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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
ANGELA SHOPE
PLAINTIFF
.........................................................
Versus
CHRISTOPHER SHOPE
............................................ _ ..... ......
DEFENDANT
............................ ... ....
..............
N o. .3.0.8.9 ............ CIVIL..... 1%9
.......... !.
DECREE IN is
D I V O R C E J 3P? PM?
AND NOW, . •• ....t...... ..., it is ordered and
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4 plaintiff,
s decreed that ... • . • ....... ANGELA SHOPE
...............
6
and . . . . . . . . . . . . . .. . .. . . . . CHRISTOPHER,$HOP,E, • , , , • , , . , • . • .. • defendant, ?-
e .......
••.% are divorced from the bonds of matrimony. o
l:
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;
e NONE
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ANGELA M. SHOPE,
Plaintiff
V.
CHRISTOPHER SHOPE,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 99-3089 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
Please 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(d) of the
Divorce Code.
2. Date and manner of service of the complaint: Christopher Shope accepted service
on July 28, 1999.
3. Date of execution of the Plaintiffs Affidavit required by § 3301(d) of the Divorce
Code: February 2, 2000; Date of service of the Plaintiffs Affidavit upon the
Defendant: February 2, 2000, as evidenced by the Certificate of Service filed on
February 2, 2000.
4. Related claims pending: There are no related claims pending.
5. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached: United States mail, first class, postage prepaid
on February 22, 2000.
Date 3 -awo
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
Supervising Attorney
DONALD MARRITZ
Staff Attorney
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ANGELA M. SHOPE,
Plaintiff
V.
CHRISTOPHER SHOPE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, CUSTODY
NO. 99-36 fr'9 CIVIL TERM
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 the 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,
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
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.
ANGELA M.SHOPE,
Plaintiff
V.
CHRISTOPHER SHOPE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, CUSTODY
NO. 99-369q CIVIL TERM
COMPLAINT FOR DIVORCE UNDER 23 Pa.C.S. §S 3301(c) and 3301(d)
AND FOR CUSTODY
The plaintiff, Angela M. Shope, by her attorneys, the Family Law Clinic, sets forth
the following cause of action:
COUNT I.
DIVORCE
1. Plaintiff is Angela M. Shope, who currently resides at 1 West Penn Street, Apt.
101, Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant is Christopher Shope, who currently resides at 24731 County Road,
13C, Mathis, Texas, 78368.
3. Plaintiff has been a bona fide resident of Cumberland County and the
Commonwealth for at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on May 5, 1995 in Carlisle,
Pennsylvania.
5. Plaintiff and defendant have lived separate and apart since January 8, 1998.
6. There have been no prior actions of divorce or for annulment between the panics.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that plaintiff or
defendant may have the right to request that the court require the parties to participate in
counseling.
WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
,marriage.
COUNT IL
CUSTODY
9. Plaintiff repeats and reallege paragraphs one through eight.
10. Plaintiff seeks custody of the following child:
NAME PRESENT ADDRESS D.O.B.
Cierra Shope 1 West Penn Street, Apt. 101 7/18/91
Carlisle, PA 17013
The child was born out of wedlock.
The child is presently i n the custody of Angela M. Shope, who resides at 1 West
Penn Street, Apt. 101, Carlisle, Cumberland County, Pennsylvania 17013.
For the last five years, the child has resided with the following persons and at the
following addresses:
PERSONS ADDRESSES DATES
Angela M. Shope Fry Loop 4/94 - 5/31/97
Christopher Shope Carlisle, PA 17013
Angela M. Shope 2218 A Shadow Valley Rd. 6/1/97 - 10/15/97
Christopher Shope NC
Angela M. Shope 36 Spinnaker Walk 10/16/97 - 11/15/97
Traci Jenkins Savannah, GA
David Cheek
Angela M. Shope 96 Winchester Gardens 11/16/97 - 11/15/98
Carlisle, PA 17013
Angela M. Shope 1 West Penn Street, Apt. 101 11/16/98 - present
Carlisle, PA 17013
The mother of the child is Angela M. Shope, currently residing at 1 West Penn
Street, Apt. 101, Carlisle, Cumberland County, Pennsylvania 17013.
She is married to Defendant.
The father of the child is Christopher Shope, currently residing at 24731 County
Road, 13C, Mathis, Texas 78368.
He is married to Plaintiff.
11. The relationship of the plaintiff to the child is that of mother. Plaintiff currently
resides with the following persons:
NAME
RELATIONSHIP
Cierra Shope Daughter
12. The relationship of the defendant to the child is that of father. Defendant
currently resides with the following persons:
NAME RELATIONSHIP
Rose Cook Mother
Gordon Cook Stepfather
Jerry Shope Brother
Alex Shope Brother
13. 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 nor 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.
14. The best interest and permanent welfare of the child will be served by granting
the relief requested because:
a) Plaintiff has been primary caretaker of the child since birth;
b) Plaintiff provides the child with a home with adequate normal, emotional and
physical surroundings as required to meet the child's needs;
c) Plaintiff is willing to accept custody of the child;
d) Plaintiff continues to exercise parental duties and enjoys the love and affection of
the child.
15. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child has been named as parties in this action.
WHEREFORE, plaintiff requests the court to grant her shared legal and primary
physical custody of Cierra Shope, with defendant having liberal periods of partial custody.
Date 1799
? / tt?l
TKIMBERLY DARDI, G
Certified Legal nern
THOMAS M. PLACE
ROBERT E. RAINS
Supervising Attorney
DONALD MARRITZ
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle. PA 17013
717/240-5204
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VERIFICATION
I verify that the statements made in this Divorce and Custody Complaint are true and
correct to the best of my personal knowledge and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn
falsification to authorities.
Date:
M.SHOPE
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ANGELA M. SHOPE,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, CUSTODY
CHRISTOPHER SHOPE,
Defendant
NO. 99-3089 CIVIL TERM
NOTICE TO DEFENDANT
If you wish to deny any of the allegations set forth in this affidavit, you must file a
counteraffidavit within twenty days after this affidavit has been served on you or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated January 8, 1998, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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. §4904, relating to
unsworn falsification to authoritie
Date U
4
? U
7 J
7
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ANGELA M. SHOPL'-,
Plaintiff
V.
Cl IRISTOPIIER SHOPE
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 99-3089 CIVIL TERM
NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE
TO: Christopher Shope:
You have been sued in an action for divorce. You have failed to answer the complaint
or file a counter-affidavit to the plaintiff s affidavit. Therefore, on or after March 13, 2000, the
plaintiff can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the court can enter a final decree
in divorce. Unless you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief.
A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE
PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
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.
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ANGELA M. SHOPE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE, CUSTODY
CHRISTOPHER SHOPE,
Defendant NO. 99-!3-PCIVIL TERM
ACCEPTANCE. h ER I F
i accept service of the Complaint in Divorce and Custody filed in this matter.
Date 7??8-?7f
Christophc Shope
24731 County Road, 13C
Mathis, TX 78368
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ANGELA M. SI101'Ii,
Plaintiff
CI IRISTOPIIER SI IOPE,
Dclcndant
IN'TIiE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, CUSTODY
NO. 99-3089 CIVIL TERM
CERTIFICATE OF SERVICE
I, Cindy A. Sheridan, Certified Legal Intern, Family Law Clinic, hereby certify that I
have served it true and correct copy ofthe Plaintiffs Affidavit on Christopher Shope, residing
at 8729 Granite Street, Apl, 111), Baton Rouge, LA 70810, by this date placing the same in the
United States null, first class, postage prepaid.
Dille p
Cindy heridan
Certified,Degal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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ANGELA M. SHOPE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN DIVORCE
CHRISTOPHER SHOPE,
Defendant NO. 99-3089 CIVIL TERM
CERTIFICATE OF SERVICE
I, hereby certify that I have served a true and correct copy of the Praecipe to Transmit
Record and Vital Statistics form on Christopher Shope, at 8729 Granite Street, Apt.#D, Baton
Rouge, LA 70810, by this date placing the same in the U.S. mail, first class, postage prepaid.
Date J-DO-0y
Cindy A. eridan
Certified gal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Fax: (717) 243-3639
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SEP 21
ANGELA M. SHOPE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
: IN CUSTODY
CHRISTOPHER SHOPE,
Defendant NO. 99^x"" CIVIL TERM
CUSTODY AGREEMENT
THIS AGREEMENT, made this pN+a day of Se kpM))2r , 1999,
between plaintiff, Angela M. Shope, hereinafter (mother), and
defendanc, Christopher Shope, hereinafter (father), concerns the
custody of the child: Cierra Shope, born 7/18/91.
Mother and father desire to enter into an agreement as to the
custody of the child and to have this agreement made an Order of
Court. Mother and father agree to the following:
1. The parties shall share legal custody of the child.
2. The mother shall have primary physical custody of the
child.
3. The father shall have the right to partial physical
custody at times mutually agreed upon by the parties.
4. The non-custodial parent shall be entitiled to reasonable
telephone,access with the child.
5. The parties shall keep one another advised of their
current address, home telephone number and work phone number.
6. The father and mother will notify each other of all
significant medical care which the child receives while in that
parent's care. Each parent will notify the other as soon as
possible of medical emergencies involving the child which arise
while the child is in that parent's care.
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7. Neither party will do anything which may estrange the
child from the other parent, or injure the opinions of the child as
to the other parent or which may hamper the free and natural
development of the child's love and respect for the other parent.
8. The father acknowledges that he has been informed that
the Family Law Clinic represents only the mother in this case and
that the Family Law Clinic has given him no legal advice other than
to seek his own counsel.
9. The parties intend to be legally bound by the terms of
this agreement and agree that it shall belmade on Order of Court.
Ch.'stopher Sh e
Defendant
gel M.
ain iff
/Kinhberly D. Harding
Certified egal Inte n
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Thomas M. Place
Robert E. Rains
SUPERVISING ATTORNEY
Donald Marritz
STAFF ATTORNEY
FarI= CL1" .i1C
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Counsel for Plaintiff
ORDER
AND NOW, this day of
Agreement is approved and entered
1999, the foregoing
an a/e/cf/ourt.
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