HomeMy WebLinkAbout07-2949
LORI DUNCAN,
Plaintiff
V.
DONALD L. DUNCAN, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action- Law
No. 07 - .?, gqq
(2 t-c..,z L
IN DIVORCE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
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 also 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle.
IF YOU SO 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 LAWYERAT 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.
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 atrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. oZgyc?
DONALD L. DUNCAN, JR.,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(c) or 3301(d)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Lori Duncan, by and through his counsel,
Michael J. Whare, Esquire and avers as follows:
1. Plaintiff is Lori Duncan, an adult individual, who currently resides at 15
Roxbury Road, Newville, Cumberland County, Pennsylvania.
2. Defendant, Donald L. Duncan, an adult individual who currently resides at 52
West Main Street, Newville, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents in the
Commonwealth for at least six months immediately previous to the filing of this
Complaint.
4. Plaintiff and Defendant were married on May 12, 2001, in Newville,
Cumberland County, Pennsylvania and separated on or about May 12, 2005.
5. There have been no prior actions of divorce or annulment between the parties
hereto in this or any other jurisdiction.
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 require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
Decree in Divorce and such other Orders as may be just and appropriate.
Date: 1-/ 7" 0 7
Respectfully submitted,
10w4-%J /) ?vA
Michael I Whare, Fi6quire
Attorney for Plaintiff
37 East Pomfret Street
Carlisle, PA 17013
Supreme Ct. Id No. 89028
(717) 243-3561
LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
DONALD L. DUNCAN, JR.,
Defendant
: No.
IN DIVORCE
VERIFICATION
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. §
4904 relating to unsworn falsification to authorities.
Date: 5 / 7 6 /
Lori Duncan, Plaintiff
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LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07- a4y9 ??? ???.
DONALD L. DUNCAN, JR.,
Defendant
IN DIVORCE
AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. The parties to this action separated on May 12, 2005 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 Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
4904 relating to unworn falsification to authorities.
Date: j i 7 zn LoDar6n, Plaintiff
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LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
DONALD L. DUNCAN, JR.,
Defendant
No. 07-2949
INDIVORCE
AFFIDAVIT OF CONSENT
4. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
May 18, 2007.
5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing the Complaint.
6. 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. §
4904, relating to unworn falsification to authorities.
Date: d O?? D ` -
ori Dun aintiff
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77
LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-2949
DONALD L. DUNCAN, JR.,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
2. 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. §
4904, relating to unsworn falsification to authorities.
Date:
Lori aintiff
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LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-2949
DONALD L. DUNCAN, JR.,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
May 18, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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. §
4904, relating to unsworn falsification to authorities.
Date: e? 415- , 0 x Q- 'J,
onald L. Duncan, Jr., Defendant
Feb-" Q c09
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COMMONWEALTH OF PENNSYLVANIA
:4NOTT IAL. SEAL
BAR BARA AKE, Notary Public couti
May Commxpo es?Aug. 8 2011
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CA 7
LORI DUNCAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
DONALD L. DUNCAN, JR.,
Defendant
No. 07-2949
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 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. I
understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §
4904, relating to unworn falsification to authorities.
Date: :)` /S - 0 O
Donald L. Duncan, Jr., Defendant
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KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQUIRE
ATTORNEY ID 92207
4660 TRINDLE ROAD, SUITE 201
CAMP HILL, PA 17011
(717) 761-7573
COMMONWEALTH OF PENNSYLVANIA,
V.
TRACY LEE DURF,
Attorney for Defendant
FEB 212008A'Y
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.3170-CR-2007
ORDER
AND NOW, this 224day of [;!L , , 2008, upon filing of Defendant's Omnibus
Pretrial Motion, a hearing is scheduled on said motion to be held on the ??,d4 day of , 2008,
at q 36 o'cloc a.m. pa in Court Room No. at the Cumberland County Courthouse.
Cc: Shane B. Kope, Esquire, 4660 Trindle Rd., Ste. 201, Camp Hill, PA 17011
Daniel J. Sodus, Esquire, DA's Office
Clerk of Courts
Court Administration
Defendant.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action- Law
No. 07-2949
IN DIVORCE
'ROOF OF SERVICE
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
L-U121 I)UNC-AN
PLA-XNTYFF
VERSUS
bON A L F-) L-b! /L146.,_
UE NDANT
No. d007 --aq qq ?=vr? TE?wi
DECREE IN
DIVORCE
AND NOW,
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IT IS ORDERED AND
DECREED THAT L-oR= bUNc-pA/ , PLAINTIFF,
AND D0/VA 4-r) L DUAICA&Z 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;
PROTHONOTARY
oNE,
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