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Home My WebLink About99-02948 I i? ?? ?. ,,, }'ti jl,?', ,?: [;r; I t +7@: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNSYLVANIA 99-2948 CIVIL No TERM ......................... .................. DECREE IN DI V 0 R C E AND NOW, ... cp1Ct?.? ..ZS...... 19.99..., it is ordered and decreed that MATTHEW, A... Pj41UP . . ..... . ........... . plaintiff, MARY A. KEMPER defendant, and ............................ ........................... 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 ........................................................................... By The Alter ..I ,y ?w 4W 4014& 40. +7m: 4* 4W •710. -M d* {a6 -= W %V •A., c.. ,.. 4 Prothonotary Ac, Ar. ze, W, ?/fGZc?? LA ?? ??1? ? ?? ??? MATTHEW B. KEMPER, " IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION MARY A. KEMPER, Defendant NO. 99-2948 CIVIL TERM 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 53301(c) Mkbd*kb:Cof the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Service was accepted by Richard S. Friedman, Esquire, attorney for Defendant, on Mdjy ldo plete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 53301(c) of the Divorce Code: by plaintiff 9/22/99 by defendant 9/3/99 (b)(1) Date of execution of the affidavit required by 53301(d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: None S. Complete either (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 53301(c) Divorce was filed with the Prothonotary: September 24, 1999 _ Date defendant's Waiver of Notice in 53301(c) Divorce was filed with the Prothonotary: - September 24, 1999 Date: September 29, 1999 Attorney for (Plaintiff)QDU%utXkX)* Marlin R. McCaleb, Esquire cs' u?<5 c! ?G c3: U 1 [. ?_ s 1 cn LL Ck- Ua pl. C,rj a- u- C) rn Cl CJ MATTHEW B. KEMPER, Plaintiff VS. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-@qq- ° CIVIL TERM CIVIL ACTION - 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. If the ground for the divorce is indignities or irretrievable breakdown of the marriage, 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 marriage counselors is available in the Office of the Prothonotary at Cumberland County Court House, Carlisle. 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 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 TARE 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LAW Oll IC1 MANLW W MrCALLII Marlin R. McCaleb Attorney for Plaintiff MATTHEW B. KEMPER, Plaintiff VS. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-.19`/V CIVIL TERM CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 330111111(c) OR 3301 d OF THE DIVORCE CODE 1. Plaintiff is MATTHEW B. KEMPER, who currently resides at 8 Summer Drive, Dillsburg, York County, Pennsylvania 17019, since April 1, 1994. 2. Defendant is MARY A. KEMPER, who currently resides at 19 Gettysburg Pike, #8, Mechanicsburg (Upper Allen Township), Cumberland County, Pennsylvania 17055, since on or about March 1, 1999. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 24, 1990, in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court LAW OI ILL.', require the parties to participate in counseling. MARLIN H. M,CAL1E13 -2- 8. Plaintiff requests your Honorable Court to enter a decree of divorce. 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. Matthew B. Ke per, Plaintiff Date: May 14, 1999 Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiff LAW 0$ 1 It I MARLIN 11, MCCALLR -3- II° MATTHEW B. KEMPER, Plaintiff Va. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-.?95/.F CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Matthew B. Kemper, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the office of the Prothonotary, 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 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. Date: May 14 1999 -y 6'a,,. Matthew B. Kemper, Plaintiff. IA. „111. 1-. MANIIN 11 . M,CAi.GB E., c? Ly L mm ?' I• ?... 00 q9 W w C I w. w z PQ +J 0 ? ro a q roi H W 4, L w A t i ?l z W w N ai E x F 0 a ti ° H m > U \ W z N 2 o u Q x z Q W J y 0 U Y Q ° m z W m m u i ° N U Z W s 1 MATTHEW B. KEMPER, Plaintiff VS. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2948 CIVIL TERM CIVIL ACTION - IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE AND ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: Please enter my appearance for and on behalf of Mary A. Kemper, the Defendant in the above-captioned action. I hereby accept service of the Complaint in Divorce on behalf of Mary A. Kemper, Defendant herein (and certify that I am authorized to do so) and I acknowledge receipt of a true copy of same. Date: , , 1999 Friedman & Friedman, F.C. 600 North Second Street Fifth Floor P.O. Box 984 Harrisburg, Pennsylvania (717) 236-8000 FAX: (717) 236-8080 Attorney for Defendant 17108 I.M1W Of ill L} MARLIN H. WCALM L JI ;- 1i- LI fll ' ?. ) G • l SARAH M. RICHIE, Plaintiff V. ERIC A. ROBISON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 99- 3D/9 : IN CUSTODY CIVIL TERM ORDER OF COURT AND NOW, 5(a0 1999, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel ap ear before ?1(a?J {%_,Lry the c$nciliator, at t?lk 1 . on the :??r day of ll ne _ ,1999, at 111,06 am., fora Pre-H wring Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Byc Custody Conciliator ` The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 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 TELEPHONE: (717) 249-3166 cc: Lindsay D. Baird, Esquiretlp?p? Eric A. Robison nus 5/1y/g? (*V" r. I I (JC'r ()9 ,".," IZ' f1 ! SARAH M. RICHIE, Plaintiff V. ERIC A. ROBISON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 99- 3 W 7 CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Sarah M. Richie, residing at 120 G Street, Carlisle, Cumberland County, Pennsylvania. The defendant is Eric A. Robison, residing at 210-B Lincoln Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Residence Aga Brianna Elaine Robison 120 G Street, Carlisle, PA I Yr. 9 Mo. The child was born out of wedlock. The child is presently in the custody of mother. During the past one year and nine months, the child has resided with the following persons and at the following addresses: Person Address Dates Mother, father & maternal grandfather Greensboro, N.C. 8.22.97 - 6-1-98 Mother, father & maternal 2nd cousin Ridge St., Carlisle, PA 6.1-98 - 10-1.98 Mother &. Father 210-B Lincoln St. Carlisle, PA 10.1-98 - 5-5-99 Mother & family 120 G St., Carlisle, PA 5/5/99 - present The mother of the child is Sarah M. Richie, currently residing at 120 G Street, Carlisle, PA. She is unmarried. The father of the child is Eric A. Robison, currently residing at 210-B Lincoln St., Carlisle, PA. He is unmarried. 4. The relationship of plaintiff to the child is that of mother. The plaintiffs household includes: Name Relationship Sarah M. Richie Mother Brianna Elaine Robison Daughter Joan Crowl Maternal Grandmother Jack Crowl Maternal Grandmother's husband Michael Richie Maternal Uncle Dustin Crowl Jack Crowl's son Ian Crowl Jack Crowl's son . Ryan Crowl Jack Crowl's daughter 5. The relationship of defendant to the child is that of father. The defendant's household includes: Name Relationship Eric A. Robison Father 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; b) Plaintiff is willing to accept custody of the child; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant her custody of the child. v/Iindsay Dare Ilaird, Esquire 37 South Hanover Carlisle, PA 17013 Attorney for Plaintiff I verify that to the best of my knowledge and belief, the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of I8 Pa.C.S.§4904 relating to unsworn falsification authorities. A Sarah M: Rrchie, Plaintiff ` ?` r.? ?, ?: - _; .( --!?? : - ffi?? ?? IP ?^\ ,?? ,v V MATTHEW B. KEMPER, IN THE COURT OF Plaintiff COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW MARY A. KEMPER, NO. 99 - 2948 CIVIL TERM Defendant CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER X3301 (c) OF THE n1VORCE 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, lawyers 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. 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. C .? Date:'-` 1999 Mary A. Kemper, Def ndant «n CV ?E C?j `L C4 Vi a% U MATTHEW B. KEMPER, Plaintiff vs. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 2948 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on may 14, 1999, and service was accepted by Richard S. Friedman, Esquire, Attorney for Defendant, on May 19, 1999. 2. The marriageof Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. I am not a member of the armed forces, nor in active military service, of the United States of America or the Commonwealth of Pennsylvania or any other state or country. 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: 1999 ?- \ !) n '? Sy"- Mary AK?emper, Defe dant F N ! 2 ? L' d._ C1: J i'.1 ISJ N T.f% U MATTHEW B. KEMPER, Plaintiff VS. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 2948 CIVIL TERM CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301 (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. 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: / - 2-2 1999 /emu -0e Matthew B. Kemper, Plaintiff LAW IN 1111-1 MA14LIN N. MtCALf_11 N r ? U1 % U?q .r Ua ??C_• :P I Yi7) C J S ? MATTHEW B. KEMPER, Plaintiff VS. MARY A. KEMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 2948 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 14, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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., Section 4904, relating to unsworn falsification to authorities. Date: 1 ZZ 1999 ze/?" Matthew B. Kempe , Plaintiff IAW Mf.1 , MARLIN N. M,CALC? N v ZI: ( li'1 ! - I -?; Lt:_ .. C Q L . F= J v; U.. O ? (J