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Home My WebLink About00-08000 .' .-' , . . . . ~~~ ~~~~ ~ ~ ~ ~ :f. :F.:f. "'Of. . .. " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS . . . OF CUMBERLAND COUNTY . PENNA. . . STATE OF THOMAS H. BURKEPILE, Plaintiff NO. 2000-8000 VERSUS . DEBRA KAY BURKEPILE, Defendant . . . . DECREE IN DIVORCE . . . . . AND NOW, f.\'f"i t z" , Zoo I, iT IS ORDERED AND THOMAS H. BURKEPILE DECREED THAT , PLAINTIFF, . . . . . . DEBRA KAY BURKEPILE AND , 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; . . NONE. , . . :f.:F. :F.:F. :F. :F.:f.:F.:F.:F. :F. :F.:F. . . . . . By THE C:~ AT . . PROTHONOTARY :ti:ti '" :F.:F. :f. "''''''':!::ti''' "'Of. ',' "-. '",- ,_",_l i"" -.-, ". ,-, ~" .,- . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . .' ) THOMAS H, BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-8000 CIVIL TERM DEBRA KAY BURKEPILE, 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 S 3301(c) 338l(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on November 14, 2001 by certified, restricted mail signed for by the Defendant. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by S 330l(c) of the Divorce Code: by the Plaintiff: April 18, 2001; by the Defendant: April 18, 200 I, (b) (1) Date of execution of the Plaintiffs Affidavit required by S 330 1 (d) of the Divorce Code: (2) Date of servIce of the Plaintiffs Affidavit upon the Defendant: 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, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by S 330l(c) of the Divorce Code: by the Plaintiff: April 18, 2001; by the Defendant: April 18, 2001. Date: April 18, 2001 omas S. Diehl, Esquire Attorney for Plaintiff " ~ I v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- 8tXO CIVIL TERM THOMAS H. BURKEPILE, Plaintiff DEBRA KAY BURKEPILE, 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 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 Prothonotary's Office at the Cumberland County Courthouse, 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, Pennsylvania 17013 (717) 249-3166 " , . _ on__ _._~ ,.,..,' _. ," ~,_ _ _ . _ _, "_.' _~_ n -,-, ~-- -, - THOMAS H. BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO,OO- 'gfHnJ CIVIL TERM DEBRA KAY BURKEPILE, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE The Plaintiff, Thomas H. Burkepile, through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Thomas H. Burkepile, is an adult individual who currently resides at 6 West Big Spring Avenue, Newville, Cumberland County, Pennsylvania 17013. 2. The Defendant, Debra Kay Burkepile, is an adult individual whose current mailing address is Post Office Box 153, Wellsville, York County, Pennsylvania 17365. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on February 26, 1976 III Churchtown, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 0:, ,i~ I -,^' -T_-C' "..,' . , "","" "".,~--- " . 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Thomas H. Burkepile, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. S 3301(c) or 3301(d) of the Divorce Code. Respectfully sub . Date: NOJ I J, J-a:o . ~/d2jJ Thomas S. Diehl Attorney for the Plaintiff One West High Street Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ,~ ~, . - ,~'" , . ~" _._.c. - ~ - ."'17'q . VERIFICATION I verifY that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. t~,~,~~ HOMAS H. BURKEPILE, PlamtJff """' "~ .--~.-,,"- -"-"',."._" , ,- ~ - -~- - ' ~ A, THOMAS H. BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 00-8000 CIVIL TERM DEBRA KAY BURKEPILE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint III divorce under S3301(c) of the Divorce Code was filed on November 13, 2000. 2. The marriage of the 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 ofthe 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. S 4909 relating to unsworn falsification to authorities. Date: <-j. 18 - () I (k~ -rI ~~~ THOMAS H. BU PILE, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 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 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.C.S. S 4909 relating to unsworn falsification to authorities. Date: L{ - ("3 ' () ( YJ;, ~ ~Q.~ ~ THOMAS H. B RKEPILE, IPlaintiff '1, ~,,' ~,' _, . " - THOMAS H. BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-8000 CIVIL TERM DEBRA KAY BURKEPILE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under S3301(c) of the Divorce Code was filed on November 13,2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe 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. S 4909 relating to unsworn falsification to authorities. Date: 11---/ g..- 0/ ~ba ~gtU~L1I'& DEBRA KAY RKEPILE, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. 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 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.C.S. S 4909 relating to unsworn falsification to authorities. Date: "/.-18'-6 ( CJJ<<II iIod.- 13tuftl 1e DEBRA KA !Y3URKEPIL ,Defendant ;:wt>l, ~ 1 ,'- '.- -r'~ .~ THOMAS H. BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-8000 CIVIL TERM DEBRA KAY BURKEPILE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 15th day of November 2000, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Thomas H, Burkepile, and states that he personally had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Debra Kay Burkepile, at P.O. Box 153, Wellsville, Pennsylvania 17365 by certified, restricted delivery, return-receipt requested, A copy of said receipt is attached hereto indicating service was made on November 14,2000. Respectfully submitted, (r4 Thomas S, Diehl Attorney for the Plaintiff One West High Street, Suite 208 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ',"1" _ I. ~~ "r',.,',,' --,'", -',' .," , '="', ,." ", '_' . ~T-_ ',T," - - - - '--' " n_ _" ~~, '._ r _; - "" ~__~, ,,'__f _~, . ~ --"- " I:] 0- r'- ru m Postage. $ .55 .-'\ m Certified Fee 1.40 r'- r'- Return Receipt Fee 1.25 ru (Endorsement Relquired)' I:] Restricted Delivery Fee 2.75 I:] (Endorsement Required) C Total Postage & Fees $ 5.95 I:] .JJ Reciplent's Name (please Print Clearly) (to be completed by mailer) I:] D.ep_r.a K~.~kepile. .__._._.........._................ g 'sii:'&.i. ~~~\~r~~:..._.:....:.::::::::::::..........................._...... C -Ctry:siifi."zipt4 r'- Wellsville, PA 17365 llcOrnpl8te ttems 1, 2, and 3. Also Complete ttem 4 W Restricted 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 mail piece, or on the front if space permits. 1. Article Addressed to: D. Is delivery address different froni Item 11 If YES. enter delivery address below: ClAgOnt Cl Addressee CJ Yes CJ No DEBRA KAY BURKEPILE P.O. BOX 153 WELLSVILLE, PA 17365 ~~:~~'LIU~ ..'tJ Registered . I H'R11~~~;Pt for Merchandise Cl insured Mall Cl C.O.D. 4. RestrIcted DellvElfy'1 (EJ<tnl Fee) XXI Yes 2. Article N~mber (Copy flOm service labeQ 7000 0600 0027 7313 2790 PS Foron 3811 , July 1999 Domestic Return Receipt 1Q2595+99-M-1789 ,. ',,-~ ~" " ,,-__ .-, ,. -0 . THOMAS H. BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 00-8000 CIVIL TERM DEBRA KAY BURKEPILE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint III divorce under S3301(c) of the Divorce Code was filed on November 15, 2000. 2. The marriage of the 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 herein are made subject to the penalties of 18 Pa.C.S:s 4909 relating to unsworn falsification to authorities. Date: 1-/, 02.- 0-1 (~J~~, THOMAS H, OORKEPIL ,Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a Final Decree in Divorce without notice, .-.------ ? I under~tand that I maylose 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 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.C.S. S 4909 relating to unsworn falsification to authorities. Date: ~ - 0.1. - 0 \ '1.b~ {S",-~.t.~ THOMAS H. BURKEPIL ,Plai'E.tiff