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Home My WebLink About97-03509 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TAMMY ROBERTA LOPER Plaintiff v, NO. 97-3509 CIVIL CIVIL ACTION - LAW IN DIVORCE JASON SCOTT LOPER Defendant PRAECIPE OF TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code, 2. Date a. b. and manner of service of the complaint: Date: July 8, 1997 Manner: Certified Mail/Restricted Delivery 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: October 12, 1997 b. Defendant: October 16, 1997. QR Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code and Date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a. Date of affidavit: N/A _ b. Date of filing: N/A c. Date of service: N/A 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) (I) (i) of the Divorce Code: a. Date of Service: N/A b. Manner of Service: N/A. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: 10/21/97 Date Defendant's Waiver filed with the Protho ( Section 3301(C) Divorce was \ , ESQUIRE e Road PA 17011 -0100 1.D. NO. 32112 Attorney for Plaintiff DIANE G. RADClIFF 3448 TRINDlE ROAD CAMPHtll, PA 17011 (717) 731-0100 Q: (::..! '.. ,fl {~<i i., \.1_ i t II ( ~ . . k .1 \ ( ~, . i ~~' t' 1'.- ... 1~ (".1' (' ----:\ ... I c~., C - u , -' . - ~ I' I. oO , , .. ~ ~~ ~ L _. ( , ,~ ,~ .~ '" 1>0 _ 1>0,. _ - ~-oo o.lj~!:: ~... -< ~ < "c.. ..:a . . c_ ,,~'C::: ",f-:t ~ ~ CIl) 0.. ~-<3;e Q U I i " 11 IlIANE (;. RAllCI.IH ATrUR:'\r\'-AT.I.AW .H411 IIU;o.;n11 MU...n C:\Mr lilli, 1',\ I7UII IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TAMMY ROBERTA LOPER, plaintiff (!~~L NO. '17- 3 'JNj V. CIVIL ACTION - LAW IN DIVORCE JASON SCOTT LOPER Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Carlisle, Pennsylvania. Cumberland County Courthouse 1 Courthouse Square Carlisle, PA l70l3 (717) 697-0371 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 766-8475 COUNT II: ALIMONY PENDENTE LITE. ALIMONY 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff lacks sufficient property to provide for herself by reasonable means and is unable to support herself through appropriate employment. ll. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. Respectfully IlIAN.: (;. RAJlC\.IH ATlORsn.A I. tAl\' \HII I MI~1JI1 MeMon ("MI'III1I,.'.\ 17t111 - - " \I} j:: t~ -: 1l " ( ;. i I;: , , , , f ~, ,- -' , l_ = I , c; r- ~" , , . I i ,I I il l>. l>. - :j?:'ttO ~:lB~ .;..."< ~ <~~ . ,. "'c . OJ - t.:l z 2:::: ",r:I: ~ ~~ ~ Q< U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TAMMY ROBERTA LOPER, Plaintiff it? - jj-otj NO. CIVIL TERM v, JASON scan LOPER, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, TAMMY R. LOPER, to proceed in fOnTIa pauperis. I, DIANE G. RADCLIFF, ESQUIRE, attorney for the party proceeding in fOnTIa pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party, The party's affidavit showing inability to pay the costs of litigation is attached hereto. Respectfully submitted, DIANE G. RAIlCl.ln' ArrORN[Y-A'r-I.AW ~Wl I Ml:'IriltU RO_..\II CAMP 11111., I'A 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TAMMY ROBERTA LOPER, Plaintiff v. NO, CIVIL TERM JASON SCOTT LOPER, Defendant '7'7-35'(J? AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding, 2, I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3, I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: TAMMY ROBERTA LOPER Address: 400 N. 7'" Street. Apartment 7. New ClImMrland. PA 17070 Social Security Number: 165-58-2926 (b) If you are presently employed, state Employer: N/A Addre89: SalllI}' or wages per month: Type of work: If you are presently unemployed, state Date of last employment: Aoril1997 SalllI}' or wages per month: $600.00 Type of work: Housekeeoina (c) Other income within the past twelve months Business or profession: None Other seU-employment: Interest: Di\'idends: Pension and annuities: Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: $483.oo/month Other: (d) Other contributions to household support (Husband) Name: Jason Scott Locer If your (husband) is employed, stete EXHIBIT "Air ~' G, RADCLIFF ,11 HINDLE ROAD ,1, Hill, PA 17011 , " '3]-0100 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TAMMY ROBERTA LOPER, Plaintiff NO. 97-3509 CIVIL V. CIVIL ACTION - LAW IN DIVORCE JASON SCOTT LOPER Defendant WAIVER OF NOTI E OF INTENTION TO RE EST TR F DI E DE RE UNO SECTION 330 ((c) OF THE DIVORCE ODE I. I consent to the entry of a final decree in 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 lrue 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. .,. '~nJ j(,~ I ammy_lY Loper Plaintiff Dated: /(1- /',) - 'i7 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737.0100 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TAMMY ROBERTA LOPER, Plaintiff NO. 97-3509 CIVIL V. JASON SCOTT LOPER Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE ST ENTR F DlV E D RE D SECTION 330((c OF THE DIVOR E ODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property. lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I veritY 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 .. Dated: /()-!Cv.- q7 j'0~ son S. Loper efendant falsification to authorities, OIANE G. RADCLIFF 3448 TRINDLE ROAD CAMPHILL,PA 17011 (717)737.0100 .". ." , '. .. ; I, , ;. , (, , I, '-'- , ,. c: ., I II II ~~,,~ ::lja::: ~ Ill...: !(u~ :a . >c= . III 1:._ C-' ~f-o:I: ~~~E" ~"':"d o .' < C. The holiday schedule shall take precedence over any other custodial period set forth herein. The other miscellaneous custodial periods shall take precedence over the regular alternating weekend and midweek custodial periods set forth herein. D. Neither PARENT shall make any derogatory comments about the other PARENT in the presence of the CHILDREN and to the extent possible shall prevent third parties from making any such comments in the presence of the CHILDREN. Further, neither PARENT shall discuss any aspect of the custodial situation with the CHILDREN and shall not utilize the children for purposes of conveying information or inquiries pertaining to the CHILDREN to the other PARENT. E. Each PARENT shall keep the other PARENT informed of all important events pertaining to the CHILDREN. Upon receipt by a PARENT, copies of the CHILDREN'S school schedules, special events notifications, report cards and the like shall be provided to the other PARENT. F. If either PARENT intends on removing the CHILDREN from the Commonwealth of Pennsylvania for a period llIAN!: G. RAJlCJ.ln- ATWRNH.A....I.AW 5HA IRISIlII IHUIl " CA'IP 11111.1',\ 17011 in excess of forty-eight (48) hours that PARENT shall provide the other PARENT with the address and