The URL can be used to link to this page

Home My WebLink About01-0585 FX i' .-, j '-k ; . Of. Of. Of. ~ ~'If. IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY Daniel Lee Peiper, PENNA. STATE OF . Plaintiff No. 01-585 Civil VERSUS Gay Karen Peiper, Defendant . DECREE IN DIVORCE . AND NOW,_~ /l1 , 'A?O\ , IT IS ORDERED AND DECREED THAT Daniel Lee Peiper , PLAINTIFF, Gay Karen Peiper AND urther ordered that the terms of the marital ARE DIVORCED FROM THE BONDS OF MATRIMONY. , DEFENDANT, AND i settlement agreement date May 16, 2001, is hereby incorporated, but not merged, with this decree. THE COURT RETAINS J,URISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; .)J();.Q J. . . . . . ;!,'-; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . s . . . . . . . . . . . . . . . . . . . . . . . . . . , " ,c",c', ,,/. "-". , I ~< ~,~~~ .f02S-0(M~~ ~~~ f.$<CJ( ~~'~ ~ :d-~" {td7 ~ r4' ,/P? ~ I" ~) l ~ ~ ,~~ ~,~ ,." . .~~~,~.~!rBj~"",_~"",~~,~ ~!IJtJ n.~"""",,< ~'-TT " ___ ! '.': tit' DANIEL LEE PEIPER, Plaintiff : IN THE COURT OF COMMON PLEAS vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 6/~ .t'"?S Ctu(l C J~ GAY KAREN PEl PER Defendant : CIVIL ACTION-LAW 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 otherclaim 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, Cumberland County Courthouse, One Courthouse Square, Carlisle. PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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 Lawyer Referral Service 2 Liberty Street Carlisle, PA 17013 (717) 249-3166 i _' '-L-'," -, "o.'''='_~,__ j, DANIEL LEE PEIPER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: GAY KAREN PEl PER Defendant CIVIL ACTION-LAW NOTICE OF AVAilABILITY OF COUNSELING TO THE WITHINNANlED DEFENDANT You have been named as a Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with ~3302(c) or (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Cumberland County Courthouse, Cumberland County, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ~ I ~i ~ ~""< DANIEL LEE PEIPER, Plaintiff IN THE COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY, PENNSYLVANIA NO: 19 1- ort;' ~T-4--. GAY KAREN PEIPER Defendant CIVIL ACTION-LAW COMPLAINT 1 . Plaintiff is Daniel Lee Peiper, who currently resides at 52 Mont Sera Road, Carlisle, Pennsylvania, 17013. 2. Defendant is Gay Karen Peiper, is an adult individual, who currently resides at 52 Mont Sera Road, Carlisle, Pennsylvania, 17013. 3. The Plaintiff has been a bona fide resident(s) in the Commonwealth for at least six (6) months immediately previous to the filing of this Compiaint. 4. The Piaintiff and Defendant were married on May 14, 1994 In Gardners, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff in this action is not a member of the Armed forces. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to 4." I " " - ,~ =~-,-w lWI'k participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to the divorce decree being handed down by the court. 9. The Plaintiff is irretrievably broken. WHEREFORE: The Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted. Jo n A. Abom, Esquire Attorney for Plaintiff 8 South Hanover Street Suite 204 Carlisle, P A 1 7013 , .,.it-, , , , ." '. DANIEL LEE PEIPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO: GA Y K. PEl PER, Defendant : CIVIL ACTION-LAW VERIFICATION I verify that the statements made in the foregoing complaint and divorce are true and correct. I understand that false statements herein are made subject to the penalties 18pa. c. s. 94904, relating to unswom falsifications to authorities. DATE: i/< '(,/o( v~~ -- .- Da;1ei Lee Peiper -::-_1 =.1 ._~ i '- -, '._w ~~ ~~".~""-'- DANIEL LEE PEIPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA s. NO: Gay K. Peiper Defendant CIVIL ACTION-LAW CERTIFICATE OF SERVICE AND NOW, thisdi day of January, 2001, I, John A. Abom, Esquire, hereby certify that I did serve a true and correct copy of the foregoing Complaint in Divorce, a Notice to Defend and Claim Rights and a Notice regarding the availability of counseling by mailing the same by regular, first class mail and by restricted, certified mail, return receipt requested, addressed as follows: By Certified Mail to: Gay K. Peiper 52 Mont Sera Rd. Carlisle, PA 17013 ~- C_____ A. Abom, Esq ,~ " ,,, < ";; - T~'\' 4 " DANIEL LEE PEIPER, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-585 CIVIL GAY KAREN PEl PER, Defendant. CIVIL ACTION - LAW AFFIDAVIT OF SERVICE I. John A. Abom, hereby certify that I served a true and correct copy of the Complaint Under Section 3301 (cl of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached receipt card on February 2, 2001. Respectfully submitted, ABOM & KUTULAKIS Date: February 13, 2001 / (.__d.' Joh 'A. Abom, Esquire orney I.D. No: 77961 Suite 204 8 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff - l.............. "~ ,. ~ i j" ~.~ ,~.; .. -, - ~ - - ~- il j . I" r (DomestIc Mall Only; No Insurance Coverage ProvIded) I"- CI <0 =t- .-'l I"- U1 .-'l Certified Fee a- Return Receipt Fee o (Endorsement RequIred) CI CI CI ru ru ITl 0- 0- ~ciii.siaie:'iip~~4---".._---'----_'.___A".___-------'-h--.U_____u___u____...d__.____..w PS Form 3800, JUly 1999 See ReV0r"e for i 1St ,lctIons . -- :-~-" - '- :-- .': -- --~;" , ': ' ".,,~:, , Compiete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print you'r name and address on 'the reverse so that we can retLirn' the card to you. . Attach this card to the back of thl3i' m~,Yprege, or on the front if space per:m,rt;. f:;jil'i." 1. Article Addressed to: 6C/kf{ft~ .,\5';). ~~ Rr/. (! 44-l,~re ~'!- ; lOr 3 3, Service Typ ~ified o Registe D Insured~ .".....',.". '. ..l.....~ PS Form 38. ~-^ '" ' ," ['j , J."" . " . ii!!j;A-h't~'iMlIfm~i&'iiilllil'i "-'" 'Iii ~ ~ ~~~~i~. ; ~"-.-. .,-,,-'......" . , , ~II d" ~ -,., [ ..'",,",~ i , ~ ~ I' " " [ " i /1 (} Cl ,~ C ~, :c- "T] v;.~ ..." 52~t ("T1 ',' 0 -, ,:-p ,- z~ :"1 (f) )~ " .---i ~2:' ..- , '1~ .-:::.~ ,"", ::::::~") ,~ 4(; "'" " c, 3: .::::;y T ;."-:,~~ ~CI / t(; '- <....,/ Z ::...> >....: ::2 :D -..! -< ~~ ., , ~ J "0" . ,. , DANIEL LEE PEl PER , Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-585 Civil GAY KAREN PEl PER, Defendant. CIVIL ACTION - LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under 93301(c) of the Divorce Code was filed on January 29, 2001. 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 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: :) )b~ / . s~- -,;-:-1 I. i ^_ >.1 ,_ 1 "_ .=~"'~" , DANIEL LEE PEl PER , Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-585 Civil GAY KAREN PEl PER, Defendant. CIVIL ACTION. LAW 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 of 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 Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: 5/fG pi 5:)::-- _~ Daniel Lee Peiper .... '" d ,~ ~ ~_."" ,-~, - ",,~~-,. . ~ ill"""" uilli1l.. ~F'''''''''''''~lI!iI~llii;;t;r''''''''''.fuJf!'';W'''-'''''5!;\Wl''~';;;'i~Bl\IdU > ~_, ~"" ^~ ~,_, 4 ..~ ~ "I -,'. -,. lli -~-~",.......".,,-,....~'t~ , ~""',.. ~, , lIII C') c: "TJ ~~ n-lr~; 2:" zt (0--::,. f;J c~: $C' "',:0 ""c: 2: ::< c 3: ~::;'" c,) . , ~ ::::> en =: , ~-~ ~ 'l~': ~~ ~ -< J'" ,__I~~~. ~_" . " .1 I~ ~- ._~!,: , DANIEL LEE PEl PER , Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-585 Civil GAY KAREN PEl PER, Defendant. CIVIL ACTION. LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on January 29, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. /' Date: ~vllo-()I ~ tool1 ~ Gay aren Peiper ': l<ilili !1i_i4itV'~ -"'.----~'. I;I!f<lM'~b"-,,,j,'~h~<r"l'J-M;;.$Wifiili~!JU -~-~ ,. ."""""".....'r..""~- -,- ,,,,,,,,,," r .lI:ii..ilifil~~" '" ~..",'~" o s ;i?&~ ~rn 0~ t;;::c5 .?3c:, s;:cs r:= ~ -< ". 'I " , r-c'. :~~ co -';':': ~) .. o (..t'l ~ , ~--~ I """'- , '_,I _ - __n, ~ ~'~:r . , DANIEL LEE PEl PER , Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01.585 Civil GAY KAREN PEl PER, Defendant. CIVIL ACTION - LAW 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 of 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 Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. '" Date: la'/{er or ~Ofl1Jl~J Gay K en Peiper ~~"" 'w......,""'~L;j~~Jtiti ' ~ -~"~,,, -~ - ,.~" ..- -. 'Jji_~11!i_1!I.t::;l{ilf4.U~~:.."'tt~lci""M;~;I.\""'- -0" 'Lt"' ,-,;' -=,=-~ -, . , .~"' . ,._~-". ,,, " .. -" - , " ' <~.~~,"~ ?, ~. JU' ,--I - ~ ,- ~-"< '", >~-~ (") ~~3 [11\": ~Zrc ~1'~~; C..-- ~~-~" '-.,' -0 :;Pc: ~ ~ -< ..,....."..;.l4d'.....".., . "', '. -~-! . , C1 () "!'" -"" c;r:.} -\, ~..) o 01 if ~'_..J~"~' ~ " = ..r. _{. l'- ~ ~ , ' -~ ...,. "'" , DANIEL LEE PEIPER , Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-585 Civil GAY KAREN PEl PER, Defendant. CIVIL ACTION - LAW PRAECIPE TO TRANSMIT THE 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 9(3301 (c)) of the Divorce Code. 2. Date and manner of service of the complaint: February 2, 2001 by certified mail, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff 5/16/01 by defendant 5/16/01 (b)(l) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: None ,~-~~~~~ ., I j . "'._ - i ~_;_"_:,,_ _ _ --" \_,C ,t-e ....;1 -:., . 5. (Complete either paragraph (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: 5/17 /01 Date Defendant's Waiver of Notice in 93301 (el Divorce was filed with the Prothonotary: 5/17 /01 Respectfully submitted, ABOM & KUTULAKIS Date: May 18,2001 J n A. bom, Esquire Attorney I.D. No. 77961 Suite 204 8 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ~~~roil@jfl!f';'_'BJd~~~iMl:i"'-fu;H:~"",~.l;;"41;il"fl:',II<;>;_m,,~d." ~ ~Lf ,0~. O~ _0_="""'''' "^'o.,,,~_.~" ~^ _"O'~ ~ "''''',,,L ,_"". "',~,,"',," .., ","'L._""t0-"',".~~_" .__, ~ -. ..'~ () C- uf; flll< 2::. :']~ -:;"C' 0~> ~(S- ;@C') 5>0 c ::::: :< ~,,'~ ,I ..- .., , ",',',' i..~,) -~ ";."" c) ~;' :::> Q, '" .. L. ,-' [