permit. ! . Write "Return Receipt Requested" on the mailpiece below the article number. +"' .. The Return Receipt wiU show to whom the aniele was delivered and the date g delivered. "t:I 3. Article Addressed to: ., ~. " C. E o e '" '" OJ a: c c ,.' "'~. ~~jgnature (Addressee) I also wish to receive the following services (for an extra feel: 1. 0 Addressee's Address 2. )q Restricted Delivery Consult postmaster {or fee. 4a. Article Number ,; e .~:. " '" Debra D. Mack 310 West Dauphin Enola, PA 17025 Street Z 321 829 4b. Service Type o Registered ~ Certified o Express Mail 183 '03 '(ii', e " a:. ~. :; ;:; a: m' <:: 'w " l; - D Insured o COD Jir Return Receipt for Merchandise 7. D.'Jte of Delivery ~{t,jTe (Agentl " , g.r 8. Addressee's Address (Only if requested ~ and fee IS paid) ~ ..c !- . )11~_December 1991 *U.S. GPO: 1992-3'23-402 DOMESTIC RETURN RECEIPT EXHIBIT "A" EDWARD W. MACK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 00- bt IN DIVORCE CIVIL TERM DEBRA D. MACK, Defendant 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 in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation with your children. When the ground for 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, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 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 FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 EDWARD W. MACK, Plaintitf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK, Defendant NO.OO- C. i IN DIVORCE CIVIL TERM COMPLAINT UNDER SECTION 3301(,,) OF THE DIVORCE CODE I. Plaintiff is EDWARD W. MACK, who currently resides at 7 East Beale Avenue, Enola, Pennsylvania 17025, since September, 1996. 2. Defendant is DEBRA D. MACK, who currently resides at 310 West Dauphin Street, EnolaPennsy1vania 17025, since October, 199. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 13, 1989, in Lewisberry, York County. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. I verifY that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Ii 4904, relating to unsworn falsification to authorities. Date: jL/? /97 /" / ~JhL Edward W. Mack LAW OFFICE OF EDWARD L. SCHORPP BY:-~~/ Edward L. Schorpp, Esq. Attorney for Plaintiff , , Rlm-{t,:"FlCf Or' ~I" t ~~'I.I ""JOTAR'( ~r~,~L:I;-:',!~U: !. ,'. 00 Ji:\!j -5 Pll I: 80 C' I' . - .,.,. .', l'OU'ITY UI~"i,':ILJ,"d.I "L) .. r ~'Ei~~ GfL'/"."1 tI .., " '''' ,/ ,? 't"!j', : .,If ,lI!,11 I ~." ? i~.I' ./,/ //b , I , f1!" f.,.:',t " ,t 'l/'i ..-.. J.t ,- , 1'1 1 I ,/,': +-,------ - , EDWARD W. MACK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK, Defendant NO.00-61 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301(c) of the Divorce Code was filed on January 5, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(J:) OF THE DIVORCE CODE I. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers 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 thc prothonotary . I verifY that the statements made in this affidavit and waiver are true and 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: r~O ~~);;J Edward L. Mack, Plaintiff AtED-OfFiCE OF iF: C-l:JT; l).!.JTARY 00 APR I 7 AH II: 15 CUMBERLAND COUNlY PENNSYLVANIA Ii , .' J ,.: I :i i: J I i , , , . " I , ,I I: I. : I . . , EDWARD L. MACK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK, Defendant NO.00-6I CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301(c) of the Divorce Code was filed on January 5, 2000. I acknowledge receiving a true and correct copy of the Divprce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on January 6, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THF: 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, lawyers 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 affidavit and waiver are true and 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: ,,/-/S-C!4 ~a.~ /7;JacL- Debra D. Mack, Defendant , CI E.I)-C"Fi.AC 1'", I ,V:_ O. ,. 11 ,~: I:. :~TH:)W):rARY r ,L.... _11,1, ''l\ 'It";,! 00 ~,PR I 7 AI'III: I 5 CUMBERLAND COUNTY PENNSYLVANIA , I I' i , i ,il i: \ '( (: " i I I I' ., JI i I ,i , 'I i .~ ~- JAN 0 7 ZOfjfJ~ EDWARD W. MACK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK, Defendant NO.OO- tJ IN DIVORCE CIVIL TERM ORDER OF COURT AND NOW, this ~~ day of ~ ,2000, upon agreement of the parties, the attached Stipulation and Agreement is hereby made an Order of Court, and all prior Orders, if any, on this matter are hereby vacated. BY THE COURT: J. Edward 1. Schorpp, Attorney for Plaintiff Debra D. Mack, pro se FI' E"r, '~If'C l .v-'.....rt'"'Vl- or- 1H[ r-?.oT~~NOTA.qy 00 JM-l \ Oll.\'\ \0: 25 CUMBEf-\LIND C;OUN1Y PENNS'{LVi\NIA < .. " EDWARD W. MACK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA D. MACK, Defendant NO. 00- IN DIVORCE CIVIL TERM CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION is entered into the day and year hereinafter set forth, by and between EDWARD W. MACK (hereinafter referred to as "F ATHER") and DEBRA D. MACK (hereinafter referred to as "MOTHERn). WHEREAS, the parties wish to enter into an agreement relative to custody and temporary custody/visitation of their son, Edward W. Mack, Jr., born July 20, 1996. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. The parties will have shared or joint legal custody of their son, meaning the parties shall confer with each other on all matters of importance relating to his health, welfare, maintenance and education with a view toward obtaining and following a harmonious policy of his best interest. Each party shall keep the other informed of the progress of their son's education and social adjustments. 2. FATHER shall have primary physical custody of his son. '. ~- --=-,- 3. MOTHER shall have temporary custody/visitation with her son on the following schedule: (a) On alternate weekends from Friday at 6:30 P.M. until 7:00 P.M. Sunday evenmg; (b) On every Wednesday evening from 5:00 P.M. until 8:00 P.M.; (c) Alternating with Father on the following holidays: New Year's Day, Easter, Memorial Day, Independence Day, Labor Day, Thanksgiving, and their son's birthday. When MOTHER shall have such visitation, she shall pick up her son at 9:00 A.M. and return him by 8:00 P.M. the same day. The parties shall alternate custody of their son during the Christmas holiday so that on alternate years MOTHER shall have temporary custody from 6:30 P.M. Christmas Eve until 12:00 Noon Christmas Day, and the following year on Christmas Day until 8:00 P.M. Christmas Day. (d) On such other times as the parties shall mutually agree. In the exercise of her temporary custody/visitation, MOTHER shall be responsible for transportation of her son to and from FATHER'S home. 4. The parties will keep each other advised immediately in the event of serious illness or medical emergency concerning their son and shall further take any necessary steps to ensure that his health and well being is protected. During such illness or medical emergency, both parties shall have the right to visit their son as often as he or she desires consistent with his proper medical care. -. - , 5. Neither parent shall do anything which may estrange their son from the other party, or injure his opinion of the other party, or which may hamper the free and natural development of his love or affection for the other party. 6. Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 7. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of their son and shall retain such jurisdiction, should circumstances change and either party desire or require modification of said Order. 8. The parties agree that in making this Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 9. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein mentioned. WITNESS: (()~JS}U . Date: /tz- y19'9 8/~jlk)d Edward W. Mack 11{;A~LJ T;ttJ-- Date: d-,p- 79 ~/r7acL - Debra D. Mack RI. ED.-Q"T:C!: CF TIlE :'1');1-::): :OTARY OOJf.N-'5 PH 1:33 CUMBErlLN{) COuNTY PENiBYLVANIA '. , "