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Home My WebLink About97-04350 :-' I I I I i ! I \. I " I ~ "" (;:.J ~ '- ! " 1 tl ~ / / ~ <<) ~ . ~I c:s- I; 'I Ii I' . !I Ii 'I I' I II II II II ii 'I II II II " I' d 'I !/ 11 I, 'I " ,I , ; ~ " " j: ii " Ii , SAlOIS, GUIDO, SHUff ... MASLAND ~h W Ib.h Strm Carll\k,PA CINDY I. CLEPPER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-4350 CIVIL TERM v. JOEL L. CLEPPER, Defendant CIVIL ACTION - LAW 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: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail return receipt requested, restricted delivery, postage prepaid attached hereto as Exhibit "A". 3. (Complete either paragraph (a) or (b): , " (a) Date of execution of the Affidavit of Consent required !, by Section 3301 (c) of the Divorce Code: i: E By the Plaintiff: November 24, 1997; By Defendant: November 12, 1997. f " ,< j, (b) (1) Date of Execution of the Plaintiff's Affidavit ii required by Section 3301 (d) of the Divorce Code: ,I 1,'Ii (2) Date of service of the Plaintiff's Affidavit upon the Defendant: Ii " ii ;1 !! Related claims pending: None. Complete either (a) or (b): 4. 5. " (a) Date and r.1llnner of service of the notice of intention ; to file Praecipe to Transmit the Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in S 3301(c) divorce was filed with the Prothonotary: November~, 1997 Date Defendant's Waiver of Notice in S 3301(c) divorce was filed with the Prothonotary: November 20,~. Date: Id)~fc,7 ~~ ~ Edward E:~ido. Esquire Attorney for Plaintiff . EXHIBIT "A" I ~_'_2for__ - .. .~_3,"'0Ild"" . ~ I .....,... --........ ~.. . lei'" WI tin........ _It_ ,,' .............. . '**.......... . .c::-_ ...__ . ."",- _0Ild..._ .- I "6, r2,~) 'I I. 'aAdclrWllli InI file" P/III1I I 1IIIo......1ll *""-.. fIllIawlng lIMeN (lor.. .... '"t. i ;~~~I= 1 Conut~",l. ~~I.lorlM. J /./)I~' ';CeItIed j C e.- MIll c INond J C IlIUlIlIaiplb ....#1.1... C coo J l '......"", J Joel L.Clepper 19 Olestnut Street Newville, PA 17241 s. , (P'IW NMte} L. I '(. fIT .. X PI "- 3111, Oecamlleo '114 \c. ~) ~~. .. :.- - .- j.. "~r~' ",_ 'l!'" . . , -!.~:( "', . ,,\ . 1.:: l...', . ", 'Pd o..u, ) 11~. ~l) .,' vlJ S..J 4<- I 'i 0,\11 LAW OFFICES SAIDrs, GUIDO, SHUFF" MASLAND H_llip_ c.-. PA I lOll lOIo 17m 20.6212 Fa, l111t 20."16 210'1"__ C..., 1lt11. PI< 11011 IN, t1I1t n1..~ F.. (1111111-:1401 (.k ,Hv{ /i!.... j,-) 71" SAIDIS, GUIDO, SHUFF " MASLAND 26 W Hilh StlftI C""'Io. ,,, i d !i ,I :i Ii CINDY I. CLEPPER, Plaintiff IN THE COURT m" COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-'/ i,/I CIVIL TERM if I, Ii :' v. ,I H : JOEL L. CLEPPER, Defendant CIVIL ACTION LAW IN DIVORCF. 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 Ii 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 reI ief 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 CI.AIM ANY OF TIlEM. YOU SHOULD TAKE THIS PAPER TO YOUR lAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFmRD ONE, GO TO OR 'tELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HEI.P. Cumberland County Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 SAlOIS, li:x':SHU:F . MASLAND 8 . ;"}f~ y. ..,...,...,......4_.._._w, F,dwanl ~:, Guido, Esquire Supreme Ct. I.O. , 21206 26 West High Street Callisle, PA 17013 (1\7) H}.f)222 Attorney tor Plaintiff SAlDIS, GUIDO. SHUFF " MASLAND 26W HipS..... C.tr1u..."" CINDY I, CLEPPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA II v. NO. 97- '13...l) CIVIL TERM II JOEL L. CLEPPER, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301rcl OR 330lldl OF THE DIVORCE CODE 1. Plaintiff is Cindy I. Clepper, who currently resides at 1935 State Road, Duncannon, Perry County, Pennsylvania. 2. Defendant is Joel L. Clepper, who currently resides at 19 Chestnut Street, Newville, Cumberland County, Pennsylvania. 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. The Plaintiff and Defendant were married on April 22, 1983 in Carlisle, Cumberland 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 80 advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. 1 I[ II Ii Ii ., I' AFFIDAVIT I, Cindy I. Clepper, 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 require that my spouse and I participate ill counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's 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 counselling prior to ~ i I 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: 'l.~~C\7 L, Ml'J Q CttP (u.\. Cindy . Clepper\-Vlai'htiff II ~ I , I SAlOIS, GUIDO, , SnUFF " I\IASLAND 26 W H..h s.... C"'"Ie,"" ~ 'i Ii II " il a " !i r1 " Ii !~ ("; :3 :') . " ) , ..,~ , ) ; .. ,; -. . , .. " - If;;. "'" n J) 0 C. -.I 'n :;-"" .. ',~ - \ :n ~ '..; 'J .:; ,"J "1 ::1 ..... ~ .. ....j :, ,,., .~ ~A1 UJ ".