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Home My WebLink About03-4078HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : :CIVIL ACTION LAW- DIVORCE NO. 03- qO?PClVIL 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland Connty 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. HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA :CIVIL ACTION LAW- DIVORCE : : NO. 03- CIVIL TERM O_1 - COMPLAINT The plaimiff, HarD' Bishop, Jr., by his attorneys, the Family Law Clinic, sets forth the following cause of action: DIVORCE UNDER 23 Pa.C.S. SECTION 3301 (c) AND 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Harry Bishop Jr., who currently resides at 3780 Spring Road, Carlisle, Cumberland County, Pennsylvania, 17011. 2. Defendant is Edith M. Bishop, who currently resides at 1318 Kittatinney Road, Harrisburg, Dauphin County, Pennsylvania, 17011. 3. Plaintiff has 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 January 17, 1981 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since July of 2001. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, plaintiffrequests the court to enter a decree in divorce dissolving the marriage. Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Harry Bishop, Jr. HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA :CIVIL ACTION LAW- DIVORCE : NO. 03-ttcaF CIVIL TEm' PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Sherif: Kindly allow Harry Bishop, Jr., Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceed'rog in forrna pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attomeys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND ,COUNTY, : PENNSYLVANIA : :CIVIL ACTION LAW- DIVORCE : : NO. 03- 4078 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject The Family Law Clinic to the penalties of 18 Pa. C.S. §4904 (relating to unsworn falsification to authorities), the undersigned verifies that Lara Mammana mailed a true copy of a Divorce Complaint to the Defendant by placing the same in the U.S. Mail, certified no. 7000 1670 0001 8783 0000, restricted delivery, return receipt requested, postage prepaid, on the 25~h, day of August, 2003 addressed as follows: Edith M. Bishop 1318 Kittatinney Road Harrisburg, PA 17104 Sender's receipt no. 7000 1670 0001 8783 0000 is attached hereto and incorporated by reference. On the 8 day of September, 2003, green return receipt no. 7000 1670 0001 8783 0000 was delivered to the Family Law Clinic, bearing the signature Edith M. Bishop and showing a date of service of September 6, 2003. The return receipt is; attached hereto and incorporated by reference. Lara Mammana Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17(}13 717-243 -2968 · Complete Items 1, 2, and 3. ~ complate Item 4 if Restricted Delivery ia deelrad, · Print your name and address an the reverse so that wa can return the card to you. · Aflach this card to the back of the mallptane, or on the front If space permits, 1. Article Addressed to: C. Signature _ × ~ j,.2,j.~o r',.~; .- D. ~ d~k~V ~ d~e,~t fm.~ r~n l? rny~ If YES, enter dellv~y addrea~ below: [] NO i"l ~xprea~ Mall ~ Receipt for Merchandise [] C.O,D. "':"'""'~':'flf',tWa'H'T [ ~! lift Il [,~! IIIbl I.U i ~ ~ 102595-99-M-1789 HARRY BISHOP, JR. Plaintiff V. EDITH M. BISHOP, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : CIVIL ACTION-LAW : DIVORCE AND CUSTODY : : No. 03-4078 CIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated in July 2001 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 unswom falsification to authorities. D~te / ~ Harry Bistl~op Plaintiff HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : NO. 03-4078 CIVIL TERM CERTIFICATE OF SERVICE I, Jason C. Evans, hereby certify that I am a competent adult and that I served via U.S. Mail Postal Service a true and correct copy of the Plaintiff's Affidavit to, EDITH M. BISHOP, 1318 Kittatinney Road, on February 12, 2004. I verify that the statements made in this certificate are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. Date: 7-- IZ-geoq JcaeS~l e~ ~ i~nte m~g~ ~HOM~ ~. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CL1NIC 45 North Pitt Street Carlisle, PA. 17013 717-243 -2968 HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP Defendant To the Prothonotary: : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA :CIVIL ACTION LAW- DIVORCE : NO. 03-4078 CIVIL TERM PRAECIPE TO TRANSMIT RECORD Please transmit the record, together with the following information to the court for entry ora 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: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid, Service was complete upon receipt by Defendant on September 6, 2003. 3. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: by the Plaintiff.' February 10, 2004, Date of filing and service of the Plaintiff's affidavit upon the Defendant: February 12, 2004 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record a copy of which is attached: March 4, 2004 regular mail. Date Respectfully Submitted, Jaso~lC. Evans Certified Legal Intern ~?? ~(/YlS~C~D ON^LD -F OX LUCY JOqqNSTON-WALSH ROBERT E. RAINS THOMAS M. PLACE Supervising Attorneys The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW IN DIVORCE NO. 03-4078 CIVIL TERM CERTIFICATE OF SERVICE I, Jason C. Evans, hereby certify that I am a competent adult and that I served a true and correct copy of the Notice of Intention to Request Entry of § 3301 (d) Divorce Code and Defendant's Counter-Affidavit under §3301(d) of the Divorce Code on EDITH M. BISHOP by U.S. mail, addressed to Defendant at 1318 Kittatinney Road, on March 4, 2004. I verify that the statements made in this certificate are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. ~atr~fieC~ ~;;: Intern LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 HARRY BISHOP, JR. Plaintiff EDITH M. BISHOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL ACTION - LAW IN DIVORCE : NO. 03-4078 CIVIL TERM CERTIFICATE OF SERVICE I, Jason C. Evans, hereby certify that I am a competent adult and that I served via U.S. Mail Postal Service a true and correct copy of the Plaintiff's Affidavit to, EDITH M. BISHOP, 1318 Kittatinney Road, on February 12, 2004. I verify that the statements made in this certificate 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. isoa, e. Evans Certified Legal Intern THO~M ~I'. PLACE THOM ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 HARRY BISHOP~ JR.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. PLAINTI~E VERSUS _ EDTTH M. RTSH~p, DEFENDANT NO. 4078 2003 AND NOW, DECREED THAT DECREE IN T IS ORDERED AND _ HARRY BISHOP~ JR. ~, PLAINTIFF, AND EDITH M. BISHOp , 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; NONE