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Home My WebLink About03-5190 LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant : NO.O'?>"5l90 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. 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 County is required by law to comply with the American 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 lease 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. JASON KOPPENHAVER, Defendant : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY oJ-.5; f~ : No. CIVIL TERM DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Lisa Koppenhaver, by her attorneys, the Family Law Clinic, sets forth the following causes of action for divorce and custody: COUNT I. DIVORCE UNDER 23 Pa. C. S. SECTION 3301 (c). 3301 (d). AND 3301 (a)(6) 1. Plaintiff is Lisa Koppenhaver, who currently resides at 2010 Lenox Street, Camp Hill, Cumberland County, Pennsylvania, since June, 2003. 2. Defendant is Jason Koppenhaver, who currently resides at 16 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, since August, 1999. 3. Plaintiff and defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on September 28, 2002, in Camp Hill, Cumberland County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since June, 2003. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff avers that defendant, in violation of his marriage vows under the laws of the Commonwealth of Pennsylvania, has offered such indignities to the person of the plaintiff, his injured and innocent spouse, as to render the condition of the plaintiff intolerable, and life burdensome. 9. 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, plaintiff requests the court to enter a decree of divorce dissolving the marriage. COUNT II CUSTODY 11. Plaintiff repeats and re-alleges paragraphs one through ten, as if fully set forth herein. 12. Plaintiff seeks custody of the following child: Name Present Residence Age 4 (d.o. b. 1/31/99) Adam Koppenhaver 2010 Lenox Street, Camp Hill, P A 17011 The child was born out of wedlock. The child is presently in the custody of Lisa Koppenhaver, who resides at 2010 Lenox Street, Camp Hill, Pennsylvania. During the past four years, the child has resided with the following persons at the following addresses: Persons Lisa Koppenhaver Jason Koppenhaver Justin Tomkinson Rick Tomkinson Linda Tomkinson Vicki Tomkinson Kevin Tomkinson Address 20 I 0 Lenox Street Camp Hill, PA 17011 Dates 1/99 - 8/99 Jason and Lisa Koppenhaver 16 West Keller Street Rear Apartment Mechanicsburg, P A 17055 8/99 - 6/03 Lisa Koppenhaver Justin Tomkinson Rick Tomkinson Linda Tomkinson Vicki Tomkinson Kevin Tomkinson 20 I 0 Lenox Street Camp Hill, PA 17011 6/03 - present The mother of the child is Lisa Koppenhaver, currently residing at 2010 Lenox Street, Camp Hill, Pennsylvania. She is married. The father of the child is Jason Koppenhaver, currently residing at 16 West Keller Street, Mechanicsburg, Pennsylvania. He is married. 13. The relationship of the plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Linda Tomkinson Rick Tomkinson Justin Tomkinson Kevin Tomkinson Vicki Tomkinson Relationship Mother Father Son Brother Sister 14. The relationship of defendant to the child is that of father. 15. The 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 or any other State. 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. 16. 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 moral, emotional, and physical surroundings as required to meet the child's needs; c) Plaintiff is willing to accept custody of the child and foster a relationship between the child and the Defendant. d) Plaintiff exercises parental duties and enjoys the love and affection of the child; e) Defendant only has seen the child three times for short periods of time since the parties were separated in June, 2003. Defendant has not sought a schedule of regular contact with the child. 17. 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. WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of her children. Date i/ 3 t!) /0.3 4-L- Heather Fine Certified Legal Intern '1!../AJLf,f// THOMA~/M PLACE ~ ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)-243-2968 VERIFICATION I verify that the statements made in this Divorce Complaint with Custody Count are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: If J... q {O,,> ~!~ y :>l ~ --;:,,;.;, n~l [-' .~/ ~>'; :i~ ( ~( (') " C::.'.' :") ;q Q ',,) ':'J ::-; o (") ",1. .-) ~ - i ,I:) ,C_) , n :;: ') !n ,~ . t:? <:0 ~~ LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant ~ No.03-57~IVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Lisa Koppenhaver, Plaintiff, to proceed in forma pauperis. I, Heather Fine, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Date: rj.f03 ~z- ~ Certified Legal Intern ~t~-( R B . RAINS "{!; THOMA M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 o c (fr/?~'- iI-" ~.~ ;:-:- ! o-!.;':: ..i~_ ' ~. - ~ ~ - -" r-, c..-;' '-") :~?7 '0 -) (-, -.' _~J LISA KOPPENHAVER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-5190 CIVIL ACTION LAW JASON KOPPENHAVER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 08, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 06, 2003 at 9:30 AM for a Pre-Hearing 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. The court hereby directs the parties to furnish auy and all existing Protectiou from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Jacqueline M. Verney- Esq. Custody Conciliator c The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible faciliti,:s 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 ATTORJ\IEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ ~ r ~ ~ ~ ['(/-170/ ..#p ~ ~ ~IL. ['~.P t?/ X?fJ Z;~~ ~ U?tJ.t71 'iIIN\I'lI.1ASi\!N3d jJJ\ln~' "I' ',-. '--"V ~O I' ,'" ',"'1'., ... "f" . "",' '.,.- ',,' " ...i ,j ~ t 9S :Z J.!d 6 -- J.JU CO /\UVlC,:<,,, ;~.-' 1). ~j() :C;:,L LISA KOPPENHAVER, Plaintiff v. JASON KOPPENHAVER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTlON- LAW : IN DIVORCE AND CUSTODY : NO. O.3-SI"fo CIVIL TERM CERTIFICATE OF SERVICE I, Heather Fine, Certified Legal Intern, Family Law Clinic, hereby certifY that I served a true and correct copy of the Complaint for Divorce and Custody on Jason Koppenhaver, at 16 West Keller Street, Mechanicsburg, PA, 17055, by depositing 81 copy of the same in the United States mai], certified, restricted delivery, return receipt requested. Service was complete upon receipt by Jason Koppenhaver on the 21" day of October, 2003, as evidenced by the attached green card. ai ~ ~ ,~ _ > 0- o.'e.=a . g!!"5E '~:6 ~~ 51'0 c__ . <.!Il oi1o~ c.; ~i CJ~ ~ -g.~-c~.2l 0- C'Cl~i-G)8 " "O~=[ .....:'2 ai!.s Ul .2 "0 CD "0'" 1 E:SEfacac . ~m2!u~,g G)a: 5~:.2 II) ~ 15:!:: 0 _ +'.c .;f o.."<t ~~ij~ ~ . EEc-aso 0 8~ir51~o ~ . .. ,....: ~ . ~ . ~ ~ " 0 .Q 15. ~J ~ .. ~ Eo .f c. tl d ~ oll a: cj ~ ol2lo I!! ~ ~ 'ffi 'ffi.2: i!." 1l" ~ dH~ '~~~~E ~ ~~D ~ M ..t ~ 1 ~ ~ a ~ , .........,...... I)- ~ l:f ~ ~, ~ :> $ . ~ jl~ ? Heather Fine Certified Legal Intern ~ \;l' <;)- THE F AMIL Y LAW CLINIC 45 North Pitt Street Carllisle, PA 17013 (717)-243-2968 " oj P1" n"; ~~; ~). ~,. ~~ -- c.:> -") ~--I i'.) c-. ~-o :",) \.0 NOV 0 7 2003 ~ l5 LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-5190 CIVIL TERM JASON KOPPENHAVER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this /0'" dayof,J ~ , 2003, upon consideration of the attached Custody Conci]iation Report, it is ordered and directed as follows: 1. The Mother, Lisa Koppenhaver shall have sole legal custody of Adam Koppenhaver, born January 31, 1999. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical eustody at such times mutually agreed upon by the parties. 4. This Order is entered following a Custody Conciliation Conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. Father may modify the provisions of this Order by filing a Petition for Modification with the Court, at which time the matter will be referred again to a Conciliation Conference. J. cc)-Ieather Fine, certified legal intern Anne MacDonald-Fox, Esquire, Family Law Clinic, Counsel for Mother /fason Koppenhaver, Father 16 West Keller Street, rear .1 .~. Jy Mechanicsburg, P A 17055 6'\ :I': r. ~~~19 <<' ~ \iiNVmASNN3d "~I(V"'" ""'r".""'^'n'" f\.Li~, :1).; , ,! '., ,"t~,::j':;(-", V as :}; \~d 0 I hUN f:O A!:i'71C\). ., 381~j0-<L~rn:,; .(() -v LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2003-5190 CIVIL TERM JASON KOPPENHAVER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Adam Koppenhaver January 31,1999 Mother 2. A Conciliation Conference was held in this matter on November 6, 2003, with the following individuals in attendance: The Mother, Lisa Koppenhaver, with her counsel, Heather Fine, certified legal intern, and Anne Ma(:Donald-Fox, Esquire, Family Law Clinic. Father, Jason Kippenhaver did not appear, although he received notice of the conference. 3. Mother requested an Order in the form as attached. II~ ~()) Date ~.E~!~ Custody Condliator Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EICHELBERGERS, INC. vs. CIVIL ACTION - LAW M. H' DIELECTRICS, INC., Defendant NO. 03-5197 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO: Curtis R. Long, PROTHONOTARY Cumberland County Court of Common pleas One Courthouse Square Carlisle, PA 17013 please enter a Default Judgment in favor of Plaintiff, Eichelbergers, Inc. and against M.H. Dielectrics, Inc., Defendant, in the amount of $3,172.00, plus all costs of this action, attorneys' fees and any fees and interests. Written notice of Plaintiff's Notice of Intention to file for Entry of Default Judgment was mailed to the Defendant and is attached to this Praecipe as Exhibit "A", along with a copy of correspondence sending the Notice and copies of the certified mail receipts. Respectfully, Pa. I.D. , Esquire 9475 Je~~~~~p, Esquire Pa. I.D. No. 86556 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorneys for Plaintiff, Eichelbergers, Inc. .. EICHELBERGERS, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW M. H. DIELECTRICS, INC., Defendant NO. 03-5197 CIVIL TERM TO: M. H. Dielectrics, Inc. One Mountain Street Mt. Holly Springs, PA 17065 ~~ ,-_.: -.. ~ DATE OF NOTICE: November 6, 2003 IMPORTANT NOTICE ~ , :s -< c;~ __"0.' -, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Cumberland County Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 B4~/;~ E,quice Pa. LD. ~~9475 By: ,,",Li.~1ll'~ Jen~l~f~r B. Hipp, Esquire Pa. I.D. No. 86556 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorneys for Plaintiff, Eichelbergers, Inc. EXHIBIT IIAII .-----'" J.~;,IES 0, BOG.~? ATTOR~E, \T UW ONE WEST ;vL\[;'\J STkEt:'i SHIRE~,[A~STOWN ?E:.rNS'rj;- \,\Ii.:\ e-mail cllaiL]'ho}.c' "y"'"):n i::~;::?~.C:ii: JAMeS 0 BOGAR JEi'lNIFER 8. HIPp. -:-: i"; 737-87.51 ~.-\-'::S: M:~;:: -L' 737.2086 'Also admined to :-k,vJer:rey ear ':;if"'~l -c. :~.l:: ,.hl~~sb0gariaw,~om N'C\2::tbe:::: J 20J3 VIA CERTIFIED ~L~~~ M. E. Dielectrics, Inc. One Mountain Stree~ M~. Ho:ly Springs, PA 1~C6S ~~: Eichelbergers, Inc. v. f.'!. E. Dielectrics, I:-:..c. No. 03-5197 Civil Ter~ Dear Sir or Madam: WA are e~clos:ng ::= se=vlce e~o~ you a Notice of Inte~~ic~ to File Default Judgme~:. Please contac: us i: you ta72 2~j ~uestions. Very truly yours, JZ~~~ ~ ~tIPe E::cl.cst.:.::-e cc: Ei~telbergers{ Inc. .~~::tr.. : James A. Baird, CPA, Vice Pres_dent 8f clna~ce .~ e~c~. CE?_TIFJ:~=' H..:1..IL NO. 7002 2J3C! 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CD ~ _.,,= !l 0" ~. ~ =::: ~ 0 2S: '<~~.~ ~ 1--1 ~ ~,....(1) c. "1 = n ~ ,.... CIJ'" ~ ...~. al .., ('l . ~.al "'O~ :> ~ ('l .... 8 <:'" .. - o · m ..... )> r.o '1J-' o=O:::!..$"() ~ :J~:ra3~ :3 :f::!.'< J:l,."C W (])~~g::o;$" ... ~1ii"(1)""':OCD f g" 0 ,,::I (]);:;: - _QJQ) cnS2 . ;;a.::J35::3 :;: (lI _ CD CD $l CoO i3 i~2'~~-"'" ... n i3 o.ON AI (]) l>> m ~ t: ~ g-i8:~~ · 30oCiCDo' =--- ~ag:;~ ~ . :rog a.tn ijj CD '< _ ctl 0 rI. 3oi~g -. irJj ritd9 >< ~ (,...> a. -. :D sn < - ~ ::."" ill ~ ~ 11 ~ 51 ~ ~ 7~ ~ ~ c:'" ~ ~ "7\) \,,~ ~r ~ ~'-',~ ~.... -.) _ 3, ",j;. e. (i a" .. 5- ~ \f'~ ~ ~ (' ~ ~ ~~ DODD r:..lii' ~~iS:)> ~'ii (fj a. '5l ~ 9- ;;a <:'\.0 ~ "I!. ~ ~~f -< CERTIFICATE OF SERVICE We, James D. Bogar, Esquire, and Jennifer B. Hipp, Esquire, hereby certify that we are this day serving the foregoing Praecipe for Default Judgment as required by Pa. R.C.P. 237.1 upon the following named corporation this day by depositing same in the United States Mail, Certified Mail, Return Receipt Requested, at Shiremanstown, Pennsylvania, addressed as follows: M. H' Dielectrics, Inc. One Mountain Street Mt. Holly Springs, PA 17065 B (I. J~~/()t... ~J~ D. Bo a , Esquire Pa. I.D. No. 475 By: Jenji71B~~p, Esquire pa~~~. No. 86556 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorneys for Plaintiff, Eichelbergers, Inc. Date: November 19, 2003 , .. ~ ~ ~ ~~~ ~ -.... l.\ ~ -{:, " -<. e I ~ , f\ ~ ~ -! l ~ "- "'- ..... ~ ~ c' c' (0- '- " _... .. :~ - 1.[,) ~',J -" LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant : NO. 03-5190 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(C) of the Divorce Code was filed on September 30,2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have lapsed from the date of filing and service ofthe 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. 94904 relating to unsworn falsification to authorities. Date: ~f f-()L CJ c; .'. , c c..: " :::j -< ...., = cc> G' -" ....... co o -n .... :r: """T'! rnF: -om -DO ?..) ~ ~?~{ C2f') t:::rn -~ % :.< oJ::> 5: c...n (.)'1 LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant : NO. 03-5190 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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. 9 404 relating to unsworn falsification to authorities. D,,, ~ {'J / ()l-/ ~~ ...., = c:;') ...- ..,., Pl c:J (') 41 ::;-2 rc;lp2 -nIT; "')'7 ~j~ ~~ :;;;,.(") ,:.:;(T: ~~5 -~ UJ ~7' U1 VI LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA V. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant : NO. 03-5190 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Macht, hereby certify that on this date I am serving a true and correct copy of Plaintiffs Waiver of Notice of Intention to Request Entry of a Divorce Decree Under 93301 (c) of the Divorce Code and Plaintiff s Affidavit of Consent, by first class mail, on the Defendant, addressed as follows. Jason Koppenhaver 16 West Keller St. Mechanicsburg, P A 17055-6339 Date:#1 ~A~IA!I~ Michael Macht Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 o ~~,; ,..., co> (:::.;) .r' ..., r"'1 c:l cO :"'--:1 .< ~: o -n :::! f'hp -am ::Dy '8~ <..1"\1 C) ,-, :iQ en .s:- LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYL V A IA v. : CIVIL ACTI0N- LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant : NO. 03-5190 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(C) of the Divorce Code was filed on September 30, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (9 ) days have lapsed from the date of filing and service of the complaint. 3. 1 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. 1 understand hat false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to un orn falsification to authorities. Date: ~ -! 6 -Oil LISA KOPPENHAVER, Plaintiff : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYL V A IA v. : CIVIL ACTlON- LAW : IN DIVORCE AND CUSTODY JASON KOPPENHAVER, Defendant : NO. 03-5190 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVOR E DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by t e Court and that a copy of the decree will be sent to me immediately after it is lied with the prothonotary. 1 verify that the statements made in this affidavit are true and correct. I understand t at false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 404 relating to uns om falsification to authorities. Date: 1/ - It, - 04 Lisa Koppenhaver, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V A IA v. : CIVIL ACTION - LAW : IN DIVORCE Jason Koppenhaver, Defendant : NO. 03-5190 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for ntry of a divorce decree: 1. Ground for divorce: mutual consent under Section 330 I (c) of the Divorce Code. 2. Date and manner of service of the complaint: October 21,2003, by United States mail, certified, restricted delivery, return receipt requested. 3. Date of execution of the Plaintiffs affidavit of consent required by S 3301(c) oft e Divorce Code: by Plaintiff - February, 14, 2004; by Defendant - November 16, 2004. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: February 4, 2004. Date Defendant's Waiver of Notice was filed with the Prothonotary: Novem er 22, 2004. ~ tc . I IuJl (;^.~ Mic ael Macht 4 Date /.:l ~tt Certified Legal Intern F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 'f'f.:+::+::+: :+::+: :+: +:+::+::+::+::+::+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~+~~+:+:+':+:~+~'f~~+:+::+:+:+:+:+:+~~+'~~:+:++,++:+:+,:+:+,+,~+,~~,+,,+,+,,+,+,~+,~~++++'++'+'++'f+~~:+:+,+,++ '+':+::+::+: +. +:+::+: +.:+:+:+::+: +:+: 'f:+::+: :+::+:+':+::+:+':+:+:+:'f:+::+::+:'+':+:'+':+:+++:+:+:+:++++++++':+:+'+'+++++'+'+'~ . . . . . . . . . . . . . . . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + ++~,+,+,+,+.+I' IN THE COURT OF COMMON PLEA OFCUMBERLANDCOUNTY STATE OF PENNA. Lisa Koppenhaver No. 03 5190 Plaintiff VERSUS Jason Koppenhaver Defendant DECREE IN DIVORCE AND NOW, ..,. c,,-~..... ~ 7 ~/:Ji ~. )001/, IT IS ORDERE AND DECREED THAT Lisa Koppenhaver , PLAINTIFF, AND Jason Koppenhaver , DEFENDAN , ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA YET BEEN ENTERED; O,)t" B ATTEST: PROTHON HAVE NOT TARY J. . ~ :? /f7~" ~2L 5'(/0'./ . 7:d ~ r~"" 4~.~ 5??S',/ '" J ,~