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Home My WebLink About01-0016 FX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .~-"," , . . . . ;F.;+; "';F. . . . . . .. . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ANDREA L. BISHOP, No. 01-16 CIVIL TERM plaintiff VERSUS ,Tnl-Tl\T R l:n- ql-TOP , qR Defendant DECREE IN DIVORCE AND NOW, IVL1 31 .:r (.: 1'1 A.A. ~bl ,IT IS ORDERED AND DECREED THAT ANDRF.A T, BTSHOP , PLAINTIFF, AND JOHN E. BISHOP, SR. , 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; No issues are outstanding and none were raised by either party. iF. if. '" :f. :Ii '" ;F.;t;'" iF. '" :f.;t;:f. ;t; . . .. . . . . . II . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff NO. 01-16 CIVIL TERM JOHN E. BISHOP, SR., Defendant CIVIL ACTION - LAW IN DIVORCE 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. c. of filing and manner of service Date of filing of Complaint: Manner of service of Complaint: Date of Service of Complaint: of the complaint: January 2, 2001 Certified Mail/Restricted Delivery January 9, 2001 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: May 29, 2001 b. Defendant: May 9, 2001 OR 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 execution: N/A b. Date of filing: c. Date of service: 4. Related claims pending: No issues are pending. 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) (1) (i) of the Divorce Code: a. Date of Service: N/A b. Manner of Service: Date Waiver of Prothonotary: a. Plaintiff's b. Defendant's OR Notice in Section 3301 (c) Divorce was filed with the Waiver: May 29, 2001 Waiver: May 9, 2001 ( , " I~I ~,- .' . 1 " '::.1' ... ''''' -",,~.,,"",- - 'b~ ,. . -~ ~,- ',< , ~,-,. ~v..~-o ~~',-,~, "' ;C' ,'".' '""": " ~ '-fej'~:~TIl[(f'flW'"1i;'_l"" ~'<_T-'_'-'~ii>fjP.fi"r(y,-,c"':Hi~ (") ~.;; <~ ~~ ~~~, r:: '-./ ~{"'~' 5f;g 7' :::J -' ...... r'-~) ~ r\ co :.n C0 c,r!' T"Til\'WIt'~~J!;t"" Wt'K;lI1"_l\",p:!J1','rJ"mrl:@'ni!l'"~Ui'Ef~~!%jmj:filfflffiiiW',~.n,.._lt~I~J.!, DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 - ,--.-.,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, plaintiff v. NO. Of - It:> twJ CIVIL ACTION - LAW DIVORCE JOHN E. BISHOP, SR., 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. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 "--" 1'"1"'"' " - . DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL. PA 17011 (717)737-0100 ;'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff v. NO. oJ-I(.,~ ~~ JOHN E. BISHOP, SR., Defendant CIVIL ACTION - LAW DIVORCE COMPLAINT AND NOW, this~day O~1'"\DcUU 4- Plaintiff, Andrea L. Bishop, by her Attorne~, , 2000, comes the Diane G. Radcliff, Esquire, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is Andrea L. Bishop, an adult individual residing at 1022 Swarthmore Road, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is John E. Bishop, an adult individual residing at c/o Cecil Bishop, RR# 1 Box 1150, Mifflintown, PA 17059. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 23, 1997 at Spicewood, Clinton County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to -2- "I-I DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP lliLL, PA 17011 (717) 737-0100 participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. Or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EOUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from August 23, 1997 until on or about November 19, 2000, the date of separation, all of which is "marital property". - 3 - II - ~, 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT III: ALIMONY PENDENTE LITE. ALIMONY 13. Paragraphs 1 through 12 are incorporated by reference hereto as fully as though the same were set forth at length. 14. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 15. 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. COUNT IV: COUNSEL FEES 16. Paragraphs 1 through l5 are incorporated by reference hereto DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 - 4 - it' ~I , II' DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HIlL, PA 17011 (717) 737-0100 '~I~""~"1' "',",-'" as fully as though the same were set forth at length. 17. Plaintiff has employed Diane G. Radcliff, Esquire, as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Reepee"ull 'ub~ , ESQUIRE e Road Camp Hill PA 17011 ourt rD #32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff - 5 - - -,~ " ""1'''''1- 1 ' -. DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 "";" T 'I . . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~l- (I- ~ REA L. BISHOP -6- I ' I ~ " DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737.0100 I I .~_ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff v. NO. 01-16 CIVIL JOHN E. BISHOP, SR., Defendant CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE OF DIVORCE COMPLAINT AND NOW, this .2tl1 day of ,Tanllary, 2001, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have served a copy of the Complaint in Divorce in the above referenced case upon the following named person, by mailing same by certified first class mail, postage prepaid, addressed as follows: John E. Bishop c/o Cecil Bishop RR #1 Box 1150 Mifflintown, PA 17059 Respectfully submitted, , ESQUIRE le oad Ca Hill, P 17011 Phone: 737-0100 Fax: (717) 975-0695 Supreme Court ID # 32112 . ~ "1'''1 H \ . Complete items 1, 2, and 3. Also complete item 4' if Restricted Delivery is d~&irtld. . 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 maiJpiece, or on the front if space permits. 1. Article Addressed to: iTOH-"-l E. !31:5FfuPf '5'(2. C/D CUrL. 8rSl-f-vp {2(2,=#, J 50Y- I1S0 v'-^-\ F-FU c0 "TOW,0 ? 1\ ad'S1 2. Article ~unjJseri(Gopy frqm servige la~O; ,: 7'01 "t3'rimDcO-Y j:-1a-<t PS Form 3811, July Hl99 ''', ~I 'T" , l' -'~. 3. Service Type )f5;r Certified Mail o Registered o Insured Mail o Express Mail ~eturn Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) es &'-{~i Domestic Returf1~eipt 102595-99-M-1789 I I i I i I I I Ii I, I Ii il II I 1",,,,,",,,,- ~,c._" " ~ .I!./lI!!lrUl!.rW ,!'J!llJlill(~fl'l'~ I~WJQIIIIlI "~. 0" ~- . i '. (") 0 ~ "- ""Oro Ofrn ".. Z=o ;,e: Z~- I':> (I)..::;: .j:" -<~-" ~O .'U ~O ::z: pO --; (-::, c: '::? <.::.") .-;~ Z ::.~~J ~ =< ~ ~:b <>> --:;: ~ ~=~l!!lWi..,IT"";;'''~~' n""~--'-oW,'tP"";-~~T'wm~'Il~llllo;:l1tll~"~'!l'"\T""" F,!!~IW~~'~;I'i'~~ DIANE G. RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 (717)737-0100 '.""''''' ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff JOHN E. BISHOP, SR., Defendant NO. 01-16 CIVIL CIVIL ACTION - LAW IN DIVORCE AMENDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce has been served upon the Defendant, John E. Bishop, Sr., by Certified Mail, Restricted Delivery on January 9, 2001. The return receipt is attached hereto as Exhibit "A" and made a part hereof. CLIFF, e Road A 1701l . ) 737-0100 Fax: (717) 975-0695 Supreme Court ID # 32112 Attorney for Plaintiff -I I'll EXHIBIT "AU RETURN RECEIPT DIANE G. RADCLIFF 3448 TRINDl.E ROAD CAMP HIl.l., PA 17011 (717) 737.0100 -2- .~>~,., ,. -. 11'1 - 'I"' , . Complete items 1, 21 and 3. Also complete item 4'if 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 jf space permits. 1. Article Addressed to: JOH-r.J E, !3r:)FfoPt 1:;-(2, C/D CELCl B,s/h)p {2(2q:y' coY- IISO v'-^- \ WLlt0 'TOW,0 '? f\- adS'? 3. Service Type ~. Certified Mail 0 Express Mail o Registered ~eturn Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) es 2. Article Number (Copy from service labeO 1-01. <t 3'1 tJd ooo-Y 7-t(j<.( (", '-(11r PS Form 3811, July 1999 Domestic Return Receipt ~ .CI.I_ .~, , ", 102595.99-M-1789 ~f' DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA nOll (717) 737-0100 " , .., -1,-" -', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff NO. 01-16 CIVIL TERM V. JOHN E. BISHOP. SR., Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 2, 2001 and served on the Defendant on January 9, 2001 by Certified Mail, Restricted Delivery. 2. The marriage of 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 in 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. Section 4904 relating to unsworn falsification to authorities. Dated: .s 1;;1.1 IOL I ' ~Da 2i cru~ ANDREA L. BISHOP "'1'1-' I / .^ .' I DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 "j'. 'l'" ." IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff NO. 01-16 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE V. JOHN E. BISHOP. SR., Defendant WAIVER .OF. NOTICE OF INTENTION TO REQUEST E~TRY OF A DIVORCE DECR~E UNDER SECTION :.:s:.:s U.L ( C) 0.1:" 'l'Ii.!!: D~ VORe.!!: 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 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 the Prothonotary. I verify that the statements made in this Waiver 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: s/.;;.,)O( . I rldM/L cA. ~~ ANDREA L. BISHOP " \ ~I "II','" "I II ! I I .i 'I - "."~ ~...,..." 4_ ~ ~"', (:2 t~ -0',-: S2 ~~E -z:t.. ~Q ~~ ~c> ~~~ Y'l__ c/ ::::':1 -< c.;) - i'j \..c; -' 9? :J1 rv _J" '!!llI~~'MilF~I<!"'~Wl!_l'l'lW'l'Wl';!!Ji~~t~lI9IS!ii!llUll!!lIii'lRM!ll1'lll'!1~~ IftIm! DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 ,:,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L, BISHOP, Plaintiff NO. Ol-16 CIVIL TERM V. JOHN E. BISHOP. SR., Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT ,. l. A complaint in Divorce under Section 330l(c) of the Divorce Code was filed on January 2, 2001 and served on the Defendant on January 9, 200l by Certified Mail, Restricted Delivery. 2. The marriage of 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 in 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. Section 4904 relating to unsworn falsification to authorities. Date 12. ~~ I-I I h -, (') c: - :s, rR1J5 2Q-- .:2,.p' c6J;:, ~E;- :?C) ~r") C :c: :.< .' Tv a - -,.. .~ o -f"j ~""J:: 1 '-0 v -e -'-.. ~ ,>T ~ ~= ~""""j"'~ ,. ~if!lI!!llJf!!!i~!f1j!Nilr""~'i1f"'RJ;~~f""~~!W')',t,"~~'~_M ~-~_r _" ",~ DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL. PA 170ll (717) 737-0100 !~- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANDREA L. BISHOP, Plaintiff NO. 01-16 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE V. JOHN E. BISHOP. SR., Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33Ul(C) OF THE DIVOKCE 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 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 the Prothonotary. I verify that the statements made in this Waiver 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: - 1",:",""",1 I', I I ~'" ' '1- SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1()(3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBERS. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DATE May 22, 2001 DOCKET NUMBER 01-16 PLAINTIFF'S NAME Andrea L. Bishop PLAINTIFF'S SS # 264-11-6542 DEFENDANT'S NAME John E. Bishop, Sr. DEFENDANT'S SS# 195-30-2625 !~ "" , "1'-' . '''"'4 " _ -:1' d' -". _ -~",- . , . . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .. A nd1'a L. BishoB PIa ntiff o I - (j60 ( (p ., File No. vs. IN DIVORCE '00 hn E. BiSho~ SR- De endant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, havi~g been granted a Final Decree in Divorce on the -----2ht day of prior surname m~ of , ~ (J D.I R/:Jl3erc, pursuant to , hereby elects to resume the , and gives the pr~ Of. ~~04. !l:u}AJ./I ~. ~ ~~!-LJ Signature -,-vO- this written notice DATE: J./ ~' OiL Si (j,. s COMMONWEALTH OF PENNSYLVANIA: 55. COUNTY OF CUMBERLAND On the d.. J ';j- day of ~ (J../lfj clmp', before me, a Notary Public. personally appe red the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that helshe executed the foregoing for the purpose therein contained. seal. I n Wi tness Whereof, I have hereun to set ,my. hand and official CJCUed?~<' &p~i)j)~1 Not!'lry'Publ1.c NOTARIAL SEAL CLAUDIAA. BREWBAKER, NOTARY PUBLIC Carlisle Boro: Cumberland County My Commission Expires April 4, 2005 I'."'~ =,~"'_, rl ,~~-~ ""~ I Ii " I: II !I II 'I !' ;: ~ 1..--.- .__ IMRII ~ 0 0 0 ~ C 1'V ''7l -:'l <: '- ;:g~ c: ~ ;".-11 () z::r/ ~ ' ,['= W};~, N ~.~~;0 - C 1-J -<:,/. ;~~js ~C; r-- ~ ~f~ s: ~ 9 6f~ )>(~ --, ~ z ~ ~, :;! ::0 -' 'D -< ,Jd :J8 !'llmlllWl~~~ ,~~o/m"'I1~]"''B;flj'''[1'''-'-' ",--, ",<,"-''''''"