The URL can be used to link to this page

Home My WebLink About01-4677 SAIDIS SHUFF. FLOV~R & LINDSEY 26W. High Street Carlisle, PA 2t09MARKETSTREET CAMPmLL, PA 17011 P~DNE(717) 737-3405 ROBERT W. SIPE, KAREN L. SIPE, Plaintiff : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVD~NIA NO.O/'g~7~IVIL TERM CIVIL ACTION - LAW IN DIVORCE 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, Carlisle, Pennsylvania. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 S AIDI~~~0WER & LINDSAY Date: 773~_ /~,,. 2o¢ ~ By: ~ J./~/fpecky,~u Jo Esquire Supreme C~Surt ID # 53147 26 West High Street Carlisle, PA 17013 (717) 243 -6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSEY 26 W, High Street Carlisle, PA ROBERT W. SIPE, KAREN L. Plaintiff : SIPE, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - I~AW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d} OF THE DIVORCE CODE 116 North 27th Street, Camp Hill, Pennsylvania. 2. Defendant 308 Prowell Drive, Plaintiff is Robert W. Sipe, who currently resides at Cumberland County, is Karen L. Sipe, who currently resides at Camp Hill, Cumberland County, Pennsylvania. in the Commonwealth for at least to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 23, 1971 in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. Plaintiff and Defendant have been bona fide residents six months immediately previous SAIDIS SHUFF, FLOWER & LINDSEY 26 W. High Street Carlisle, PA 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court a decree in divorce. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY By: Joh~ Esquire Supreme C6urt ID # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSEY 26 W. High Street Carlisle, PA AFFIDAVIT require (2) marriage available to me upon request. (3) require I, Robert W. Sipe, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court that my spouse and I participate in counselling. I understand that the court maintains a list of counselors in the Prothonotary,s Office, which list is Being so advised, I do not request that the court that my spouse and I participate in counselling prior to a divorce decree being handed down by the 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. Dated: R err W S~pe, Plaintiff VERIFICATION 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. Section 4904, relating to unsworn falsification to authorities. Dated: SAIDIS SHUFF, FLOWER & LINDSEY 26 W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA ROBERT W. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01-4677 CIVIL TERM KAREN L. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divome Code was filed on. 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 in Divorce after service of notice of intention to request entry of the Decree. I vedfy that the statements made in this Affidavit 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. Dated: /~ ~/~ /R~pe~/~. - ~E~ 2 ,~ 200! SAIDIS SHUFF, FLOWER & LINDSAY 26W. High S~eet Carlisle, PA ROBERT W. SIPE, KAREN L. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01-4677 CIVIL TERM : SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDE.~. 3301{c) OF THE DIVORCE CODF 1. I consent to the entry of a final Decree of Divome 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 divome 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 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. Dated: /~/~/~,/ Robert W. Sipe( PIJ~intiff