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Home My WebLink About07-4742TIMOTHY D. MARPOE, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW 2007 - ~7 5j~ CIVIL TERM CRYSTAL A. MARPOE, Defendant. IN DIVORCE 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 in 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 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 17013. 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABII.ITIES 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. TIMOTHY D. MARPOE, SR., Plaintiff, v. CRYSTAL A. MARPOE, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - y 7 v ~ CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND ~ OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Timothy D. Marpoe, Sr., by and through his attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Crystal A. Marpoe, representing as follows: 1. The Plaintiff is Timothy D. Marpoe, Sr., an adult individual residing at 421 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The Defendant is Crystal A. Marpoe, an adult individual whose last known address was 421 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on September 4, 1999, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN & McKNIGHT By: Marc r ,Esquire Supr Court I.D. No. 2 76 West P mfret Professional B 'lding 60 West Pomfret Street lisle, Pennsylvania 17013-3 22 (717) - Date: AUGUST 9, 2007 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. TIM THY RPOE, SR. Date: AUGUST 9, 2007 TIMOTHY D. MARPOE, SR., Plaintiff, v. CRYSTAL A. MARPOE, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's Office, 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: AUGUST 9, 2007 ~ ~~L _ TIM THY D. OE, SR. "w\~. `V ~" ~N 'V ~n I `TV V C-'f C_` ~4 ~J' ..~i~ _ f !_ ~'- ...~ rv ~~ -..J ~a K:". Ci ~ l.Q i7 ~~ V S '-~ _.~.y ~~ ~ ~:.: -s-j;.. ^t ~,. :_ ~ ~~s __` l ' ~ ~ ~l i ,+ a -' 1 TIMOTHY D. MARPOE, SR., Plaintiff, v. CRYSTAL A. MARPOE, Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO.1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 4742 CIVIL TERM IN DIVORCE . SS: NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Crystal A. Marpoe, on August 11, 2007, by certified, restricted delivery mail, addressed to her at Lowe's Home Improvement Warehouse of Chambersburg, 1600 Lincoln Way East, Chambersburg, Pennsylvania 17201, with Return Receipt Number 7004 1350 0003 7289 3419.. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties o Pa. C. ion 4904, relating to unsworn falsification to authorities. ~ MARCi~ A. Attorney for Date: August 14, 2007 ' C;ERTIFIE Q ftJII~IL FiEC; (Domestic Mail Only; No Insurance Cc u ~ E - N s ~ m p p Certltkd Fee w ~~~ • 300 D p N UN/T~ ~~ p ~ RrRRedept -- ~ ~ m p m `~ ~ °~~led sM 'I `'lid N , ~ e 6 Fees 7bta1 Posta ~ -- D ~ 9 I 47 g ~ O = ~ ~ o ..,. A ~.- p =~ caw ~ p N CRYSTAL A MARPOE ~ N~. ~ ~?~~ HOME IMPROVEMENT ~ o•Q ^ 2Delhrery deeir ^ Prfr~t your narrle and address on the rwerse so that rre can return the card to yau. ^ nttecn trde cand to the paa~ of the rr^ilp~ece. or on the lrnnt ff spare penntts. 1. /M1Mde Addressed to: ATTN CRYSTAL A MARPOE LOWE'S HOME IMPROVEMENT WAREAOU~R OF CHAMBERSBURG 1600 LINCOLDT WAY EAST CHAMBERSBiTR1C: PA 172fl1 a tson.~+a. X ^ ~: e. br ~Pnve.d wme) c. Date of DWvery ~r,~-t rmr(`t~ '6-11- D. is deWarY addiws ~IMerd from Item 1? ^ Yes tf YE3, er-ox dstivary addiass t~elow: ^ IJo 9. Servlos type ~J Cattllled MaN Cl ExpnesSMa[I ~j Rsphtwrld 09 Fisturn Reoelpt for Masse ^ IrMUSd Mdl O C.O.D. 1.IIrs111o1sdOdrsryt Ord 6ZiM 2• ~eHkan°~ 7004 1350 003 7289 3419 (itansAr nom serYkx /e6eQ - PS Form 3811. Fetxuary X004 Domestlc Ftetum Receipt ,-M-,sao ; c ~ ~ ; -r~ :~, „ =: ~ _ _ ~ r~~ ~ w ~ ~ Y `~t`3~i '' =u.. ~ *~ ~~ ~